these changes are supported by the design requirements, the associated change mechanisms need
attention. Corrective actions should be initiated promptly where necessary to prevent unauthorized,
unreviewed, improperly controlled, or poorly documented changes.
The conditions that initiate the change mechanism and the organizations that use the change
mechanism should also be documented. This information will support the evaluation of potential
consolidation of existing change mechanisms. It will also be useful as a starting point for a listing of
change mechanisms that should be Included in the governing change control procedure.
126.96.36.199 Change Process Elimination, Consolidation, and Upgrade
For each change mechanism, a determination should be made as to whether it will be retained,
improved, or terminated. When deciding which change mechanisms to retain, consideration should be
given to (1) the extent and impact of improvement actions necessary to eliminate deficiencies and
weaknesses and (2) potential consolidation with other similar change processes. The ability to
effectively manage many change processes should be considered. Consolidation of a deficient change
process with a similar, acceptable change process is often preferred to upgrading the deficient process.
A typical facility may have a number of different organizations making changes to the facility using
many different control mechanisms. As a result, unnecessary management and control problems can
arise. To minimize these problems, consideration should be given to consolidating as many types of
changes as practical into a few well managed control processes for use by all facility personnel. For
example, various temporary physical change mechanisms, regardless of which organization (e.g.,
Engineering, Operations, Maintenance) is making the change, can be consolidated into a single
For each change mechanism retained, upgrade actions should be defined to bring the process into
alignment with accepted methods and requirements established by the change control program
element. For example, the temporary change control process might be upgraded to include the
following needed features: technical reviews of proposed temporary changes prior to implementation;
preparation and distribution of interim, marked-up drawings and procedures for use by operators and
other facility personnel; and periodic assessment (e.g., at least every 6 months) of the continued need
of the temporary change until removal.
Change processes should be streamlined and efficient to ensure that they are used. Also, they should
be enhanced to accommodate change faster and easier. Change processing should be defined by
procedure for each approved change mechanism. Streamlining of internal program forms and
documents is important to improve comprehensibility and ease-of-use. This applies throughout the CM
program, but is particularly applicable to change control, which directly interfaces with the most
organizations and personnel. Effective internal forms and documentation associated with change
control have the following attributes: they facilitate complete and timely change identification and
control, they are user-friendly and encourage participants to use them, and they provide for
management tracking and reporting.
Upgrade and consolidation of change mechanisms typically include revised procedures, revised forms,
and associated training. Active involvement of the process owners in answering questions and
providing clarifications can be critical to a smooth transition to new or different processes. An
effectiveness review of the upgraded or consolidated processes after 6 to 12 months can be very useful
in defining further improvements and efficiencies.
The initial development of the change control element is complete after the change control processes
have been identified, reviewed, consolidated, upgraded, and determined to be acceptable.