a NON-CONFORMANCE PROCEDURE NO. : CSP-19 CARIGALI CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 2 OF 14 1.0 PURPOSE 2.0 3.0 4.0 This procedure’ established to provide a systematic approach for controlling and recording products or processes which do not conform to specified requirements to prevent them from unauthorised use or installation. SCOPE This procedure covers the identification, documentation, evaluation, segregation, disposition and notification to the CONTRACTOR or CARIGALI (for CARIGALI's supplied materials) of the non-conforming product or processes identified/detected throughout the execution of CARIGALI's Project. REFERENCES Contract Documents DEFINITIONS Non-conformance - An existing condition that does not conform or deviates from the requirement of the Contract. Disposition - Am action to determine how a non-conformance shall be resolved. HOLD - A tag or mark used to identify a non-conforming item to prevent it from further processing pending its resolution. QA/QC Manager - ~The. CONTRACTOR's Quality Assurance / Quality Control Manager or his designated Representative. Works = Alll activities or services to be performed by the CONTRACTOR as expressed in the Contract, Document. Non-conformance - —— Arreport to identify, describe and document the Report (NCR) specific non-conformance. File: CSP-19 amparworas NON-CONFORMANCE PROCEDURE NO. : CSP-19 CARIGALI CONTROL PROCEDURE REVISION, : 0 JACKET/TOPSIDES PAGE 3 OF 14 Non-conformance - Areport to establish and / or recommend in Corrective Action and _detail the corrective action to be taken to resolve Close-out (NCCACO) —_the non-conformance. The report also documents 5.0 that the approved disposition and corrective action had been implemented and the results recorded in the close-out section of the report Non-conformance - A record for tracking all NCRs and their Report Register (NCRR) current status, Non-conformance - report to seek a waiver from CARIGALI on a Waiver Request (NCWR) specific non-conformance, Non-conformance - A record for tracking all non-conformance Waiver Request waiver requests and their current status. Register (NCWRR) Non-conformance - — Arreport to identify, describe and document the Report (CARIGALI) specific non-conformance for CARIGALI (NCRC) supplied materials. PROCEDURE The reporting of non-conformances must, in keeping with the CONTRACTOR's responsibility for project quality, be one of the primary functions of the CONTRACTOR's Project Management Team and in particular the CONTRACTOR's QA/QC Department. The expeditious handling of the disposition and corrective actions to resolve the non-conformance is essential in order that the Works may proceed with minimal delay to the Project schedule. The reporting of non-conformities detected throughout the Project phase, by either CONTRACTOR or CARIGALI, is classified into two categories i) Non-conformance by CONTRACTOR. ii) ‘Non-conformance of CARIGALI Supplied Materials. 5.1 Non-conformance by CONTRACTOR. 5.1.1 When a non-conformance is identified during inspection, the CONTRACTOR's QC Inspector shall raise a NCR File: CSP-19 amPerHOMAs CARIGALI NON-CONFORMANCE PROCEDURE NO. : CSP-19 CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 4 OF 14 5.2 5.12 5.13 3.14 SS 5.1.6 (Appendix 1) on the non-conformity and submit to the QA/QC Manager for further action “The CONTRACTOR's QA/QC Manager shall submit the NCR, together with the Non-conformance Corrective Action and Close-out form (NCCACO) (Appendix 1), to the Project Manager for acknowledgement and further action, The Non-conformance Report Register (NCRR) (Appendix IV) shall be updated accordingly. A copy of the NCR shall be extended to CARIGALL. ‘The QA/QC Manager shall liaise with the Project Manager to study the NCR in consultation with the relevant personnel and Department and propose the disposition and corrective action required to close-out the non-conformance. The proposed non-conformance disposition and corrective action shall be submitted to CARIGALI within forty-eight (48) hours from the time of NCR issuance. The CONTRACTOR's QA/QC Manager shall seek CARIGALI's approval on the proposed disposition and corrective action prior to implementation. All non-conforming items shall be tagged and marked as "HOLD" and segregated from the accepted items until such time the disposition and corrective action on the item is resolved and accepted by CARIGALL The CONTRACTOR’s QA/QC Manager shall expedite and co-ordinate with the Project Manager for the proper and timely execution of the NCR's corrective action and close-out the non-conformance. Non-conformance of CARIGALI Supplied Materials. 3.21 When a non-conformance is identified upon receiving inspection, the CONTRACTOR's QC Inspector shall raise a Non-conformance Report (CARIGALT)_ (NCRC) File: CSP-19.a1mNON-CONFORMANCE, PROCEDURE NO, : CSP-19 CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 5 OF 4 83 (Appendix 11) on the non-conformity and submit to the QA/QC Manager for further action. 5.2.2 The CONTRACTOR's QA/QC Manager shall issue the NCRC to CARIGALI through the Project Manager for further action, The NCRR shall be updated accordingly. 5.23 CARIGALI shall propose a disposition and corrective action within forty-eight (48) hours from the time of NCRC issuance, The proposed disposition and corrective action shall be done through the appropriate section of the NCRC and submitted to the CONTRACTOR's Project Manager for further action. 5.2.4 All non-conforming items shall be tagged and marked as "HOLD" and segregated from the accepted items until such time the disposition and corrective action of the item is finalised by CARIGALL 5.2.5 The CONTRACTOR's QA/QC Manager shall expedite and co-ordinate with the Project Manager and CARIGALI for the proper and timely execution of the NCRC's corrective action and close-out the non-conformance Disposition and Corrective Action for a Non-conformance The Non-conformance Corrective Action and Close-Out form (NCCACO) shall be utilised by the CONTRACTOR to record the disposition, corrective action, if any, and close-out the non-conformance once the corrective action is acceptable to CARIGALL The disposition of the issued NCR and NCRC proposed by the CONTRACTOR / CARIGALI shall be based on the following: Accept-As-Is- This non-conformance does not affect the basic use of materials or items as specified in the Contract. Rework = This non-conformance may be reworked to meet the Contract's requirements. These reworked items shall File: CSP-19sameroMas CARIGALI CONTROL PROCEDURE NON-CONFORMANCE REVISION. : 0 JACKET/TOPSIDES PAGE 6 OF 14 PROCEDURE NO. : CSP-19 Repair Reject 5.3.1 5.3.2 be inspected and/or retested in accordance with the relevant procedure. = This non-conformance may be repaired to a condition that the material or item(s) functions reliably and safely. The repaired item shall be inspected and/or tested accordingly. = This non-conformance cannot be physically reworked, repaired or does not meet the Contract requirements, Such item(s) shall be marked/tagged and removed from the Project. "Accept-As-Is" Disposition i) iii) When the "ACCEPT-AS-IS" disposition proposal of the CONTRACTOR is acceptable to CARIGALI, the CONTRACTOR’s QC Inspector shall remove the "HOLD" and release the item for further processing. The Non-conformance Close-out section of the NCCACO shall be filled in by the CONTRACTOR's QA/QC Manager for submission and approval by CARIGALL The same shall apply with the NCRC, if the NCRC is raised by the CONTRACTOR Upon approval of the close-out by CARIGALI, the CONTRACTOR's QA/QC Manager shall update the NCRR and submit a copy of the approved NCCACO or NCRC to the Project Manager and CARIGALI for further action, "Reject" Disposition i) When the final disposition as agreed by CARIGALI is "REJECT", the CONTRACTOR's QA/QC Manager shall update the NCRR and submit a copy of the NCCACO or NCRC to the Project Manager and CARIGALI for further action, File: CSP-19 amRONAS CARIGALI NON-CONFORMANCE PROCEDURE NO. : CSP-19 5.3.3 CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 7 OF 14 ii) The CONTRACTOR's QC Inspector shall remove the "HOLD" and redesignate as "REJECT" Materials that are identified as "REJECT" shall be transferred to the designated area for removal from the Project. iii) The CONTRACTOR's QA/QC Manager shall expedite and co-ordinate with the Project Manager and, if required, with CARIGALI for the proper and. timely replacement of the rejected item and close-out the non-conformance. "Rework" or "Repair" Disposition ) iit) iv) When CARIGALI concurs. with the CONTRACTOR's "REWORK" or "REPAIR" disposition and corrective action proposal as described in the NCCACO form or the NCRC, the CONTRACTOR's QC Inspector shall remove the "HOLD" and release the item for further processing. The CONTRACTOR's QA/QC Manager shall update the NCRR and submit a copy of the NCCACO or the NCRC to the Project Manager and CARIGALI for further action. The corrective actions to be performed for the "REWORK" or "REPAIR" shall describe in detail the remedial work to be done to ensure that the non-conforming item is rectified. Additional information may be attached to the NCCACO or the NCRC, if required The CONTRACTOR's QA/QC Manager shall expedite and co-ordinate with the Project Manager and CARIGALI for the proper and timely completion of the "REWORK" or "REPAIR" on the non-conforming items and close-out the non-conformance File: CSP-19.smenn NON-CONFORMANCE PROCEDURE NO. : CSP-19. CARIGAL CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 8 OF 14 v) Upon completion of the "REWORK" or "REPAIR" ‘on the non-conforming item, the item shall be re-inspected by both the CONTRACTOR's and CARIGALI's Representative to ascertain the items acceptability. vi) In the event the remedial work is unacceptable, the QA/QC manager shall fill in the Non-conformance Close-out Section of the NCCACO and propose the next course of action for the non-conformance. The NCRR shall be updated accordingly. The same process shall be applied on the NCRC for CARIGALI's items. vii) The CONTRACTOR's Project Manager in consultation with the QA/QC Manager may seek CARIGALI's concurrence to repeat the "REWORK" or "REPAIR" process by reissuing a new NCCACO form bearing the original NCR identification number and further identified as "ISSUE NO. 2" viii) ‘The rectification process of the non-conforming item may be repeated to properly resolve the non-conformance ix) If the corrective action results for the "REWORK" or "REPAIR" are acceptable to CARIGALI, the NCR shall be processed as described in Section 53.1. 5.3.4 The CONTRACTOR's QA/QC Manager shall be responsible to monitor the NCRR to determine and ensure that the Project Manager makes the necessary changes on existing processes to prevent recurrence of the non-conformities. 5.3.5 The CONTRACTOR's QA/QC Manager shall ensure that appropriate corrective actions and preventive measures are implemented as and when required, through continuous monitoring, investigating and analysing of recurring non-conformities, audit findings, CARIGALI complaints and File: CSP-19 sam3.4.1 542 $43 5.4.4 5.45 54.6 rernonas NON-CONFORMANCE PROCEDURE NO. : CSP-19 CARIGALL CONTROL PROCEDURE REVISION, : 0 JACKET/TOPSIDES PAGE 9 OF 14 poor performance by suppliers to eliminate potential causes of these problems 5.4 Non-conformance Waiver Request The CONTRACTOR may raise a waiver to seek concessions from CARIGALI on non-conforming products or processes having minor deviations or changes from the Contract requirements. The Non-conformance Waiver Request (NCWR) form (Appendix III) shall be used when seeking concessions from CARIGALT on non-conforming products or processes. The CONTRACTOR's QA/QC Manager shall submit the NCR and NCCACO together with the attached NCWR for CARIGALI's approval All NCWRs, endorsed by the Project Manager, shall be supported and justified by sound engineering practices. Once the Non-conformance Waiver Request has been approved by CARIGALI, the CONTRACTOR's QC Inspector shall remove the "HOLD" and release the item for further action. The Non-conformance Close-out section of the NCCACO for the NCWR shall be filled in by the CONTRACTOR's QA/QC ‘Manager for submission and approval by CARIGALI. The CONTRACTOR's QA/QC Manager shall update the Non-conformance Waiver Request Register (NCWRR) (Appendix V) and submit a copy of the NCWR to the Project ‘Manger and CARIGALI, for information. The CONTRACTOR's QA/QC Manager shall update the NCRR and submit a copy of the approved NCCACO to CARIGALI and the Project Manager for further action, File:CSP-19sameTROMAS CARIGALI NON-CONFORMANCE PROCEDURE NO. : CSP-19 CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 10 OF 14 55 5.4.7 In the event the NCWR is unacceptable to CARIGALI, the ‘Non-conformance Close-out section of the NCCACO shall be "filled in by the CONTRACTOR's QA/QC Manager and a new NCCACO reissued to CARIGALI bearing the original NCR identification number and further identified as "ISSUE NO. 2" to clear the non-conformity. The NCRR shall be updated accordingly. The non-conformance shall be processed as described in Sections 5.1 to 5.3 as applicable. Duties and Responsibilities The CONTRACTOR's duties and responsibilities to process a non-conformance may be summarised as follows. 5.5.1 QA/QC Inspector i) Identify the non-conformity and tag/mark the non-conforming item on "HOLD" Note: For steel materials the markings shall be carried out using paint markers ii) Obtain from the QA/QC Manager a NCR/NCRC number and raise the NCR/NCRC. iii) Follow-up on the NCR/NCRC proposed disposition and corrective actions. iv) Replace the on "HOLD" marker or tag with the appropriate disposition action, -—_ ie. "ACCEPT-AS-IS", "REWORK", "REPAIR" or "REJECT" v) __Re-inspect and verify the results of the corrective action are in accordance with applicable procedures. vi) Propose close-out of the NCR/NCRC to the QA/QC Manager when the corrective action results are acceptable to CARIGALL File: CSP-19.amPerROMAs CARIGALI NON-CONFORMANCE PROCEDURE NO. : CSP-19 CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 11 OF 14 vii) Release the item for further processing when the non-conformance close-out has been approved by CARIGALI. 5.5.2 QA/QC Manager i) ii) vii) Issue NCR to the Project Manager or NCRC to CARIGALI Act as the focal point to monitor and co-ordinate the circulation of the NCR/NCRC and related documents between the Project Management Team and CARIGALL Maintain, file. and keep the original Non-conformance Documents. Maintain and update the NCR Register describing the nature and causes of the non-conformity. A copy of the latest NCRR shall be submitted monthly or upon request to CARIGALL Assist the Project Manager and other relevant project personnel and Department to evaluate, review and propose the disposition and the corrective actions to be taken to close-out the rnon-conformance prior to submission to CARIGALL. Ensure all Non-conformance Waiver Requests are supported and justified by sound engineering practices, Maintain and update the NCWR Register describing briefly the justification for the waiver. A copy of the latest NCWRR shall be submitted monthly or upon request by CARIGALL File: CSP.19 amvernonas NON-CONFORMANCE PROCEDURE NO, : CSP-19 CARIGALL CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 12 OF 14 viii) Expedite and co-ordinate with the Project Manager xi) and CARIGALI for the proper and timely rectification of the non-conforming items. Fill in the Non-conformance Close-out section of the NCCACO/NCRC for submission and approval by CARIGALI to close-out the non-conformance. ‘Analyse the non-conformities. and introduce measures to prevent recurrence of the non-conformance, Ensure that the relevant Discipline Managers incorporate the accepted changes or deviations in the ‘As-Built-Drawings and Final Documentation. Project Manager, Discipline Managers and Project Personnel i) ) Review the NCR in consultation with the QA/QC ‘Manager to establish the disposition and propose the corrective actions to close-out the non-conformance prior to submission to CARIGALI Expedite the proper and timely completion of the disposition and corrective actions for the non-conforming items. ‘Analyse the non-conformities and introduce measures to prevent recurrence ofthe non-conformance. Ensure the NCR and NCWR Register describing the nature and causes or the justification to accept the non-conformity are maintained and updated Ensure that the accepted changes or deviations are incorporated in the As-Built Drawings and Final Documentation. File: CSP.19.mpermonas CARIGALI NON-CONFORMANCE PROCEDURE NO. : CSP-19 CONTROL PROCEDURE REVISION. : 0 JACKET/TOPSIDES PAGE 13 OF 14 6.0 SPECIAL REQUIREMENTS 6.1 62 63 CARIGALI shall at any time raise a NCR when a non-conformance is, identified, the same NCR form as per APPENDIX I shall be used. CARIGALI shall issue the NCR to the QA/QC Manager for further action. Tn such cases, the QA/QC Manager and Project Manager shall be responsible to investigate, review and propose the disposition and corrective actions to resolve the non-conformance following the steps as described in this procedure. Only one (1) NCR shall be raised in the event that the same non-conformance has been identified by either CONTRACTOR or CARIGALL To ensure project quality and prevent recurrence of the non-conformance, the CONTRACTOR shall closely monitor every non-conformance committed to identify the cause or the personnel involved. For the First Offence, the CONTRACTOR's personnel committing, the non-conformance shall be counselled to avoid future occurrences with a view to educate and instill quality awareness to the personnel. It is the CONTRACTOR's QA/QC Manager's responsibility to educate such personnel Repeat offenders shall be disciplined as follows: 63.1 Workers, ie. Welders, Fitters, etc. :- i) Second and Third offence - Written warnings shall be issued by the CONTRACTOR. ii) Fourth offence - The personnel shall be demoted or removed from the Project at the discretion of CARIGALL File: CSP.19 ampaTmouas NON-CONFORMANCE PROCEDURE NO. : CSP-19 CARIGAL CONTROL PROCEDURE REVISION, : 0 JACKET/TOPSIDES PAGE 14 OF 14 63.2 Supervisor/Foreman :- i) Accumulation of Five (5) non-conformances by the personnel under his supervision - The CONTRACTOR's QA/QC Manager shall counsel the personnel and a written explanation and commitment by the Supervisor/Foreman to avoid future occurrence of non-conformances shall be submitted to CARIGALI. ii) Accumulation of Ten (10) non-conformances by the personnel under his supervision - A written warning shall be issued by the CONTRACTOR, iii) Subsequent offences by the personnel under his supervision - The Supervisor/Foreman shall be demoted or removed ffom the Project at the discretion of CARIGALL. 7.0 RECORD 7.1 The CONTRACTOR's QA/QC Manager shall be responsible for this procedure and shall be made available to the respective personnel. 72 The CONTRACTOR's QA/QC Manager shall keep, maintain, update and distribute as required, a file of all the non-conformance reports and related documents such as NCR, NCRC, NCCACO, NCWR, NCRR and NCWRR 73. The CONTRACTOR's QA/QC Manager shall ensure all NCR records are kept current at all times and available for examination or audit by authorised parties, ie. CARIGALI Site Representatives, CONTRACTOR and CARIGALI Auditors, and others as required 7.4 Periodic summary reports shall be prepared by the CONTRACTOR's QA/QC Manager on the non-conformance activity and submitted on a ‘monthly basis or upon request to CARIGALI, These reports shall contain a listing and the disposition status of each non-conformance, personnel committing the non-conformance, including the identification number, description, location and date of occurrence File: CSP.19 samAPPENDICEScsP-19 APPENDIX | Page 1 of 2 Fapricayors NON-CONFORMANCE REPORT TO: PROJECT MANAGER NCRNO. : ATIN: DATE PROJECT CONTRACT NO. : __ PAGE DESCRIPTION OF NON-CONFORMANCE : INITIATOR OF THENCR = DATE : CONTRACTOR" /CARIGALI" _“{OELETE AS APPLICABLE) RELATED DOCUMENT (S) P.O ‘SPECIFICATION ws PROCEDURE OTHERS IssUEDBY = ACKNOWLEDGED RECEIPT BY QAIGC MANAGER PROJECT MANAGER i DATE DATE NOTE: NCRTO BE SUBMITTED TOGETHER WITH THE NON-CONFORMANCE CORRECTIVE ACTION and CLOSE.OUT form,csP19 APPENDIX! PAGE 2 OF 2 FABRICATORS Loco NON-CONFORMANCE CORRECTIVE ACTION NCRNO. : DATE ‘CORRECTIVE ACTION PROPOSAL ACCEPT -AS -1S REWORK Oo (5 RePaiR, PROPOSED BY Es PROJECT MANAGER, REJECT CONCURRED BY (QAsaC MANAGER F PROPOSAL REVIEWED. 7 (] acceprasue (] unscceprasue ‘CARIGALI QA ENGINEER ‘CARIGALI RESIDENT ENGINEER —| NON-CONFORMANCE CLOSE-OUT COMMENT (F ANY) APPROVEDBY =: APPROVED | NOT APPROVED ‘CARIGALI RESIDENT ENGINEER pate NOTE: NON-CONFORMANCE CORRECTIVE ACTION and CLOSE-OUT form C.¢.: PROJECT MANAGER, ‘TO BE SUBMITTED TOGETHER WITH THE NCR. i romecsp9 APPENDIX I PAGE 1 OF 1 NCRC NO. = Fasricators © NON-CONFORMANCE REPORT ssueno. Loco ( CARIGALI ) DATE TO + GARIGALI RESIDENT ENGINEER AMIN PROJECT CONTRACT NO. ‘Related Document(s) (Purchase Orders, Specifications, Procedures, Drawings, etc) DESCRIPTION OF NON-CONFORMANCE ITATED BY pate CONTRACTOR" CARIGAL “DELETE AS APPLICABLE) EEE AGREED BY ; __ewac maNAceR DATE ISSUED BY 7 __proveermanaccR = DATE: 0 2 PROJECT MANAGER ATTN cisposmon: [—] accepT-as-is [] epwr [] Rework [] RevEcT (CORRECTIVE ACTION PROPOSAL : REVIEWED BY ‘CARIGALI QA ENGINEER ‘CARIGALI RE: NON-CONFORMANCE CLOSE OUT : ‘COMMENT (IF ANY) APPROVEDBY =: APPROVED NOT APPROVED : ‘@NGC MANAGER a CARIGALI RESIDENT ENGINEER pare: pate:csP.19 ‘APPENDIX i PAGE 1 OF 1 aii NON-CONFORMANCE WAIVER REQUEST To ‘CARIGALI RESIDENT ENGINEER NCW NO: AMIN, REF.NCR NO. : PROJECT CONTRACT NO. DATE : ‘DESCRIPTION a (WAIVER JUSTIFICATION AFFECTED DOCUMENT (S) INmiaTED BY IssuED BY = PROJECT MANAGER a DATE 10 1 PROJEGT MANAGER ATIN paTE : ‘CARIGALI RESPONSE of | ao ANSWERED BY _ - - = ee [] nor approveo ‘CARIGALI RESIDENT ENGINEER ATEspo APPENDIX IV 3 Page 1 of 1 FABRICATORS Loco NON-CONFORMANCE REPORT REGISTER To 1 CARIGALI RESIDENT ENGINEER REGISTER NO : ATTN. PROJECT CONTRACTNO. —: ie PAGE oF REMARKS / NcR | DATE DESCRIPTION pisposiTion | CLOSE PERSONNEL No. roate | OUT | COMMITTING THE DATE | _NON-CONFORMANCE PREPARED BY : ENDORSED BY = PROJECT MANAGER ‘QA/QC MANAGER:csp.19 APPENOIXV = Page 1 of 1 FABRICATORS Loco WAIVER REQUEST REGISTER To 1 CARIGAL! RESIDENT ENGINEER REGISTER NO : ATIN. 7 PROJECT 7 CONTRACT NO : a PAGE oF WR | DATE DESCRIPTION NCR REMARKS, No. AND JUSTIFICATION REF. PREPARED BY : QA/OC MANAGER, ENDORSED BY = PROJECT MANAGER,