Application of Process to Management of Change and Modifications

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Hazard Study Process GBHE-PGP-006

Application of Process to Management of Change and Modifications

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Process Safety Guide: Application of Process to Management of Change and Modifications CONTENTS 1.0 PURPOSE 1.1 THE NEED FOR MODIFICATIONS 1.2 GENERAL DESCRIPTION OF A MODIFICATION

1.3 PRINCIPLES TO BE FOLLOWED 1.4 REPLACEMENT OF ’LIKE WITH LIKE’ 1.5 REMOTE / SMALLER SITES 1.6 GENERAL GUIDANCE TO INDIVIDUALS DOING SHE ASSESSMENTS

FOR MODIFICATIONS 1.7 MODIFICATIONS HAZARD STUDY DECISION MECHANISM 1.7.1 Purpose 1.7.2 Methodology FIGURE 1 MODIFICATION FLOWCHART M1 Title, description, registration and process flowsheet

Gate 1 Preliminary authorization

Table 1 Difference between a Modification and a Project M2 Risk Assessment

Gate 2 Approval



M3 Detailed design and implementation

Gate 3 Pre-commissioning check M4 Commissioning

Gate 4 Commissioned M5 Final review and file APPENDIX APPENDIX A CHECKLIST FOR MODIFICATIONS APPENDIX B DOCUMENTATION PROMPT LIST APPENDIX C TYPICAL MODIFICATION FORM

G1 PRELIMINARY AUTHORISATION M2 PRELIMINARY SSHE ASSESSMENT

G2 REVIEW PRELIMINARY SSHE ASSESSMENT M3 DESIGN and ESTIMATION

SSHE ASSESSMENT

G3 APPROVAL M4 DETAILED DESIGN AND IMPLEMENTATION

G4 PRECOMMISSIONING CHECK M5 COMMISSIONING

G5 COMMISSIONED M6 FINAL REVIEW AND FILE



1.0 PURPOSE There shall be arrangements to ensure that no Modification compromises SHE performance. Proposals shall be registered and assessed, and Modifications shall be authorized. Necessary hazard studies shall be carried out, appropriate design considerations made and all changes properly engineered and recorded. This Hazard Study section intends to provide guidance for trained and experienced persons to make a judgment of what is required. 1.1 THE NEED FOR MODIFICATIONS The requirement to modify equipment or procedures will normally arise from the routine business pressure to change or improve operations. A procedure to control Modifications needs to take into account that some Modifications are essential to the development of a business. A Modification procedure should not seek to prohibit changes to plants but to regulate changes so that undesirable or unsafe Modifications are filtered out. The primary intention of a Modification procedure is to detect unsafe aspects of a Modification but the procedure by its nature should also detect unworkable changes. Experience has shown that the introduction of a Modification is a common cause of a SHE incident. The Hazard Study procedure is an obvious method of checking Modifications with a reasonable hope of success in preventing SHE incidents. There are concerns that the Hazard Study procedure is too time consuming to be applied to every Modification. 1.2 GENERAL DESCRIPTION OF A MODIFICATION A Modification is any change of hardware or software, whether temporary or permanent, outside the approved methods of operation or maintenance that are described in the operating and maintenance procedures.



It is useful to consider exactly what is a Modification? The initial perception is that it is a physical change to a section of operating plant, which is true, but also applies to the following:

• Change in management structure

• Removal of a job classification

• Change of contractor or change to a contractor for a service

• Replacement with equivalent, not identical, equipment

• Change in supplier

• Change to product specification

• Introduction of legislation

• Transfer of regulatory responsibility

• Supplier changes specification

• Supply department changes a supplier

• An adjustment is made within an installed range

• Frequency of operation changes

• There is a change of intent during a Modification

• Only part of a Modification is completed

• A temporary Modification is removed

• Changes are made to buildings, foundations or structures

• Changes are made in security or emergency procedures. Conclusion: Any changes to facilities and the arrangements for its operation,

including changes to personnel, is a MODIFICATION.



1.3 PRINCIPLES TO BE FOLLOWED The general principles that should be followed are:

• Changes, which constitute a Modification, should be clearly defined

• There should be a Modification procedure in use

• A statement of the purpose and benefits of the Modification should be approved by person nominated for that purpose

• A technical / SHE assessment should be carried out in a systematic

manor

• The technical / SHE assessment should involve or be approved by managers and engineers with appropriate training and experience

• Documentation should be completed and brought up-to-date.

• There should be an appropriate technical management structure in place

• If in doubt initiate an appropriate Hazard Study

• Production pressures are important but should not be dominant

• Avoid Modifications outside normal working hours

• If there is a change in non process related systems such as management

responsibilities consider a Modification form of Hazard Study.



1.4 REPLACEMENT OF ’LIKE WITH LIKE’ It is normally said that the replacement of like with like does not require the implementation of a Modification procedure. But if the equipment to be replaced is more than a few years old will the new replacement part be identical? The answer is almost certainly, no. Suppliers through their process of continuing improvement will have changed their equipment in ways that they see to be a combination of the suppliers and the customers benefit. The main defense against this type of problem is that suitably experienced staff is involved in the decision on what equipment to install as a replacement. This is part of the argument for having suitably experienced maintenance organizations. 1.5 REMOTE / SMALLER SITES There are many operational units where there is little or no engineering presence but there is a requirement to make Modifications. It is unreasonable to expect an operating manager at such a site to initiate and approve a Modification. Some mechanism should be devised whereby appropriate engineering skills can be involved in the evaluation of the Modification. This could involve infrequent visits, the use of phone calls, faxes or e-mail. 1.6 GENERAL GUIDANCE TO INDIVIDUALS DOING SHE ASSESSMENTS

FOR MODIFICATIONS Obtain the records of previous Hazard Studies and Modifications in the area to be modified; the ’area’ should include surrounding and related plant. Gain an understanding of the underlying hazards within the plant and how the existing design copes with them. Consider how the proposed Modification changes the protection against the hazards or introduces new hazards. Talk to people who have experience on the plant of operation and maintenance. Previous Modifications may not have been documented, what is being proposed may have been tried in the past.



1.7 MODIFICATIONS HAZARD STUDY DECISION MECHANISM 1.7.1 Purpose This section gives guidance on the identification of hazards resulting from a Modification to a plant, process, equipment and buildings. Simple guidance is given on procedures that should apply and the level of Hazard Study required for changes and small projects. The approach to identification, control and documentation of hazards is different depending on whether Modification or Project Hazard Study procedures are followed. Capital projects, with mandatory Hazard Studies, fall under Group SSHE Standard 17 ’Plant and Process Design, Development and Hazard Review’ and Group Guideline 17.03 ’Hazard Identification and Risk Assessment for Projects, Plant, Equipment and Processes’. Modifications fall under Group SSHE Standard 18 ’Management of Change’ and Group Guidelines 18.1 ’Management of Change’. Any procedure developed to identify and control the hazards arising from Modifications needs to be;

• flexible in its ability to handle small trivial Modifications to large complex Modifications;

• effective in identifying all hazards including obscure hazards; • simple to understand and apply; • Encourage employee participation.

1.7.2 Methodology A simple flowchart showing the activities and decision points of a typical Modification control process is shown in figure 1. This flowchart encompasses the requirements specified in SSHE Standard 18 and Guideline 18.1. A Modification form is available (see appendix C). Other Modification control processes exist. All the larger and many of the smaller plant sites have developed their own procedures. Some of the decision points are combined. A Modification committee rather than a single responsible person should agree all Modifications. The Modification committee should consist of three nominated people; the site responsible engineer, the plant manager and the SHE manager. All Modifications shall be authorized by at least two of the committee members who have assessed the Modification.



M1 Title, description, registration and process flowsheet Simple Modifications can be fully explained by means of sketches and a short description. More complicated Modifications may state the general purpose and objectives leaving the detailed design for later. A Process flowsheet should be made of the Modification. Gate 1 Preliminary authorization The local responsible manager, for example plant manager, plant engineer, technical manager, decides whether the Modification is viable. Large complex proposals are identified to follow project procedures. No difficulties are experienced with small modifications or large projects but when is it a complex Modification, a project, or a simple Modification? The key differential characteristics are given in Table 1.

If the Modification has preliminary approval to proceed then a person or persons should be appointed to carry out a Risk Assessment. This person or team should encompass the skills involve on the site and be trained in hazard identification, for example hazard studies.



M2 Risk Assessment The nominated SSHE assessor (or team) needs to make a decision on whether the Modification is simple or complex. In order to do this the person(s) should be aware of the aspects and techniques of the different methodologies. For all Modifications appreciation of possible hazards can be gained by running through the Modification prompt list (see appendix A), and identifying which factors will be affected. For each of these, asking whether any hazard will arise. In the simplest Modification or where there are no significant hazards present then the decision to proceed is easy. If several, say more than 7 to 10 hazards are identified, then a full hazard study is recommended. If in doubt a full hazard study should be carried out. Any design required up to P&ID level is carried out. A cost estimate is produced if required. Gate 2 Approval The Modification is approved for construction (or rejected) by the Modification committee. The project manager and commissioning manager are appointed. These may be the same person. M3 Detailed design and implementation Besides the technical design the persons involved and/or effected need to be trained and the training recorded. Documentation updated. Authorities informed, approvals obtained etc. as appropriate. Gate 3 Pre-commissioning check The Modification is checked that it complies with the SSHE requirements, previous actions have been completed. Hazard Study 4 and 5 may be used for the more complicated Modifications. This section is signed off when the commissioning manager is satisfied that the residual risk is acceptable and that it has been built as the Modification stated.



M4 Commissioning Process fluids etc. are introduced under the guidance of the commissioning manager. For all but the simplest Modification a written commissioning plan should be followed. The documentation should have been brought up-to-date, including the P&ID. See appendix B for a list of possible systems that need to be updated. It is good management to review whether the anticipated benefits have been achieved. Gate 4 Commissioned When the local responsible manager is satisfied that the Modification works properly as specified and the Modification and documentation are complete, the Modification can be signed off. If changes are requested then consideration shall be given as to the need to recheck Hazard Study 2 before implementing Modifications to the original Modification. M5 Final review and file The Modification form with the appropriate documentation is filed in a secure place. Temporary Modifications Temporary Modifications are short-term changes that will revert to their original conditions after a stated time. All temporary Modifications should have a start date (time) and a proposed end date (time) listed on the form. All temporary Modifications (such as interlock bypasses) should have the length of time that the Modification will be in place and the committee shall be notified when the Modification is reversed. All interlock bypasses require Modification status. Originators of temporary Modifications will be asked by the committee on a monthly basis the status of their temporary Modifications. No temporary Modification shall last more than 3 month without a new request. If a temporary Modification is made permanent, hazards re-check needs to be done.



APPENDIX C TYPICAL MODIFICATION FORM PLANT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . BUSINESS SECT . . . . . . . . . . TITLE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AUTHOR . . . . . . . . . . . . . . . . . . . . . . LOCATION . . . . . . . . . . . . . . . . . . . . . . . DATE M1 DESCRIPTION OF MODIFICATION Sketches with this form; What is the change? Purpose, effect, Safety, Health, Environmental or financial benefits; Estimated cost: <1000, 1k-10k, 10k-100k, >100k PLEASE SEND FORM TO THE RESPONSIBLE PERSON



G1 PRELIMINARY AUTHORIZATION The proposal has been preliminarily approved and …………………………… .…………………………………………… is nominated to proceed with:

• A Capital project request.

• The Modification

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .is nominated to proceed with the Preliminary Security, Safety, Health and Environmental Assessment (M2) Signed . . . . . . . . . . . . . .. . . . .. . . . . the Responsible Person Date . . . .. . . M2 PRELIMINARY SSHE ASSESSMENT Are the effects (see the checklist appended) on the process or product hazards fully recognized? What is the worst incident / emergency that can result from this Modification? Is this acceptable?



If the equipment or process to be changed involves:

• a hazardous material? • High kinetic or thermal energy including speed, pressure, chemical

energy? or the change impacts on equipment or process above, or the change impacts on any critical product quality then a fuller hazard study, is required. Is a fuller hazard study required? If so which; HS1, HS2, HS3, Risk Assessment? Is Product Safety Clearance required? G2 REVIEW PRELIMINARY SSHE ASSESSMENT A Modification SSHE assessment will be adequate*/ A Hazard Study 1*, 2*, 3* / A Risk Assessment is required*. Signed . . . . . . . . . . . . . . . . . . . . . . . . . . the Responsible Person Date …….. M3 DESIGN and ESTIMATION Mass balances and flowsheets available; P&ID drawing available; Equipment identified; Authorities contacted; Estimated cost of the Modification; Estimate accuracy; Estimated completion date; ______________________ * Delete if not applicable



G3 APPROVAL Hazard Study 1, 2, 3, and / or a Risk Assessment have been carried out**. The Modification has been adequately defined, the hazards have been identified, and the consequences are known and acceptable. Signed . . . . . . . . . . . . . . . . . . . . . . . . . . the Responsible Person Date . . . .. . . . . This Modification is approved for implementation. …………………………….is nominated to complete the design and implementation. ……………………………..is nominated to commission the Modification Signed . . . . . . . . . . . . . …... . . . . . . . . . . . .the Responsible Person Date . . . .. .



M4 DETAILED DESIGN AND IMPLEMENTATION Permits; Detailed design; Engineering documentation; Site Safety Instructions considered; Codes of Practice and guidance considered; Operating manuals revised; Training given; Training recorded; G4 PRECOMMISSIONING CHECK The Modification has been inspected and found to be as intended and all required actions have been completed and commissioning procedures have been defined. HS4 and HS 5 checklists used**. Signed1 . . . . . . . . . . . . . . . . . . . . . . . . . . Date . . . .. . . . . . . M5 COMMISSIONING Modification and documentation controlled. G5 COMMISSIONED The Modification requirements have now been met and it is now suitable for continued operation. Signed1 . . . . . . . . . . . . . . . . . . . . . . . . . . Date . . . .. . . . . . .



M6 FINAL REVIEW AND FILE Have the documentation and operating systems been changed to reflect this Modification? Have the anticipated SHE and financial benefits been achieved? The Modification has been examined and works satisfactorily*/ the temporary Modification has been removed and the plant / equipment / process returned to its original state*. All outstanding actions are complete and the site records adequately reflect the changes brought about by this Modification. Signed . . . . . . . . . . . . . . . . . . . . . . . . . . the Responsible Person Date . . . .. . . . . . Modification filed in the SSHE dossier _____________________ * Delete if not applicable 1 The person defined at gate 3 to carry out the commissioning

Application of Process to Management of Change and Modifications

Technology

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