IGD 1019: MANAGEMENT OF CHANGE PROCEDURE
This Interpretive Guidance Document (IGD) establishes the formal procedure for a structured Management of Change (MOC) process. This document provides guidance to address a change in the organizational structure, process, legal requirements, or other requirements when the change has the potential to affect the environment or DLA Strategic Materials’ Environmental, Safety, and Occupational Health Management System (ESOHMS) performance.
This MOC procedure provides a framework to identify a change and then evaluate the change for potential environmental impacts. Implementation of the MOC procedure is required so that environmental considerations, including regulatory compliance, are taken into account when changes occur.
2.1 Responsibility and Authority
The Environmental, Safety, and Occupational Health (ESOH) Management Representative (EMR) has the primary responsibility and authority to monitor the ESOH Management System (ESOHMS) including the need for changes to the ESOHMS. The primary responsibilities of Depot managers and action officers are defined in IGD 1006 and include implementing changes and maintaining documentation. Exhibit 1 illustrates the MOC process described in Section 2.2.
2.2 Assessing and Documenting Management of Change
- Any DLA Strategic Materials employee contemplating or aware of a change outside of normal DLA Strategic Materials procedures should notify the EMR. A change outside of normal DLA Strategic Materials procedures may include, but is not limited to, the following:
- Organizational restructuring, including hiring of new employees
- Change in legal or other requirements
- Mission changes
- Construction or demolition planning
- Proposed engineering/operational changes to equipment or processes
- Proposed procedural changes/revisions, including work practices
- Purchase, sale or acquisition of new equipment, chemicals, or materials
- Once notified of the potential change, the EMR should form a MOC Review Team of at least two potentially impacted DLA Strategic Materials employees. If the potential change could impact a Depot, a knowledgeable Depot representative must be included on the MOC Review Team.
- The MOC Review Team must meet to complete the MOC Checklist provided in Appendix A. If there changes in identified in Appendix A, Section 3, the MOC Review Team will also establish action items intended to address or further research the environmental impacts of the potential change. Action items will be documented in the Appendix A, Section 3 table.
- The EMR reviews the completed MOC Checklist.
- Once approved by the EMR, the MOC Review Team begins implementing actions outlined in Appendix A, Section 3 table. The team will track action items completion, documenting results in the Appendix A, Section 3 table
- Once the actions are complete and documented in Appendix A, the EMR or a MOC Team representative must sign acknowledging that actions are complete and the project may proceed.
- Completed MOC checklists and associated records or documents should be maintained in accordance with IGD 1016 and IGD 1009, respectively.
- If an Environmental Assessment or Environmental Impact Statement is being done via the National Environmental Policy Act process in lieu, the MOC process is unneeded.
3.0 EXAMPLES OF ESOHMS SUPPORTING DOCUMENTATION REFERENCES
3.1 Management of Change Process
3.2 Management of Change Checklist