Professional Documents
Culture Documents
List of recipients:
5. Chief HSE
Contents
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:
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.
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
1.4 SCOPE
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:
ONGC installations are designed and constructed based on relevant national and international
regulations, standards, codes and guidelines like
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. 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.
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.
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
3 TYPES OF 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.
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.
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.
The OIM shall set up a Change Management Team consisting of all Sectional Incharge and the
HSE Manager to-
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.
Change management team carries out risk assessment/ranking using tools like HAZID, HAZOP,
Risk Ranking Matrix.
Change management team suggests risk mitigation measures to bring down identified risks to
ALARP level.
Change shall be approved by appropriate authority depending upon the type of change.
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.
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.
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
Table-2 Drilling
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.
Head HSE shall carry out periodical review of all incidents and accidents that occurred in
ONGC Assets to collate statistical data to determine –
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.
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.
NO, NOT The complete negation No part of the intention is achieved and
OR of design intention nothing else happens
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
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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Management of Change
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.
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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Management of Change
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
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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Management of Change
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.
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.
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;
8 IMPLEMENTATION
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:
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.
Change Management Team shall prepare a project schedule with milestones for
implementation of the change. Copies of project schedule shall be made available to:
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.
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
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.
9.4.2 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.
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Management of Change
Annex 1 Flowcharts
Figure 1: Change of Process / procedure / parameter / surface facility
Review by OIM
Is change
acceptable? No
Yes
Feedback Conduct detailed
Yes
Risk Analysis
Is the change
No major? ChMT Assessment Revise
Execution at site
SAM/ No
Rig Manager Review
Surface
Manager/Operation
Manager Approval
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Management of Change
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
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
Name of Installation
Date of Initiation
Reason for change
Detailed description of change
Risk Date
Assessment
/ /
conducted
Approval
3. Description of Change:
Process Conditions
1. Temperature
2. Pressure
3. Flow
4. Composition
5. Toxicity
6. Flash point
7. Flash point
8. Operation
9. Method Start up
11. Shutdown
Comment:
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Management of Change
Procedures
26. Noise
27. Vibrations
Hardware Design
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
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Management of Change
37.
Trips & Alarms
38.
Access
39.
Rate of corrosion
40. Rate of erosion
(Tick as applicable)
E. HAZOP
Assessment
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Management of Change
(Tick as applicable)
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?
Comment:
Assessment
Signature................................... Date.................................
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Management of Change
(Tick as applicable)
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
Assessment
Signature................................... Date.................................
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Management of Change
(Tick as applicable)
Assessment
HSE Manager/ Elect I/C Mech I/C Sub Sea I/C CE(Marine) Master
Page 38
Management of Change
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)
NOTES