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    SUMED R B PETROLEUM PIPELINES COMP NY

    Management Of hange Procedure

    0 25-May-12 First Issue

    Rev Date Revision Prepared By Approved By

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    TABLE OF CONTENTS

    1 INTRODUCTION ............................................................................................................... 3

    2 TYPE OF CHANGES ........................................................................................................ 3

    3 PROCESS OF MOC .......................................................................................................... 5

    4 PROCEDURE .................................................................................................................... 7

    5 CHECKLIST ...................................................................................................................... 7

    APPENDIX 1 - MANAGEMENT OF CHANGE FORM ......................................................................... 8

    APPENDIX 2 - MANAGEMENT OF CHANGE FLOW CHART .......................................................... 10

    APPENDIX 3 - MOC SAFETY CHECKLIST GUIDELINES .............................................................. 13

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    1 INTRODUCTION

    Any facility or operation is subject to continual change. Changes often are made in equipment,materials and processes to increase productivity or to correct hazards. In some cases, temporary

    adaptations, connections, bypasses or other modifications are made to the facility or process.Although some changes are more critical than others, each modification should be analyzed forinherent hazards that may result from the change.

    To assess the impact of change and to monitor its implementation a policy and procedure forManagement of Change (MOC) is applied to all SUMED managed sites and operations.

    No modification shall be made to a plant, equipment, control systems, process conditions, andoperating procedures without authorization from a responsible manager or his delegate.

    Proposed modifications must be evaluated for Safety, Health and Environmental impact and a signeddocument should be available before the change can be implemented.

    The Management of Change Procedure (MOC) is geared to safe process and equipmentmodification.

    2 TYPE OF CHANGES

    2.1 In-Kind/Not In-Kind change

    In Kind change is a replacement that satisfies the design specifications.If it is proposed to replace a piece of equipment with another that is functionally identical and of thesame specifications, the change is In-Kind and does not require an MOC process.

    Equipment replacement is considered In-Kind if it meets the following criteria: Material specifications (dimensions, weight, etc.) are the same.

    The service for which the equipment is being used remains unchanged. All process conditions

    must remain the same as for those of the original item. Inspection and maintenance

    requirements should not change.

    The replacement is part of routine maintenance. The In-Kind item is being replaced because it

    has a known life span.

    Replacing In-Kind equipment that is failing without known cause requires investigation and analysisof the cause and MOC.

    2.2 Small/large change

    Large changes usually involve many modifications to system and administrative procedures, andtherefore should receive a full MOC review. However, small changes may not be reviewed with thesame rigor because they can be implemented quickly and do not appear to make a significant impacton the way a plant operates. MOC reviews, at least through a checklist, should accompany evensmall changes.

    2.3 Emergency change

    Emergency change is one that has to be made very quickly when someone in authority decides thatthe dangers of doing nothing are greater than those possibly associated with the proposed change.

    An emergency change may be justified for reasons such as the following: danger to personnel

    potential for major equipment damage

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    potential for major operational loss

    serious environmental impact

    serious community complaint

    regulatory violation

    Every effort must be made to minimize the number of emergency changes, because they bypass thenormal systems for hazard identification. After the fact, every emergency change should be reviewedby the formal MOC procedure to ensure that no unforeseen problems exist and to ensure the changeis documented and monitored.

    2.4 Temporary change

    In many instances temporary changes also are emergency changes. They usually are implemented tokeep an operation running while a piece of equipment is repaired or replaced. A temporary changeshould have a termination date.

    A temporary change of even a short duration should go through at least a Safety Review Checklist(see Appendix). A new procedure should be written and an emergency response prepared in case themodification does not work properly.

    2.5 Infrequently repeated change

    Infrequently repeat changes are those that have occurred at least once before and are repeated atinfrequent intervals. If a change has been carried out before, and if it was properly managed, theMOC process generally will not need to be repeated. However, it needs to be stated in the MOCrecords that this is the case.

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    3 PROCESS OF MOC

    The process for management of chnage is described as follow:

    3.1 Initiation

    Generation of an improvement idea or a solution to a problem. The person who makes the initialrequest is called the Initiator. Usually the Initiator is a manager, a supervisor or an engineer. However,all employees and contractors should feel free to propose changes they feel will make the facilitysafer, cleaner or more profitable. Participation of all employees is crucial if continual improvementsare to be made.The proposed change should be discussed within the department team and department supervisor.

    Determine if the change is In-Kind/Not-In-Kind. If the decision is made that the change is In-Kind, thenecessary action can be taken without further review or analysis, and the formal Management ofChange process is not pursued.

    If proposal is feasible then a formal Management of Change process shall be initiated.

    The formal MOC process is initiated by issuing a Request for Change (RFC) form (as per attachedform).

    The form shall contain the following information:

    Administrative information

    The first part of the form provides all the administrative information and the basis for the proposed

    change and includes the following: Change proposal title.

    Change category (Technical, Organizational or Administrative or Other).

    RFC number to be assigned by change coordinator, location, department, and date.

    Type of change whether the change is deemed emergency, permanent or temporary and, if

    temporary, its time frame.

    Criticality (risk ranking) of the problem.

    Change description /description of the problem

    The person(s) requesting the change shall clearly define the idea to be implemented or problem to besolved or outline the opportunity for improved performance. This will be the basis for other evaluationsof the situation. Also where applicable attach associated drawings and P&ID(s).

    The Initiator shall explain why he believes action must be taken. This could be for any combination ofthe following reasons:

    Safety

    Environment

    Operations

    o Increased production

    o Increased productivity/efficiencyo Reduced energy consumption/losses

    Maintenance

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    o Reduced maintenance costs

    o Reduced spare parts inventory

    Public relations

    o Public response

    o Other plants in the area

    o Other companies using similar technology

    Regulatory requirements

    Risk vulnerability (refers to those changes that are made to reduce risk, even if an incident has

    not yet taken place)

    3.2 Detailed evaluation

    Evaluation and review of technical, operational, safety, environmental, quality and economical

    aspects of the change, the evaluation is performed by a team ( committee) representing differentdisciplines according to the nature of the change.

    Sector manager or higher authority should nominated the team (committee) and also nominate thechange manager assigned to follow up the change, the change manager may be the team leader orone of the team members or the initiator.

    The team members should have experience and knowledge of the process under review andknowledge of similar problems that occurred in the past and actions that were taken to solve them.The Team members should have multidisciplinary technical knowledge in areas related to theproposed change.

    The team shall make an initial assessment of the chnage and the proposed solution and add relevantinformation and suggestions based on knowledge and experience.

    Having selected the Review Team, the next step for the change manager is to plan the work flow andestablish a schedule that will make sure the evaluation stays on track while also making sure thatpeople have enough time to think about what is being proposed. Scheduling may require coordinationwith other departments or functions.

    Once the Reviewers have completed their analyses, a final report shall be issued by the evaluationteam with all of the comments and ideas that have been generated, and summarize and analyze themand the action that should be proposed. This report will be presented to the management.

    Attach to the MOC form all related team minutes of meetings (MOM) and opinion of all involvedparties and also the final report.

    3.3 Approval

    Before a change can be implemented, it must be formally approved and accepted by themanagement.If more than one solution is presented, the management shall select the most appropriate of thosepresented.

    3.4 Implementation

    Once the change is approved the change implementer(s) with change manager shall developimplementation plan, purchasing & contracting specification and all other related activities.

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    3.5 Information Updating

    After implementation and completing outstanding work, implementation team and change managershall update all relevant documentation such as product specifications, operating procedures, control

    logic documentation, alarm trips schedules, drawings and manuals, pressure test certificates,cleanliness certificates, training records, etc.

    3.6 Training

    Ensure that affected employees and contractors are trained on the impact of the change prior to therestart of the changed process.

    3.7 Verification

    The change must be verified to ensure that it is in accordance with the change note and all relevantrequirements prior to restarting the Changed Process.

    4 PROCEDURE

    A typical Management of Change flow chart and RFC (Request For Change) Form are attached.

    5 CHECKLIST

    The suggested Management of Change checklist should be used in the initial stage to ensure that allsafety aspects are covered and no omissions have been made.

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    APPENDIX 1 - MANAGEMENT OF CHANGE FORM

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    REQUEST FOR CHANGECHANGE PROPOSAL TITLE:

    Technical MOC RFC NUMBER:

    Organizational MOC LOCATION:

    Administrative MOC DEPARTMENT:

    OTHER:

    Emergency Permanent Temporary From: To:

    Risk rank : Low Medium High

    Change Description /Description of problem: use extra sheet if required and associated drawings

    Target Outcome / benefits

    Proposed by: Date:

    Reviews

    Functional Area Name Agree / Disagree / NA By initials & dates

    Review meeting MOM and signed final report can be attached instead of filling the previous table.

    Approval of ChangeName Title Signature Date

    In case of rejection Reason for rejection:

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    APPENDIX 2 - MANAGEMENT OF CHANGE FLOW CHART

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    An Idea to Implement orsolution to a problem is

    conceived

    Prepare Request ForChange (RFC) form

    Initiator /supervisor

    Change Evaluation /

    Modification / Adaptation

    Sector Manager

    Is the change within sectormanager Authority?

    Sector Manager

    Create a review team (committee)from all involved department.

    Assign a change manager and/orchange coordinator

    Refer to other /higher Authority

    Documentreason and

    archive

    Reject

    YES

    NO

    Accept

    Issue a report to managementwith results and requesting

    Approval

    Change manager + committee

    ApprovalRequest

    NO

    1YES

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    APPENDIX 3 - MOC SAFETY CHECKLIST GUIDELINES

    1. Location - evaluation

    Explosion/fire Noise

    Utilities available

    Ground stability - foundation

    Drainage

    neighboring activities

    Mobile crane and FLT accessibility

    Site traffic control

    Third party risks

    Hazard quantifications

    Soil contamination

    2. Equipment selection specifications

    Pre-purchase analysis

    meeting design criteria and purchase order specifications

    3. Material selection specifications

    Compatibility with product use

    Meeting/exceeding wall thickness and/or desired pressure

    cleaned when required

    Electrical motors, panels, components and wiring conform to standards

    Fitness for intended purpose

    4. Codes

    do equipment and/or processes comply with applicable codes

    Pressure vessel and piping codes

    Fire protection

    Electrical

    Noise

    Emissions (air, water)

    5. Cleaning procedures

    oxygen cleaning

    scrapped equipment to be cleaned

    6. Welding/ brazing/testing procedures

    Special welding requirement with regard to materials, procedures or operating conditions

    Welding certificate

    Radiographic inspection requirement

    brazing material, cryogenic/non cryogenic

    Welders qualifications

    7. Pressure testing

    Approval test procedures available

    Hydraulic testing required Pneumatic testing

    Recording of testing done

    Pre-tested piping used - certificates yes/no

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    Safety distances

    Certification by official bodies

    8. Pressure protection

    Relief valves / bursting disc required due to pressure - temperature

    Relief valve in cryogenic piping between isolation points

    Relief devices on liquefied gas lines

    Over-protection pressure gauges

    Pressure protection vacuum system

    Under pressure protection system

    are pressure protection reliefs and bursting discs suitably sized + safety routed/vented

    9. Temperature protection

    safeguard personnel from hot/cold surfaces

    alarms provided for high/low temperature in process

    low temperature embrittlement of materials possible materials protected against high temperature

    10. Electrical system

    Electrical system conforms to regulations

    Grounding protection

    Identification voltage

    Main shut-off switch

    lock/out capability

    Emergency switch

    Remote start/stop switches

    Electrical isolation considered Back-up system

    overload protection electrical equipment

    HV-transformers and cabling adequately isolated

    Equipment adequate protected against collision damage

    11. Process equipment isolation

    Easy access to manual isolation valves

    Response time automatic isolation valves sufficient

    fail safe isolation requirements met

    12. Fire protection Hydrant available/accessible

    Fire hose lengths adequate to reach equipment area

    Fire extinguishers

    Alarm system at or near equipment area

    automatic systems required

    fire detectors

    13. Equipment guards - protective shields/barriers

    Machine guards on rotating equipment

    guard rails

    Bumper posts

    oxygen flash protective shields/barriers

    noise reduction

    14. Ventilation/air monitoring

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    Release of inert/toxic flammable gases possible

    Present natural ventilation sufficient

    forced ventilation required

    TLV values considered

    monitoring required (e.g. 02 level)

    Local aspiration required

    15. Access to control equipment

    locate to be maintained easily

    install stationary ladder, platform, guardrails

    16. Labeling (piping, panels, etc.)

    Process identification by labeling

    Chemical lines

    Process piping

    High voltage identification Flammable storage

    Toxic storage

    17. Drawing updates

    Construction drawing

    P&I diagrams

    Electrical diagrams

    Instrument loop diagrams

    Fire protection diagrams

    18. Warning signs/warning devices Mandatory signs in place : atmospheric hazard warning chemical hazard warning flammable

    Product warning automatic machine start warning

    Back-up (power, instrument air)

    Alarms and signalization

    19. Environmental emissions/ Permits

    noise within limit (industrial residential)

    air emission control/testing; required permits available

    water discharge

    contamination municipal sewer possible contamination canals, etc. possible

    permits available contaminations of soil or groundwater possible

    control of combustion equipment (boilers, etc.)

    Spillage Control

    20. Hazardous waste

    waste accumulation and quantity

    permits required

    storage and disposal procedures

    disposal route according law

    disposal of non hazardous

    21. Product control measures MSDS for Chemicals available.

    22. Access and Egress

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    Exit doors not blocked by equipment or piping

    equipment room doors equipped with panic bar

    area lighting adequate, emergency lighting available

    eliminate tripping hazards on exit routes

    where required, stairs and/or permanent ladders provided to aid egress

    two exits where necessary

    23. Tripping hazards

    conduits, pipes, valves, etc. not located in walkways

    eliminate tripping potential

    floor opening covers level with grade

    storage does not protrude into walkways

    24. Sharp edges - Protruding obstacles

    round off sharp edges or give protection

    Clearance on overhead pipes etc. valve handle direction away from persons

    25. Equipment lockout capability

    electrical

    mechanical

    26. Emergency shower/eve wash

    chemicals used requiring special wash

    27. Emergency procedure

    emergency plans to be revised special training required

    28. Operating procedure

    operating procedure to be revised

    additional job training necessary

    safety aspects recognized

    revision of pre-start and post stop instructions

    Workplace risk assessments/Job Safety Analysis available or completed.

    29. Contractors

    selection

    training

    co-ordination

    supervision

    work permits

    30. Operators training

    training should include but is not limited to:

    start-up/shutdown procedure

    instrumentation control method

    operating temperatures and pressures

    alarms and shutdowns

    vibration control electrical isolation procedure

    normal log control - i.e. daily temperatures/pressures, etc.

    confined space entry procedure

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    emergency procedures

    31. Personal protection equipment

    other than "normal" equipment required

    respirators

    fire resistant clothing

    Chemical protecting garments etc.

    32. Lifting devices - Lifting

    well balanced eyebolt or similar on equipment

    Warning : single point hoisting/lifting might overstress the lifting device, causing rupture

    Control weight restrictions and movement.

    FLT training33. Control of constructors

    introduction training, incl. asphyxiation- and fire hazards

    work permit control of cranes

    product hazards

    digging operation/excavations

    34. Software Changes

    Control loop changes

    Addition or deletion of software modules

    Restructuring of loops

    New control loop

    Putting loops on or off.

    35. Critical Trips/Interlocks.

    36. Spare Parts Identified and ordered.