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ONGC

MANAGEMENT OF CHANGE DOCUMENT

DOC NUMBER: ONGC /MOC/II/2017


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Management of Change

DOC NUMBER: ONGC /MOC/II/2017


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Management of Change

REVIEW AND AMENDMENT RECORD

Authorisation Record Position of Preparer Position of Approver

Version II December 2017 In-house Committee Director (Exploration)-I/C HSE


Version I July 2008 Petrofac Training Director (Offshore)

List of recipients:

1. Asset Manager- MH/ N&H/B&S/EOA

2. Chief Drilling Services- DW/SW

3. Chief Offshore Engineering Services

4. Chief Offshore Logistics

5. Chief HSE

6. Head Offshore Safety

7. Head Well Services

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Contents

REVIEW AND AMENDMENT RECORD 2


1 POLICY AND STRATEGIC OBJECTIVES 5
1.1 PURPOSE 5
1.2 POLICY 5
1.3 STRATEGIC OBJECTIVES 5
1.4 SCOPE 6
1.5 INDUSTRY CODES AND STANDARDS 7
1.5.1 Design, Construction and Structural Integrity of Production Platform 7
1.5.2 Rules of Classification Societies 7
1.6 DOCUMENT CONTROL COORDINATOR 7
2 GLOSSARY 7
3 TYPES OF CHANGE 10
3.1 CHANGES IN EXISTING FACILITY 10
3.1.1 Process change 10
3.1.2 Procedural Change 10
3.1.3 Change in operating parameters 10
3.1.4 Change in surface facility 10
3.1.5 By-Pass / Abort Control 11
3.2 CHANGE IN PERSONNEL 11
3.3 ADDITION OF NEW FIXED / FLOATING INSTALLATIONS 11
4 MOC PROGRAM ELEMENTS 11
4.1 IDENTIFICATION OF NEED FOR CHANGE 11
4.2 IDENTIFICATION OF RISKS ARISING DUE TO CHANGE 12
4.3 ASSESSMENT OF RISKS 12
4.4 IDENTIFICATION OF RISK MITIGATION MEASURES 12
4.5 APPROVAL OF CHANGE 12
4.6 IMPLEMENTATION OF CHANGE 12
4.7 DOCUMENTATION AND MAINTENANCE OF RECORDS 13
4.8 REVIEW OF CHANGE 13
5 ORGANIZATION AND RESOURCES 13
5.1 ROLES AND RESPONSIBILITIES OF OFFICIALS 13
6 HAZARD IDENTIFICATION SYSTEM 18
6.1 EXISTING FACILITIES, PROCESS AND OPERATIONS 18
6.1.1 Observation of employees 18
6.1.2 Review of past incidents and accidents 18
6.1.3 HAZOP study 19

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6.1.4 HAZOP guidewords and their meaning 20


6.2 PROCEDURAL CHANGE IN EXISTING INSTALLATION 20
6.3 CHANGE IN PARAMETERS 21
7 ASSESSMENT OF RISK OF PROPOSED CHANGE 21
7.1 ASSESSMENT CRITERIA 21
7.1.1 What is tolerable? 21
7.1.2 Method of assessment 21
7.1.3 Assessment criteria for change in personnel 22
7.2 RISK ASSESSMENT 22
7.3 PROCESS / PROCEDURE/ PARAMETER/ SURFACE FACILITIES/ 23
EQUIPMENT CHANGE IN EXISTING FACILITIES
7.4 CHANGE IN PERSONNEL 24
8 IMPLEMENTATION 24
8.1 PROGRAM FLOW CHART 24
8.2 PROJECT SCHEDULE AND MILESTONES 24
8.3 CHANGE CLOSE OUT 25
8.4 PERIODIC REVIEW 25
9 CONTINUAL IMPROVEMENT 25
9.1 TRACKING RESULTS OF THE CHANGE 25
9.1.1 Active monitoring 25
9.1.2 Reactive monitoring 25
9.2 RESULTS OF HAZARD IDENTIFICATION AND RISK ASSESSMENT 26
9.3 RECOMMENDATIONS OF AUDITS 26
9.4 MANAGEMENT REVIEW 26
9.4.1 Review by Management 26
9.4.2 Improvement 26
10 ANNEXES
Annex 1 Flowcharts 27
Annex 2 Flowcharts 28
Annex 3 Change Control Form 29
Annex 4 Assessment of Risk due to proposed change – 30
Initiator’s Review (Production Installations)
Annex 5 Assessment of Risk due to proposed change – 37
Initiator’s Review (Drilling)
Annex 6 Implementation & Feedback 38

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1 POLICY AND STRATEGIC OBJECTIVES

1.1 PURPOSE

During the lifetime of any installation, many changes will occur. These could be changes to the
physical hardware of the installation, the control systems, the operating parameters, the
business processes used, or to the organisation running the installation.

These changes have the potential to increase the risks involved in operating the installation.
The risks would continue to remain due to the following reasons:

• Inadequate identification or evaluation of the risks due to the change.


• Inadequate physical design or execution of the change.
• Inadequate communication and documentation of the change.

It is well-documented that poor management of changes has contributed significantly to loss


of human life, property and also caused environment pollution. In order to avoid such
incidents, before any changes are made, its impact on safety, health and
environment shall be evaluated and appropriate controls put in place .

The purpose of this document called Management of Change (MOC) document is to


establish the system that will provide guidelines for managing any change in personnel,
process, equipment, surface facilities and work methods.

1.2 POLICY

It is the endeavour of ONGC to carry out changes in installation and related processes after
ensuring that the risks emerging out of such changes are identified and mitigated to a level of
as low as reasonably practicable.

1.3 STRATEGIC OBJECTIVES

In pursuance of the policy mentioned above, the following strategic objectives are set:

• Use of appropriate techniques that would identify hazards due to the proposed
change.
• Risk due to the identified hazards would be assessed systematically. The focus of

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assessment would on the areas that present the greatest risk.


• Risks would be reduced to a level as low as reasonably practicable by
implementing appropriate controls.
• Management control would be exercised at different levels to
ensure safe implementation of the change required.
• Before the changed system is brought on line, an evaluation would be done to
ensure that change has been done as envisaged.
• Once a change in the engineered system is done, it would be duly reflected in
the P&IDs’ and relevant documents.
• All concerned persons would be informed prior to the change being made and
within 24 hours of the change effected or a soon as is practicable.

1.4 SCOPE

The instructions, procedures and guidance contained in MOC document apply to


all installations and activities in ONGC’s offshore operations.

Management of Change (MOC) process shall be applicable for managing any change in
personnel, process, equipment, surface facilities and work methods.

MOC process will not be applicable to those covered by Alternative Processes: Where other
specific and documented processes exist on site to manage specific changes. Common
examples of these are:

• Replacements in Kind (RIK): Where an equipment or item is replaced with an identical


item, usually in the course of routine maintenance, it is a direct like-for-like replacement.
• Addition of new fixed / floating installations usually designed and executed by a projects
function.
• Certain defined changes to operating modes.
• Instrument or control system changes within defined parameters.
• Changes or updates to operating procedures.
• Organisational changes.
• Bypass/abort of SCE for less than 14 days

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1.5 INDUSTRY CODES AND STANDARDS

1.5.1 Design, Construction and Structural Integrity of Installation

ONGC installations are designed and constructed based on relevant national and international
regulations, standards, codes and guidelines like

1. P&NG(SOO) Rules, 2008


2. IMO regulations
3. API Standards
4. ISO standards
5. OISD standards
6. BIS standards
7. NFPA
8. MODU code
9. ASME code
10. ASTM code

1.5.2 Rules of Classification Societies

The rules of classification societies like DNV GL, American Bureau of Shipping (ABS),
Indian Registry of Shipping (IRS) and Lloyds Register of Shipping, recognized world over
for certification of fitness of offshore installations, are followed.

1.6 DOCUMENT CONTROL COORDINATOR

Head-HSE is the Document Control Coordinator. He shall ensure that;

1. All authorized recipients get the current version of the document within one week
of its issue;
2. All copies of old document are retrieved and destroyed within two weeks of
issuance of the current version;

2. GLOSSARY

Accident
An undesired event that results in harm to people, damage to property or loss to
process.

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Change
Replacement or modification of a process, procedure, equipment, facility or personnel with
something different from original.
Change Management team
Multi-disciplinary team comprising of line managers responsible for proposing the change,
identification & assessment of the risks emerging due to change and suggest mitigation
measures.
Change Master Record
Data record, which contains all the information, required for managing a change.
Change Object
Object that is changed with reference to a change master record or engineering change
request.
Examples of change objects are:

• Bills of material
• Routings
• Materials
• Documents
• Drawings
• Manuals

Competent Person
A person who, by virtue of his knowledge, skills and training, can undertake the task.
Ecosystem
A self-sustaining community of living creatures existing in its own specific environment.
Environment
The outcome of inter-relationship and interaction between living and non-living components
of the ecosystem.
Exposure
Measured effect of a substance or object in a work area that poses a risk to public
safety, to the life and health of humans and / or to property, due to its
nature, properties, or state.
Hazard
A condition or practice with the potential to cause harm.
Incident
An unplanned event (occurrence, condition or action) which did or could have resulted in
personal injury or damage to the plant, community or environment.

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Quantitative Risk Assessment (QRA)


The identification of hazards and evaluation of the extent of risk arising there from
incorporating calculations based upon the frequency and magnitude of hazardous
events.
Revamping
Putting together something old as new by addition or alteration.
Risk
Risk is the product of probability and consequence of loss as a result of an accident.
Risk Analysis
Examination of available information using defined methods for identifying and rating
the risk potential of a hazard in a work area.
Risk Assessment
Process and component for determining, rating, and assessing hazards and risks in work
areas.
Safety
Safety is defined as freedom from those condition that can cause injury to persons including
death or damage to property or environment.

Abbreviations
ChMT – Change Management Team
HSE - Health Safety & Environment
OIM – Offshore Installation Manager
SAM – Surface Area Manager
PMM- Preventative Maintenance Manager

RM – Rig Manager

OM – Operation Manager

LM- Location Manager

HMDS-Head Maintenance Drilling Services

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3 TYPES OF CHANGE

3.1 CHANGE IN EXISTING FACILITY

3.1.1 Process change

The change that requires a change in P&ID, connecting a piping/spool piece,


changing the valve, changing a flange with different rating, re-routing of lines, adding a
connection to flare system/ vent system/drainage system , increasing or decreasing the set
points of alarms and trips , etc. Such changes are normally necessitated to ensure proper
process operations under changed conditions.

3.1.2 Procedural Change

It includes any change of operating/ maintenance procedure with reference to the one
indicated in operations/ maintenance manual For example: Platform start up procedure,
shut down procedure, changing operation from pressurized mode to stabilized
mode or vice –versa, well testing procedure, change of drilling fluid etc.

3.1.3 Change in operating parameters

It includes any change in operating parameters (settings) for the process or equipment,
like pressure, temperature, flow etc. e.g. changing operating parameters of separators,
changing the settings of trips etc.

3.1.4 Change in surface facility

In the course of operations, equipment require major repairs or overhauling, facility


require structural change or change of loads on the structure . It is then taken out of the
system. Such a change can affect safety of personnel.
Example:
1. One out of four lifeboats of living quarters is sent for repairs. Evacuation procedures
would have to be modified to accommodate all persons in three lifeboats.
2. Deck extensions, structural modifications or addition of load on structure

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3.1.5 By-Pass / Abort Control.

In order to continue operations, at times it may be necessary to make temporary


connections (e.g. chicksan joints), bypassing controls / alarm / trip mechanisms in
part or in full in Fire Gas detection systems, Unit Control Panels, bypassing
equipment safety system to bring back drill string to safe position etc. till such time that
normal operating procedures are restored. These short-term changes may result in
hazardous situations.

If such changes continue for more than 14 days, the same shall be addressed with
development of management of change document. Such changes upto 14 days shall be
addressed through documented authorisation by predetermined level of officers.

In case the short term bypass is considered critical from safety point of view, MOC document
may be developed for such short term bypasses also.

3.2 CHANGE IN PERSONNEL

Change in personnel is significant whenever there is change of contractor. Work


and safety cultures of the incoming contractor are key factors in managing the change.

4 MOC PROGRAM ELEMENTS

1. Identification of need for change


2. Identification of risks arising due to change
3. Assessment of risks
4. Identification of risk mitigation measures
5. Approval of change
6. Implementation of change
7. Information Management System to manage & track the change
8. Documentation and maintenance of records
9. Review of change

4.1 IDENTIFICATION OF NEED FOR CHANGE

Change is identified based on operational requirement, change in regulations, standards etc.


Change Management Team proposes the change.

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The OIM shall set up a Change Management Team consisting of all Sectional Incharge and the
HSE Manager to-

 Assess the risk of proposed change


 Develop proposal for change
 Verify the impact of change on the system, process and installation as a whole.
 Verify that the impact of change was addressed in all aspects.
 Suggest additional control and safety measures if required.
 Ensure that control and safety measures are implemented/ incorporated in the system.
 Ensure updating of relevant P&ID, change management records and documents

4.2 IDENTIFICATION OF RISKS ARISING DUE TO CHANGE

Change management team identifies the risks arising due to change using operational
experience, brain storming, lesson learnt from past incidents, standard risk list, checklists,
HAZID, HAZOP etc.

4.3 ASSESSMENT OF RISKS

Change management team carries out risk assessment/ranking using tools like HAZID, HAZOP,
Risk Ranking Matrix.

4.4 IDENTIFICATION OF RISK MITIGATION MEASURES

Change management team suggests risk mitigation measures to bring down identified risks to
ALARP level.

4.5 APPROVAL OF CHANGE

Change shall be approved by appropriate authority depending upon the type of change.

4.6 IMPLEMENTATION OF CHANGE

Change is implemented at location incorporating suggested risk mitigation measures.


Documents like P&ID, operating procedures etc. are to be updated. All concerned persons
shall be informed prior to the change being made and within 24 hours of the change
effected or as soon as is practicable.

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4.7 DOCUMENTATION AND MAINTENANCE OF RECORDS

Complete documentation of the change shall be developed and retained. The change master
record shall be updated by addition of the change to it and the same shall be maintained at
the installation.

4.8 REVIEW OF THE CHANGE


Periodic review of adequacy and effectiveness of change and mitigation measures shall be
carried out.

5 ORGANIZATION AND RESOURCES

5.1 ROLES AND RESPONSIBILITIES OF OFFICIALS

Management of change system, like any other system, ultimately relies on the People who
drive it. Role and responsibilities of officials who are to implement the change are given in the
Table below. At the installation level, OIM, Process Manager, Maintenance Manager, Wellhead
Manager, Construction Manager, Master, Barge Engineer, Chief Engineer (Marine), Tool
pusher, Sectional Incharges and HSE Manager have to work as a team in making the basic
proposal for change. Teamwork would produce a well-rounded proposal when each one of
them put in their expert views based on the ground situation. Effectiveness of the
management of change system will be greatly enhanced once the roles and responsibilities are
clearly understood. Of course, accountability is the key to success. Flowcharts in Annexes at
the end of the document show the management control at various stages from the initiation
of change, review by officials, and approval by competent authority and implementation of
change.

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Table - 1 Platform
Role Purpose Responsibilities
Asset Manager  Administration  Set policy and objectives
 Resource Provider  Conduct periodic review
 Steering change process  Approve long term bypass of SCE
Surface  Manager of change  Overall control of change management
Manager process
 Approve all major changes
 Monitor implementation of change
 Conduct periodic review
Surface Area  Facilitator  Review changes
Manager  Keep track of the changes.
 Support implementation of change as per
schedule.
Head – Well  Expert advice on  Guide engineers in implementing the
Services wellhead conditions change
Head – HSE  Expert advice on HSE.  Review change proposals
 Monitoring the change  Analyse incident and accident trend and
management identify hazards
 Recommend approvals at  Analyse regulatory changes and industry
base standards that influence engineering
changes
 Appraise senior management on accident
trend and regulatory changes.
Project  Coordination at site  Facilitate incorporation of change as
Coordinator planned
Offshore  Controller at site  Approve minor changes
Installation  Ensure implementation of change and
Manager close out in Change Control form
 Ensure updating of P&IDs’ and
documents
 Communicate change to relevant
employees
 Keep track of impact of change and
send report to Area Manager

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Process  Process Expert  Initiate basic proposal for change in


Manager  Initiator of change in process, procedure or parameter
process parameter/  Do engineering review
procedure  Work with fellow engineers to implement
 Initiator of change in change and updating of P&ID and
surface facility / static documents
equipment/bypass
control
Maintenance  Maintenance expert  Guide engineers in implementing the
Manager/  Initiator of change related change.
to rotary equipment  Ensure that equipment safety is not
jeopardized by such changes. OEM
feedback to be taken need based
 Keep track of the changes.
 Join Process Manager in initialling basic
change proposal and implementation
 Provide safety input
Wellhead  Wellhead expert  Join Process Manager in initiating basic
Manager  Initiator of change related change proposal and implementation
to well head platform  Provide safety input
HSE Manager  Platform Safety expert  Join Process Manager in initiating basic
change proposal and implementation
 Provide safety input
Change  Assess the risk of proposed change
Management  Develop proposal for change
Team  Verify the impact of change on the system,
process and installation as a whole.
 Verify that the impact of change was
addressed in all aspects.
 Suggest additional control and safety
measures if required.
 Ensure that control and safety measures
are implemented/ incorporated in the
system.

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Table-2 Drilling

Role Purpose Responsibilities

Head Drilling  Administration  Set policy and objectives


Services (HDS)  Resource Provider  Conduct periodic review
 Steering change process
Location  Manager of change  Overall control of change management
Manager/ process
Operations  Approve major changes
manager  Monitor implementation of change
 Conduct periodic review

Rig Manager  Facilitator  Review changes


 Keep track of the changes.
 Support implementation of change as per
schedule.

Head – HSE  Expert advice on HSE.  Review change proposals


 Monitoring the change  Analyse incident and accident trend and
management identify hazards
 Recommend approvals at  Analyse regulatory changes and
base industry standards that influence
engineering changes
 Appraise senior management on accident
trend and regulatory changes.
Offshore  Controller at site  Approve minor changes
Installation  Ensure implementation of change and
Manager close out in Change Control form
 Ensure updating of P&IDs’ and
documents
 Communicate change to relevant
employees
 Keep track of impact of change and
send report to Area Manager

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HMDS/  Maintenance expert  Guide engineers in implementing the


Engineering change.
Superintendent  Ensure that equipment safety is not
jeopardized by such changes. OEM
feedback to be taken need based
 Keep track of the changes.
 Provide safety input
HSE Manager  Rig Safety expert  Initialling basic change proposal and
implementation as member of ChMT
 Provide safety input
Change  Assess the risk of proposed change
Management  Verify the impact of change on the
Team (ChMT) system, process and installation as a
whole.
 Verify that the impact of change was
addressed in all aspects.
 Suggest additional control and safety
measures if required.
 Ensure that control and safety measures
are implemented/ incorporated in the
system.

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6. HAZARD IDENTIFICATION SYSTEM

6.1 EXISTING FACILITIES, PROCESS AND OPERATIONS

Continuous and systematic hazard identification is the most critical steps in risk
assessment. In installations, the main hazards are flammable and toxic substances i.e.
hydrocarbons and hydrogen sulphide (in case of sour fields). The experience gained by the
oil industry in the design and operation of offshore production platforms has been
compiled in a series of standard procedures, recommended practices, company
standards and regulatory requirements that represent good practice. These standards
specify the methods of control of hazards that have already been identified.

There are several methods for hazard identification such as What If, Checklist, HAZOP, FMEA,
Bow-tie Analysis, LOPA, Fault Tree Analysis, etc.

6.1.1 Observation of employees

An employee notices a sub-standard act or condition at the place of work first. If it is


immediately brought to the notice of supervisor or HSE Manager, the hazard can be
quickly controlled. The reported incident would also help identify the weakness, if
any, in the hazard control system and any new hazard. Employees shall be
motivated to report sub-standard act or condition at the place of work as soon as it
comes to their notice.

6.1.2 Review of past incidents and accidents

Head HSE shall carry out periodical review of all incidents and accidents that occurred in
ONGC Assets to collate statistical data to determine –

 The root cause of incidents/accidents;


 Adequacy of existing hazard control measures;
 Additional control measures required.
 Follow up actions.

Head HSE shall ensure that additional control measure, identified on the basis of review
mentioned above, are put in place in a time bound program. Head HSE shall submit a
report to the respective Asset/Services/Basin heads and Head Offshore Safety within 90
days of the review of incidents / accidents and the control measures put in place. The
report shall capture the lessons learned and the means of communicating the same to
personnel.

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6.1.3 HAZOP study

Hazard and Operability (HAZOP) studies are undertaken by the application of a


formal, systematic and critical examination of the process and engineering intentions of
a process design. The potential for hazard is thus assessed and the mal-operation or
malfunction of individual items of equipment and the consequences for the whole
system are identified. The study is structured around a specific set of guidewords. HAZOP
study is performed by a group of competent persons with relevant experience
and moderated by a HAZOP leader. Results of discussions are recorded in HAZOP worksheets.

The overall aims of HAZOP study are:

 To identify all deviations from the way the design is expected to work,
their causes and all the hazards and operability problems associated with
these deviations.
 To decide whether action is required to control the hazard or the
operability problem and if so, to identify the ways in which the problem can be
solved.
 To identify cases where a decision cannot be made immediately and to decide on
what information or action is required.
 To ensure that actions decided upon are followed through.

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6.1.4 HAZOP guidewords and their meaning

Guide Meaning Comments


words

NO, NOT The complete negation No part of the intention is achieved and
OR of design intention nothing else happens

MORE OF Quantitative increase These refer to physical properties like flow


or decrease of any rates and temperatures
LESS OF relevant physical
parameters
AS WELL A qualitative increase All design and operating intentions are
AS achieved together with some additional activity

PART OF A qualitative decrease Only some of the intentions are achieved some
are not
REVERSE The logical opposite of Reverse flow or chemical reaction
the intention
OTHER Complete substitution No part of the original intention is achieved.
THAN Something quite different happens

Outcome of a HAZOP study is a draft report containing a set of recommendations


to control the hazards identified. The recommendations may be divided into
two categories, i.e. essential and desirable. The outcome of group
discussions is recorded on worksheets. The worksheets are used to track down the
basis on which a specific recommendation is made. The study is completed with the
issue of a final report giving details of follow-up actions

6.2 PROCEDURAL CHANGE IN EXISTING INSTALLATION

If the procedure is large i.e., shut down, start up, hook up of a new facility,
the HAZOP technique with appropriate guidewords can be applied to identify
hazards. In case the procedure is small and stand- alone (say 8-10 steps in a given
sequence), Critical Task Analysis (CTA) or Job Safety Analysis (JSA) techniques are
applied for hazard identification. For Simultaneous Operations (SIMOPS), a SIMOPS
HAZID is done. It is basically a procedural HAZOP study. The operations in each
of the installation are listed in a matrix format and then the HAZOP study begins.
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6.3 CHANGE IN PARAMETERS


An engineering review is to be done to identify hazards. The equipment data sheet and
instrumentation provided for process control alarms and shut down functions
shall be reviewed.

7 ASSESSMENT OF RISK OF PROPOSED CHANGE

7.1 ASSESSMENT CRITERIA

It is recognized that no industrial activity is entirely free from risk. It is never possible
to be sure that every eventuality has been covered by safety precautions. In
assessment of risk the principle is that the risk to persons should be reduced to a
level “As Low as Reasonably Practicable” (ALARP). This level is reached when it is
found that there would be a gross disproportion between the cost (in money, time
or trouble) of additional preventive or protective measures, and the reduction in risk
they would achieve. In other words, it can be said that the risks should be low
enough for the public to tolerate. This is what risk criteria attempt to establish.

7.1.1 What is tolerable?

Where an identified hazard is one that is already recognized by the oil


industry, compliance with the standard good practice would be adequate. Where a new
hazard is identified, the risk to persons should be reduced to a level “As Low as
Reasonably Practicable” (ALARP).

7.1.2 Method of assessment

The main principles of safe facilities design and operation are:

 Minimising the likelihood of uncontrollable release of hydrocarbons and other


hazardous substances.
 Minimising the chances of ignition of flammable fluids.
 Preventing escalation of fire and damage to equipment.
 Providing for protection of personnel and escape.

These principles must be applied in assessment of risk. However, the direction and level
of effort devoted to such assessment should be relative to the inherent risk. The
focus on the areas that present the greatest risk is essential.
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7.1.3 Assessment criteria for change in personnel

A formal assessment of risk is required when a new contractor is hired for


any service related to operations at an offshore facility. The criteria for assessment are:

 Contractual personnel staying on ONGC’s installation shall follow ONGC’s SMS


 The safety management system of the contractor personnel not staying on
ONGC’s installation shall be compatible with ONGC’s SMS otherwise a bridging
document should be developed for interface management of two SMSs
 Safety training of contractor’s personnel shall be appropriate to their
functions and approved by ONGC.
 Emergency response system of the contractor shall dovetail into
ONGC emergency response system.

7.2 RISK ASSESSMENT

Once hazards have been identified, the risks are estimated from the potential
consequences and the likelihood of occurrence, using qualitative and/or quantitative
methods such as Fault Tree, Event Tree, Risk Matrix, etc. The total risk is then evaluated by
comparing against criteria for acceptability

A HAZID (Hazard Identification) study is a brainstorming session to identify as many


hazards as possible. A checklist of major hazards guides the discussions. The
guidewords are as follows:

 Hydrocarbon release
 Collision
 Structural failure
 Capsize / Sinking /Drifting/Grounding/Listing
 Transport (Vessel/Helicopter) incident
 Occupational accidents
 Non-process fires
 Rig Deployment
 Equipment Adequacy
 F&G system
 Rig Stability
 Blowout
 Stuck-up
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HAZID is typically performed by a group of competent persons with


relevant experience, moderated by a HAZID leader and reported by a skilled
secretary. The output of a HAZID study is a qualitative assessment of the hazards
identified. The Specialist Pool Manager shall ensure that competent persons
conduct a HAZID study then together with the Head (HSE) they shall review the
HAZID study report and finalize the list of hazards that need to be addressed.

7.3 PROCESS / PROCEDURE/ PARAMETER/ SURFACE FACILITIES/ EQUIPMENT CHANGE


IN EXISTING FACILITIES

1. Checklists given in the Annexes or developed on these lines should be used by


the change management team to assess the impact of change. The focus
should be to assess whether standard procedures are being followed and to
identify any problems that may further attention.

2. Based on the information from the checklist the change management team assesses
whether the change is significant enough for warranting detailed risk assessment.
Changes requiring detailed risk assessment are termed as major, all other changes
are termed as minor change.

3. For major changes, the Team shall examine the output of –

a. Hazards observed by employees


b. Review of past accidents / incidents
c. HAZID study report
d. HAZOP study recommendations
e. JSA/Critical Task Analysis
f. Engineering Review and then

i. Describe the change proposed;


ii. Describe the hazard / hazards identified due to the proposed change;
iii. Review the impact on process, mechanical and electrical
equipment, safety and environmental aspects (Use Hazard Identification
Checklist placed at Annex-1).

4. On the basis of assessment made as above, the Team shall judge-

a. The acceptability of the risk;


b. Adequacy of existing control measures;
c. Additional risk reduction measures required and its estimated cost.
Page 24
Management of Change

5. The Team shall submit its report to Surface Area Manager (SAM)/Rig Manager (RM).
In turn, SAM/RM will forward the report, together with his comments, to
the Head HSE then on to the Surface Manager/Operations Manager for approval.

6. Management’s decision on the proposed change and risk reduction measure


shall be conveyed to the Team.

7.4 CHANGE IN PERSONNEL

The Team shall assess the compatibility of the contractor’s safety management system,
emergency response system and training standard of its employees with that of
ONGC. On the basis of the assessment, the Team shall judge;

a. The acceptability of risk;


b. The gaps that must be bridged.

8 IMPLEMENTATION

8.1 PROGRAM FLOW CHART

Once the proposal for change receives management’s approval, the Change Management
Team has to get on with its implementation in a time-bound program. To put the
matter in clear perspective, the following flow charts are presented:

• Flow chart for change in process/procedures/parameter/ surface facilities/


equipment
• Flow chart for bypass/ abort-control

The Change Management Team shall ensure that the change made is duly reflected
in P&IDs & relevant documents and change master record. All changes to be discussed in
Group safety meetings and displayed prominently for awareness of personnel on-board.
Temporary changes to be marked in change master record for reverting back to original
condition.

8.2 PROJECT SCHEDULE AND MILESTONES

Change Management Team shall prepare a project schedule with milestones for
implementation of the change. Copies of project schedule shall be made available to:

1. Surface Manager /Operations Manager


2. Head HSE
Page 25
Management of Change

3. Surface Area Manager/Rig Manager


4. Specialist Pool Manager/ PMM / Engineering Superintendent
5. Offshore Installation Manager

8.3 CHANGE CLOSE OUT

OIM will oversee and ensure implementation of the change at site. Once the change is
implemented, OIM will ensure that suitable changes are incorporated in the P&IDs and
other relevant documents. OIM will close out the change by signing off in the Change
Control Form.
Subsequently, it is also to be ensured that the change has been conveyed to all the
personnel likely to be affected by the change.

8.4 PERIODIC REVIEW

Surface Manager/ Operations Manager shall review, once every six-months, all changes
under implementation / implemented in accordance with this MOC procedures. The focus
of review would be on timely implementation, adequacy of procedures and control,
documentation and communication.

9 CONTINUAL IMPROVEMENT

9.1 TRACKING RESULTS OF THE CHANGE

Once a change has been implemented at an installation, the effect of such change
on hazard control shall be monitored by Head-HSE as per a pre-
determined program.

9.1.1 Active monitoring

The focus of monitoring would be on implementation of change in accordance with


MOC, effectiveness of the change in reduction of risk and compliance
with performance standards.

9.1.2 Reactive monitoring

After implementation of the change, if there occurs an incident or accident, it should


be investigated. The focus of investigation would be to ascertain whether the change
in process or procedure requires any correction.
Page 26
Management of Change

9.2 RESULTS OF HAZARD IDENTIFICATION AND RISK ASSESSMENT

Head–HSE shall convene yearly meeting to review the results of hazard


identification and risk assessment and the changes brought about in the process,
procedures, contractor selection etc.

9.3 RECOMMENDATIONS OF AUDITS

Where an audit recommendation requires change in process and procedures,


it shall be referred to the specialist group for further design review & appropriate
action in accordance with the current engineering practices.

9.4 MANAGEMENT REVIEW

9.4.1 Review by Management


A review of this document shall be carried out every five year or earlier if need arises.

9.4.2 Improvement
Head – HSE shall ensure that the change management system is improved on the
basis of the review mentioned above.

10. ANNEXES
Annexure 1 & 2 depict the flow of a Change control document from initiation to
completion of the change.
Annexure 3 to Annexure 6 are different formats to be used for documentation of different
steps during the process of management of change.
Annexures 1, 2, 3, 4, & 6 will be used for platforms and Annexures 1, 2, 5, & 6 will be used
for rigs. Annexures 3 & 4 can also be used for rigs, if applicable.
Page 27
Management of Change

Annex 1 Flowcharts
Figure 1: Change of Process / procedure / parameter / surface facility

Initiation of the change

Initial Risk assessment


by ChMT

Review by OIM

Is change
acceptable? No

Yes
Feedback Conduct detailed
Yes
Risk Analysis
Is the change
No major? ChMT Assessment Revise

Change Closeout Review by PMM / No


by OIM Engg. Suptd/
HMDS
Approval by OIM

Execution at site
SAM/ No
Rig Manager Review

Upgrade P&ID, change


master records Yes Head HSE Review
No

Surface
Manager/Operation
Manager Approval
Page 28
Management of Change

Annex 2 Bypass Abort Control

Initiation bypass / abort

JSA / Risk
Analysis

Review by ChMT
 Assess acceptability of risk
 Identify adequacy of risk
reduction measures

Emergency Short Term Medium Term Long Term (up Very Long Term (1
(up to 14 days) (up to 90 days) to 9 months) year) & Permanent

SAM/RM SAM /RM


OIM /RM
Review Review
Review

Approval
No
by OIM Head HSE
Review
Head HSE
Review Head HSE
Review Surface Manager
Review

Approval by Approval
No Approval by
SAM/OM by AM/ No
SM/LM
HDS
No

Yes Yes
Yes

 Recording and linking with


PTW
 Visual display
 Appraisal to senior
management as per bypass
policy

Implementation Change Closeout


at site by OIM
Page 29
Management of Change

Annex 3 Change Control Form S. No. ---

Name of Installation
Date of Initiation
Reason for change
Detailed description of change

Type of Process Surface Procedure Parameter Personnel Bypass/


Change Facility
Abort

Risk Date
Assessment
/ /
conducted

SIMOPS YES/ NO SIMOPS Date / /


Involved HAZOP

HAZID Date Findings Notes:


Conducted
/ /

HAZOP Date Notes:


Reviewed
/ /

CHANGE MANAGEMENT TEAM


We have evaluated the Change control request with respect to Health, safety and environment aspects and
the following control and safety measures are proposed.

 Recommended for approval

Name & Signature of Change Management Committee members

Approval

Designation Signature Date


OIM
PMM/Engineering Supdt./HMDS
SAM/Rig Manager
Ops Manager/LM
Head (HSE)
Surface Manager
Asset Manager/HDS
Page 30
Management of Change

Annex 4 Assessment of Risk due to proposed change - Initiator’s Review (Production


Installations)

1. Type of change: (Tick Box). Process Procedure Parameter


Bypass Personnel Surface Facility

2. Reason for Change:

3. Description of Change:

4. Drawings (Attach marked-up P&IDs)

5. In the Table below, mark the items that are to be changed

Process Conditions

S.NO. Conditions Description P &ID


Affected Drawing

1. Temperature

2. Pressure

3. Flow

4. Composition

5. Toxicity

6. Flash point

7. Flash point

8. Operation

9. Method Start up

10. Routine operation

11. Shutdown

12. Preparation for maintenance

13. Abnormal operation

14. Emergency Shutdown

Comment:
Page 31
Management of Change

Procedures

S.No Conditions Description P &ID


Affected Drawing

15. Trip and alarm testing

16. Maintenance procedures

17. Inspection procedures

18. Portable equipment

19. Safety Equipment

20. Fire fighting and detection systems

21. Personal protective equipment

22. Environmental Conditions

23. Liquid effluent Filters

24. Solid waste

25. Gaseous emissions

26. Noise

27. Vibrations

Hardware Design

S.No Conditions Description P &ID


Affected Drawing

28.
Design pressure
29.
Design temperature
30.
Material of construction
31. Loads on, or strength of: Vessels Pipe
work/supports/bellows
32. Equipment
33. Valves
34.
Slip-plates
35.
Restriction Orifice
36.
Instrumentation and control systems
Page 32
Management of Change

37.
Trips & Alarms
38.
Access
39.
Rate of corrosion
40. Rate of erosion

41. Isolation for maintenance


42. Static electricity
43.
Utility Services
44. Hazardous Area Classification

Risk Assessment of proposed change – Process Review

(Tick as applicable)

Impact of Change Yes No

A. Relief and Blow down

1. Does the proposed change Introduce or alter any potential


cause of over/under pressurizing the system or part

2. Does it Introduce a risk of creating a vacuum in


the system or part of it?
3. Does it Introduce or alter any potential causes of raising
or lowering the temperature beyond the design limit?

4. Does it In any way affect equipment already


installed for the purpose of preventing or
minimizing over or under pressure?
B. Hazardous Area Classification

5. Does it introduce a new or change the location


of potential leaks of flammable material?
6. Does it change the chemical composition
or the physical properties of any of the process
materials?
7. Does it Introduce a new or change the existing
location of any of the elect/mech/inst
equipment?
C. Safety Equipment

8. Does the proposed change require the


provision of additional safety equipment?
(e.g., more detectors, more Fi-Fi
hoses/extinguishers etc.,)
Page 33
Management of Change

9. Does the change going to affect performance


of any of the existing safety equipment?
D. Operations & Design

10. Does it introduce a new or change the existing


hardware?
11. Does it required to be reviewed with reference to
any specific Codes of Practice or standard?
12. Does it affect safe access for personnel and
equipment, safe place of work and safe layout?
13. Do we need to revise inspection
frequencies for any equipment?
14. Does it affect any existing trip or alarm
system or require additional trip or alarm
protection?
15. Does it affect the controllability of the process?

16. Does it alter the composition of, or means of


disposal or effluent?
17. Does it alter noise level?

E. HAZOP

Do we need a HAZOP study to be carried out for the proposed


change?
Comments:

Assessment
Page 34
Management of Change

Risk Assessment of proposed change – Mechanical (Piping) Engineer’s Review

(Tick as applicable)

Impact of Change Yes No

1. Are the following shown/appropriate (wherever applicable):

• Line service and pressure rating


• Valve specification
• Specification breaks for piping
• Tie-in points
• Net Positive Suction Head (NPSH)
• Pockets, slope of line
• Flowline insulation gaskets
2. Is a changed P&ID required?

3. Are PSV and controller set points shown & appropriate?

4. Does the proposed change have any adverse impact on overall Layout /
routing of piping (with reference to both process and utility
equipment/piping)
5. If there is packaged item in the proposed change, has the vendor
supplied equipment-matching line shown?
6. Is equipment description adequate?

7. Equipment no., name, dimensions, duty, design temperature and pressure,


class.
8. Are any special design codes applicable?

9. Are special materials of construction required?

10.Is corrosion protection satisfactory? Comment

Comment:

Assessment

Signature................................... Date.................................
Page 35
Management of Change

Risk Assessment of proposed change – Instrument Engineer’s Review

(Tick as applicable)

Impact of Change Yes No

1. Does the proposed change put a limitation on the size of existing control
valves &/or their response time?
2. Could there be any serious impact on the proposed
change due to any particular failure mode of control
valve (fail to open, fail to close, stuck in position etc.,)
3. Has the provision of manual reset provided after actuation of shut down

4. Does the shut down actuation gives an indication locally or in CCR.

5. If there is a trip system introduced, does it have


provision for on-line testing.
6. Has testing procedures for such trip systems established

7. If there is PSV introduced does it required to be sized for fire case.

8. Does the RO (if any ) sizing consider any eventuality

9. Does the instrumentation provided (e.g., PG, LG etc.,)


have provision of drain and ventilation connection
10.Is there any critical operator interface in operation of any
instrumentation.
11.Does the proposed change requires to alter existing number
of telemetry points.
12.If control is through DCS, does the operator have adequate
information on DCS panel.
13.Does the proposed change require any protection against
static electricity, lightning, equipment-potential bonding
14.Does it require earthing

15.Has the procedure established to keep the disconnected


equipment (if any) positively isolated.
Comment:

Assessment

Signature................................... Date.................................
Page 36
Management of Change

Risk Assessment of proposed change – Change Management Team

(Tick as applicable)

Impact of Change Yes No

1. Are changes required in Operating Manual, start-up & shutdown


procedures, operating and maintenance procedures?
2. Would the additional load on utilities be within design limits?
3. Are new equipment and instrumentation compatible with existing and site
preferences?
4. Is control method overly complex, manually intensive or inconsistent
with current practice?
5. Does operator have sufficient information to control and/or detect
malfunctions?
6. Will the system be operable in extreme summer and winter weather
conditions?
7. Are tie-in points and tie-in method appropriate?
8. Is steam -out, purge, flush, drain and vent connections adequate?
9. For introduction of a new chemical-
 Is existing personal protection adequate?
 Are MSDS available?
 Do safety shower and eye wash systems cover it?
 Are any new laboratory analyses required?
 Are relevant laboratory procedures and equipment available?
10. If proposed change introduces a new vessel, does it have adequate
isolation/blinding provisions for entry/inspection and sufficient nozzles
and manholes for ventilation?
11. Does new equipment have adequate isolation for maintenance access,
for repair and/or removal?
12. Are there sufficient sample points and are there means provided to
dispose of flushings?
13. Are there adequate provisions for start-up, shutdown, ESD & start-up after
ESD?
14. Is operator training required?
15. Are there adequate provisions for testing, if required? (i.e. functional test)
16. Do changes require additional fire protection/fire fighting measures?
Comments:
Comment:

Assessment

Name and Signature of ChMT Date


Page 37
Management of Change

Annexure-5 Assessment of Risk due to proposed change - Initiator’s Review


Drilling
PARAMETER YES NO NA SAFETY /OPERATING/MAINTENANCE SYSTEM YES NO NA
Ground stability    Any change required in BOP controls   
Change in pressure    Toxic release   
Change in Temperature    Additional control/ tripping system   
Change in flow    Hydrocarbon release   
Thermal safe guard requirement    Lifesaving appliances   
Noise level    Additional Fire protection required   
Vibration level    Additional PPE requirement   
Effect on load bearing structure    Hazardous area classification   
Alarms and trips    Ships stability   
Corrosive    Tripping /Fall hazard   
Load addition within design limits    Reduction in Oxygen Level   
Flash point/Pour point    Change in lockout capability   
MANUALS YES NO NA Maintenance preparation /procedures   
Safety management manual    Inspection procedures   
Maintenance procedure manual    Change in MOC   
SOPEP    Hazardous area classification   
Operating manual    Static electricity   
Emergency response plan    Start-up method   
Office procedure manual    MSDS requirement   
Forms and check lists    Protection Barriers / Guards rails required   
ISPS Manual    Earthing requirement   
Risk register    Mandatory signs /warnings requirement   
Legal Register    Hazardous waste generation   
Towing Manual    Emergency shower/ eye wash required   
Legal Register    Load test requirement   
DMP    Change in setting /replacement of relief/isolation valve   
MSDS booklet    Change to Emergency shutdown system   
Recovery of person from water    Change / replacement of safety devices   
Stability booklet    Area isolation required temporary   
Towing Manual    Area isolation required Permanent   
Ship security plan    GENERAL/OTHERS YES NO NA
Bridging document required    Training requirements   
Briefing required in Daily Ops & Safety Meeting   
POLLUTION IMPACT YES NO NA Briefing required in GSM   
Internal environment    Change in work culture   
Gaseous emissions    Effect /Impact of action on others   
Waste generation and treatment    Coordination for activities/command &   
Surrounding environment    DRAWINGS/PLANS
control YES NO NA
Ecological disturbances    LSA PLAN   
External environs    FCP   
Impact on Air/Water    Electrical drawings   
Noise Plan   
REGULATIONS YES NO NA Hazardous area map   
Impact on Risk survey    Navigation Light Arrangement Plan   
Impact on MOP&G rules    Light
LIGHT&&Sound
SOUNDSignal PlanPLAN
SIGNAL   
Conformity to Regulations/ Codes    Piping Drawing   
IACS approval if required    System drawings   
NDT/MPI/DP Test Etc if required    P&ID   
Hazardous area map   

HSE Manager/ Elect I/C Mech I/C Sub Sea I/C CE(Marine) Master
Page 38
Management of Change

Annexure –6 Implementation & Feedback Change Control Form No.___

Name of Installation
Date of Initiation
Type of change PERMANENT/TEMPORARY
Reason for change
Detailed description of
change

Approved by

Approved on (date)

Implemented on (date)

Signature of OIM

Documents updated
(with date)
Signature of OIM

Concerned persons
informed (with date)
Signature of OIM

Change normalisation
date (in case of
Signature of OIM
temporary change)

Signature of OIM Date


Page 39
Management of Change

NOTES

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