HMS Directive No. 34 - Management of Change

8/6/2019 HMS Directive No. 34 - Management of Change

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Prepared by: Verified by: Approved by:

Livar Haga Kjetil Serigstad Anne Myhrvold

Revision number: 3 Issue date: 2009-12-30 Next review date: 2010-12-31

Classification: Public/unclassified BP internal Confidential Secret

HMS Directive No. 34 - Management

of Change


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HMS Directive No. 34 - Management of Change Doc.no: [n.nn.nnn]

[Subtitle/Chapter title] Rev. no: 3

Authority: Engineering Authority Issue date: 2009-12-30 Page 2 of 15

Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only.

The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

Document control sheet

Document owner Livar Haga

Review period 1 Year

Deviation

management

Ref. HSE-Directive No. 35

Revision history

3 2010 HMS Directive No. 34 - Management of

Change

Livar Haga Kjetil

Serigstad

Anne

Myhrvold


Change

L.Haga L.Haga H.Halvorsen


Change

L.Haga L.Haga H.Halvorsen

Rev.no Issue

date

Description Prepared

by

Verified

by

Approved

by


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Table of content

1 General..................................................................................................................................................4

2 Responsibility........................................................................................................................................6

3 Processes .............................................................................................................................................8

3.1 Plant/Equipment Change..............................................................................................................8

3.2 Process/System Change..............................................................................................................9

3.3 People/Organisational Change .....................................................................................................9

4 Demand Analysis ................................................................................................................................10

5 Risk Evaluation....................................................................................................................................11


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1 General

Purpose The purpose of this directive is to ensure that all proposed temporary and

permanent changes within BPN are systematically evaluated to ensure that the

risk related to people, plant or processes are assessed, communicated and

controlled to an acceptable level.

The mindset is that the responsible person has intent to make a change. This

directive and attached forms will be used to identify and document the risksrelated to the change and any steps necessary to mitigate those risks. If

remaining risks are unacceptable, the change must not be implemented.

This directive meets the expectations set forth in Getting HSSE Right, Element 7

Management of Change (MoC) and Integrity Management Standard element 7:

Management of Change.

Scope The directive applies to changes within BPN related to plant, process and/or

people.

All changes will be managed by utilizing a risk based&controlled decision-making

process. The level of rigor involved should be commensurate with the level ofrisk.

The directive applies to any temporary or permanent physical alteration that

deviates from the design intent, any deviation from the documented safe

operating limits or procedures, any change in process outside the design

specification, any change in management systems, or a significant change in

organization or personnel that leads to a loss or transfer of people with particular

knowledge or experience.

This directive lists factors for each type of change, to consider whether the change

requires a MoC. Consult relevant change with your supervisor. If in doubt

whether the change requires MoC contact person with adequate

experience/expertise. (I.e. HSSE representatives, lead discipline engineer,

technical authority, etc.)

The directive applies to all parts of BPN activities - onshore and offshore.

The directive and its appendices should be used for generic MOC. In situations

for which dedicated processes and procedures have been prepared satisfying the

key requirements of MOC, namely robustly documented risk management

process, such should be used for managing changes fitting their scope.

References The framework regulations

The PSA regulations

The Management Regulations

The PSA regulations

BP Getting HSSE right BP Integrity Management Standard
http://www.npd.no/regelverk/r2002/Rammeforskriften_n.htmhttp://www.npd.no/regelverk/r2002/Styringsforskriften_n.htmhttp://www.npd.no/regelverk/r2002/Styringsforskriften_n.htmhttp://www.bp.com/liveassets/bp_internet/globalbp/STAGING/global_assets/downloads/G/Getting_HSE_right_A_guide_for_BP_Managers_2001.pdfhttp://integritymanagement.bpweb.bp.com/Display.aspx?&MasterId=1750f663-72d2-4082-a004-2d6450dfadaa&NavigationId=178http://integritymanagement.bpweb.bp.com/Display.aspx?&MasterId=1750f663-72d2-4082-a004-2d6450dfadaa&NavigationId=178http://integritymanagement.bpweb.bp.com/Display.aspx?&MasterId=1750f663-72d2-4082-a004-2d6450dfadaa&NavigationId=178http://www.bp.com/liveassets/bp_internet/globalbp/STAGING/global_assets/downloads/G/Getting_HSE_right_A_guide_for_BP_Managers_2001.pdfhttp://www.bp.com/liveassets/bp_internet/globalbp/STAGING/global_assets/downloads/G/Getting_HSE_right_A_guide_for_BP_Managers_2001.pdfhttp://www.npd.no/regelverk/r2002/Styringsforskriften_n.htmhttp://www.npd.no/regelverk/r2002/Rammeforskriften_n.htm


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BP Golden Rules for Safety Management of Change

BPN Directive 35 Processing unwanted events and exemptions

BPN Directive 36 Risk analysis and acceptance criteria

BPN Projects & Modification Procedure 1.70.005

BPN Control of Temporary Equipment 1.70.007.

BPN Handover document - Transition of Roles and Responsibilities.

Definitions and

abbreviations

Acceptance criteria are criteria used to express an acceptable level of risk in

activities ALARP (As Low As Reasonably Practicable) -means that the risk level has

been reduced through a documented and systematic process to such a level

that it is no longer possible to identify cost-effective measures that can further

reduce the risk

Critical work process includes work processes where lack of control of

changes may lead to moderate or high risk (combination of consequence and

probability) of:

accidents, harm to people and/or damage to the

environment

economic loss, and/or

impairment of BP's reputation

HAZID (HAZard IDentification) is a method used to identify potential elements

of risk

HSSE (Health, Safety, Security and the Environment) The term also includes

emergency preparedness, working environment and security

MoC implies a documented Management of Change process as described in

this directive.

Plant

Is in this directive related to plant, facilities and

equipment such as buildings, structure, piping, safetyequipment, escape routes, tie-ins, by-passes, etc.

Process

Is in this directive related to work processes or systemssuch as procedures, software, conditions or

requirements (work-flow) People

Is in this directive related to organizational changeprocesses

Risk - Expression of the combination of probability and consequences of oneor more accident/incidents happening

Risk analysis - An analysis covering systematic mapping and description of

risk to personnel, the environment and material assets.

Golden Rule Work arising from temporary and permanent changes to organization, personnel,

systems, process, procedures, equipment, products, materials or substances,

and laws and regulations cannot proceed unless a Management of Change

process is completed, where applicable, to include: a risk assessment conducted by all impacted by the change development of a work plan that clearly specifies the timescale for the change
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and any control measures to be implemented regarding:

equipment, facilities and process

operations, maintenance, inspection procedures

training, personnel and communication

documentation

authorization of the work plan by the responsible person(s) through completion

Identify need for

MoC

Evaluation of the need for MoC should be done in all phases from the planning

stage and all the way through the actual execution. It is a duty of everyone

involved in the planning, approval and execution of work to evaluate the need for

MoC.

A generic MoC process is required when change introduce risk factors that are

not sufficiently identified, documented and controlled through other relevantprocedures/directives, exemplified in chapter 3. E.g. Safe Job Analysis (Directive

#11), Projects & Modification (Procedure 1.70.005) etc.

Detailed descriptions of changes requiring and not requiring documented MoC

process are specified in chapter 3 (Plant, Process and People). For changes

repeated frequently it may be worthwhile to establish described work processeswhich are reused and robustly documented. This will probably be more effectivethan to use this generic method each time such change is to be managed.

Appendices Terms Of Reference (TOR)

Plant / equipment change checklist

Process / system change checklist

People / organisation change checklist

Risk assessment table

MOC Report

MOC Poster

Records The following should be registered in Traction:

Terms of Reference

MoC Report with attachments

2 Responsibility


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Responsibility table Type of Change Accountability/ Approver People - Organization Manager of the new organization or

Line supervisor of the positionaffected

Process - Systems or Directives Work Process owner

Plant Equipment Equipment owner (OIM, arearesponsible, , etc.)

Chemicals/Substance/Materials Appropriate Plant, product or Processowner (incl. Directive owner,Industrial hygienist).

Codes and RegulatoryRequirements

Directive Owner, TechnicalRequirements Authority (TA) or HSSEManager

Emergency Preparedness OIM, Emergency Controller and/orSecurity & Emergency Advisor

Logistics and Contracts Logistics- and PSCM Manager

Managers have accountability for:

knowing the legal compliance requirements related to the operations and

assets for which they are responsible

and for ensuring that changes in legal and regulatory requirements affecting

their accountabilities are monitored, communicated and implemented

effectively.

HSSE Manager is responsible for

verifying that the risk evaluations carried out are in accordance with BP's

expectations and that adequate risk-reducing measures have been identified

ensuring management systems are in place for monitoring changes to health,safety, security and environmental laws and regulations, communicating the

changes, assessing the impact

assuring that implementation plans and monitoring methods are put in place to

assure compliance.

Client/Approver is the person requesting and approving the final MoC.

shall ensure that the directive is followed and that the

MoC team is familiar with the directive.

shall ensure that identified measures are implemented

prior to making the actual change.

The client shall assess whether the MoC shall be led by an independent party.

MoC leader is responsible for

Establishing a MoC team which will identify risks andrisk-reducing measures.

Prepare MoC report and record actions in Traction.

The person who is appointed to plan and lead a MoC process shall have the

relevant background from similar analyses, e.g. HAZOP, HAZID, etc.

Engineering

Authority

shall ensure that logged MoCs are reviewed annually to assess the cumulative

impact of all changes.

MoC team's HSSE

representative

is responsible for

making sure that the risk evaluation reflects BP's

requirements and HSSE expectations


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3 Processes

3.1 Plant/Equipment Change

Definition Plant/Equipment change process may include any changes in the following,

but not limited to

Change to the platform/building structure

Change in equipment location requiring changes in

piping or utilities

Changes in operating conditions outside normal

operating or design envelopes, such as pressures,

temperatures, etc.

Change to any safety equipment, safety related

device, safety system, escape route or hazardous area

classification

Changes which could affect the capacity or design

basis

Changes in maintenance, inspection or testing

Equipment modification (e.g., alarms, instrumentation,

etc.)

Addition of equipment that may contribute to greater

relief requirements

New projects that involve tie-ins or equipment

modification on existing units

Use of new technology, new materials, new

equipment

Change to hired or temporary equipment

Bypass connections around equipment that is normally

in service unless the change is covered in a normal

operating procedure

Change to chemical inventory and chemical use

Deferral of planned major maintenance and

modification activity

Changes for which other robustly documented risk managing processes,

procedures/directives exist should be managed using this when the situation fit

the scope (e.g. modification procedures, risk analysis methods, SJA, work

processes integrated in Computerized Maintenance Management System

(CMMS), Maint Web, Critical Protective System Register (CPSR) process, etc.).

In general, the following changes would not need a documented MoC:

Changes like-for-like in kind (equipment, consumables,

or parts)

New equipment that has no impact on existing

operations

Routine maintenance of equipment

Change that is consistent with the design parameters.

Minor changes that do not affect HSE, personnel, or

customers. (e.g. a change in supplier for materialswithout HSE-impact ).


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The effects of the

change

Based on a detailed description of the plant/equipment changes the MoC

leader will, in cooperation with relevant skilled personnel, consider the effects

by using Appendix 2Checklist Plant/equipment changes

Check against other checklists attached for relevance.

If the change will cause deviation from requirements, either internal or

external, BPN Directive 35 Processing unwanted events and exemptions

must be followed.

3.2 Process/System Change

Definition Workprocess/System change process may include any changes in the

following, but not limited to

Changes in legal and regulatory requirements,

technical codes, standards with safety, health and

environmental effects.

o New legislation

o Changes to existing legislation

o Legislation compliance issues raised by

regulatory body inspection and progress the

update of outstanding inspection-related issues.

Change in procedure, sequence, or change in steps

Use of new or upgraded software, etc.

Changes in emergency preparedness and response



the scope (e.g. risk analysis methods, SJA, work processes integrated in

Computerized Maintenance Management System (CMMS), Maint- Web process,

etc.).



customers

The effects of the

change

Based on a detailed description of the process/system changes the MoC

leader will, in cooperation with relevant skilled personnel, consider the effects

by using Appendix 3Checklist Process/system changes.



external, BPN Directive 31 Exemptions must be followed.

3.3 People/Organisational Change

Definition People/Organisational change process includes any changes in the

relationship between work tasks and available resources such as

An established job type is removed from the
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organization, or a new job type is added

Changes in the organization structure and/or reporting

relations

Changes in competence requirements for identified

roles

Changes in activity level (changes in work descriptions

for the existing organization)

Change of major supplier, including relevant sub-

contractors (changes in the supply chain)

Changes to logistics such as significant change in

transportation route, loading/ discharge location.

Individuals are required to take on significantly newresponsibilities demanding skills and competencies

unconnected with those required previously

Individuals relinquish responsibilities for tasks related

to HSSE compliance or other critical business

processes without those tasks being reallocated

Changes to outsource a function that was previously

performed by BPN personnel



the scope (e.g. risk analysis methods, SJA, Handover Document - Transition of

Roles and Responsibilities available via HRs intranetpage under Forms,

Handover, etc.).


Change in a contractor providing an existing low risk

service, subject to normal pre-qualification.


customers

The effects of the

change

Based on a detailed description of the organisational changes the MoC leader

will, in cooperation with relevant skilled personnel, consider the effects by

using Appendix 4Checklist - Organisational changes



external, BPN Directive 31 Exemptions must be followed.

4 Demand Analysis

Introduction In connection with management of change processes, the MoC leader shall

make sure that the changes are described in detail in order to

ensure a sufficient evaluation basis

ensure that the analysis basis is documented so that

the relation between the analysis basis and the results

(measures) are traceable

The descriptions should describe the current situation and the desired futuresituation.
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Terms of reference The individual who is proposing the change shall complete the following sections

of the Terms of Reference for the Management of Change (Appendix 1.)

Name and the date.

The description of the change.

The purpose of the change.

Type and Duration of change (permanent/temporary)

Target date for the change

MoC team

Approver

The approver is the individual who will ultimately approve the relevant change.

Duration of change

In emergency situation, the person in charge is authorized to execute changesto maintain the safety of the facility without following the fully documented

MOC directive. After the emergency situation is cleared, properly documented

MOC processes should be handled.

If the change is intended to be temporary, a time limit must be set on when

the original design intent (ie equipment, operational conditions, organizational

structure, etc) will be restored, and the management system (Traction) should

be used to ensure that the time limit and any other conditions are not

violated.(Normally less than 6 months).

Extension of temporary change shall be reviewed and approved by the next

higher level of management before pre-authorized time-limit expire.

Special precautions to maintain safe operations while a temporary change is in

effect shall be periodically reviewed for effectiveness.

Facilities are brought back to normal or permanent mode before a temporary

MOC is closed.

Main focus When evaluating the impact on critical work processes, the main focus must

be on identifying changes which may lead to

Related activities being completely left outdue to

lack of resources or lack of awareness of the

importance of the activity

Related activities being performed, but with

reduced quality. This may be due to inexperienced

personnel performing the work or taking "shortcuts" as

a result of imbalance between the workload and

available resources

Losseswhich may occur because personnel perform

activities for which they are not sufficiently skilled,

thus leading to the work being done incorrectly

Creeping changes The evaluation of critical work processes must also include indirect effects.

Engineering Authority shall ensure that each organizational unit reviews the

MoCs logged in Traction annually or more frequently if appropriate, to assess the

cumulative impact of all changes.

5 Risk Evaluation


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Introduction Risk evaluations of MOC processes shall be done by a MoC team.

The MoC team ought to consist of

representatives of the critical work processes

identified as being affected by the change

personnel with HSSE competence

employees' elected representative and/or safety

delegate (shall be invited.)

In selecting a team, the following mix of attributes must be considered:

Adequate technical expertise/experience.

Adequate understanding of the risks

Adequate organizational and business understanding.

Arrangements for employee contribution This team will propose measures, which limit any risks to an acceptable level

in accordance with BPN ALARP principle (ref. Directive 36 Risk analysis and

acceptance criteria).

Identifying

elements of risk

The MoC team will identify potential elements of risk using

HAZID , etc

or

other systematic methods which stimulate creativity,

i.e. which gives the participants the opportunity to

identify circumstances that are outside their own

scope of experienceby using appropriate checklist (appendix 2-5) and other tools

available for Hazard recognition

The team should consult as widely as is necessary to allow them to come to

an informed decision on the risks associated with the change. Affected

persons including contractors, sub-contractors, vendors, and customers may

be consulted as necessary.

When identifying potential elements of risk, a risk evaluation needs to be

carried out in which the elements are ranked into the following categories:

High potentialwhich means that risk-reducing

measures need to be implemented

Medium potentialwhich means that risk-reducing

measures can be implemented if deemed necessary

based on a cost/benefit evaluation

Low potentialwhich means that no further measures

are deemed necessary

The risk of an unintended incident occurring can be estimated by means of

BPN risk matrix, available through directive 35 Unwanted Events, or by

using the more advanced & detailed methodologies and acceptance criteria in

HSSE Directive no. 36, Risk Analysis and Acceptance Criteria.

Identification of

risk-reducing

measures

Based on a systematic evaluation of the elements of risk involved in an

management of change process, the MoC team is to identify

probability-reducing measuresintended to prevent

an incident from occurringand/or


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consequence-reducing measuresintended to reduce

the consequences of an incident that has occurred

Of these two, probability-reducing measures are to be prioritized

Based on the risk and risk reducing measures the MoC team shall confirm

whether or not the change should be implemented.

Implementation of

measures

The MoC team shall prepare a plan for implementation of the measures. The

plan is to propose deadlines and the person responsible for each of the

measures

This should include how the change is to be effectively communicated to the

workforce and other affected persons (such as contractors, sub-contractors,

customers, and vendors). Special competence requirements must also be considered and completed

prior to implementation of the changes.

The MoC approver shall assess whether any proposed change requires a pre-

start up review to confirm that the MoC system has been correctly applied,

that the change is safe to commission and that it meets applicable legal

obligations.

Records, procedures and drawings shall be updated to reflect the MoC.

MoC systems shall be designed to ensure that all actions are closed out and

achieves the necessary effect.

Documentation The results of the review should be well documented and retained for future

verification. This is important even if the review did not require any additional

action to be taken. MoC report, using template in appendix 6, shall be developed describing the

following sections:

Participants

Risk assessment method

Accept criteria

Actions: summary and number of identified

actions/barriers.

Assumptions: number of established assumptions.

Drawings: summary of drawings utilized.

Documents: summary of documentation utilized.

References

The approver shall sign completed MoC report to indicate acceptance or non-acceptance of the review findings.

The MoC leader must ensure

documentation of the risk evaluation in accordance

with Appendix 5 Risk Assessment Table

documentation of measures identified as part of the

risk evaluation in Tr@ction

Logged MoCs The MoC report together with measures identified shall be recorded in Traction

under Other events, Event type: MoC. The Traction shall be recorded under

the specific asset or if of general nature under BUR (Business Unit Resources).

Traction list of Management of Change processes shall be reviewed at least

annually to assess cumulative impact of all changes.

Performance

managementThe use of MoC-system shall be assessed by processes which:


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1. Confirm the change achieve its original intent

2. Confirm the changes are executed correctly

3. Confirm the actions are closed

4. EA or delegated audit MOC-processes at least annually


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Flow chart:

Client identifyingneed for change

Does the changerequire a

Management ofChange process?

Client and supervisor,and person withadequateexperience/expertise

Describe the change

Client

Complete Terms of Reference for MOC or

initiate other robustly documented riskmanagement process.

MoC team

Identify potentialelements of risk using ofthe change by usingappropriate checklist

Identify probability-reducing measures

and/orconsequence-reducing measures

Are thereducingmeasuressufficient?

Establish plan forimplementation of actions

identified

Review the management ofchanges within their function

annually to assess the cumulativeimpact of all changes.

Engineering Auth (EA)

&/ HSSE Manager

Verify implemented risk-reducing measures.

MoC approver

he change does not requirea MoC when:

the change does notintroduce any risk factors.

the change is covered inchapter 3 stating MoC notrequired.

Should you be in doubtwhether the change requiresMoC, please contact a personwith adequate experience/expertise (directive owner,HSE department, teamleadersetc.)

yes

no

yes

no

Complete MoC Report

Follow up actions in

Traction

MoC approver

MoC team

MoC team

MoC team

HMS Directive No. 34 - Management of Change

Documents

Transcript of HMS Directive No. 34 - Management of Change