PARKER DRILLING

NEW ZEALAND OPERATIONS

PROCEDURE No. 001

MANAGEMENT OF CHANGE
(Deviation Control)
DRAFT 24/03/03
 CONTENTS

1.0 Introduction
2.0 Deviation Procedure
3.0 Recurrent Deviation Requests

LIST OF ABBREVIATIONS

PDNZ: Parker Drilling New Zealand

NZOP: New Zealand Operations Procedure
HAZID: Hazard Identification
HAZOP: Hazard and Operability Study
HSE: Health, Safety, and Environment
HSE – MS: Health, Safety, and Environmental Management System
HSE- PP: Health, Safety and Environment Protection Program
PTW: Permit to Work
 Deviation Control NZOP 002

1.0 Introduction and Scope

This procedure is part of a suite of procedures that underpins the Parker Drilling (New
Zealand Operations) Health, Safety, and Environmental Management System (HSE-MS)
It is to be read in conjunction with the Health Safety and Environmental Protection
Program (HSE-PP) Section A. pages 15 –17.

This procedure covers the process that PDNZ has implemented in order to handle
requests to deviations (or relaxations) from HSE requirements.

This procedure applies to PDNZ and Contractors and to onshore and offshore work
locations.

2.0 Deviation Procedure

The deviation procedure is shown in flowchart form in Figure 1.0. The steps in the
flowchart are described in Table 1.0.

Note the procedure assumes that the deviations being considered are one-off situations.
Note also that the level of documentation, justification and authorization increase with
the potential HSE severity of the deviation. This is described in Table 1.0.

4.0 Recurrent Deviation Requests

Where deviations from a particular requirement, are requested frequently, for justifiable
operational reasons, and where the alternative/modified controls are adequate to manage
the associated hazards, then the logic underpinning the original requirement should be
challenged. If the original requirement is found to be overly onerous, outmoded or no
longer applicable, for whatever reason, then the requirement should be modified to reflect
the practice usually adopted in the deviated situation. However, if the original
requirement remains valid, then the current operating mode, equipment used, work
practices employed, etc. should be changed, in order to remove the need to generate
recurrent deviation requests.
 FIGURE 1.0: DEVIATION FLOW CHART

Confirm that a
Deviation is
required
(1)

Determine the worst case Why was the original

potential consequences. In requirement put in place
terms of harm to People (i.e. what consequences
Environment, Reputation , or was it meant to
Assets prevent?)
(3) (2)

Formulate modified or
alternative controls.
(4)

Are the modified controls Yes

adequate to prevent the
consequences being
(realized”?
(5)

No Can the absence of the

original controls, or the
Formulate additional Yes presence of new ones,
controls lead to a new set of
(6) consequences?
(7)

No
Authorize the deviation, in
accordance with table 3
Authorization Matrix
(8)

Implement the
agreed controls
(9)

Undertake the
operation.
(10)
 TABLE 1.0: FLOWCHART SUPPORT NARRATIVE
Flowchart Description of Flowchart activity
Symbol No.
1 Deviations from clearly stated requirements in procedures or manuals should only be
made in exceptional and justifiable circumstances. The person requesting the change
(“The Requester”) should satisfy his (or her) self that a deviation really needs to be made
before commencing the deviation request process.
2 The first question that the Requester needs to ask is: “Why is the original requirement
was put into place – i.e. what undesirable consequence is it meant to prevent?” In most
cases this should be obvious, but if any doubt exists the requester should consult with his
immediate supervisor.
3 Once the Requester understands the reason for the requirement, then he should be able to
determine the worst-case consequences, with reference to table 2.0 (see below).
4 The Requester needs to formulate modified or alternative methods and controls to those
originally required.
5&6 The Requester needs to assess whether the modified or alternative controls are adequate
to prevent the worst-case consequences being “realized”. There are various assessment
methods available, ranging from the very straightforward to the very complex. Typical
techniques include Job Safety Analysis, HAZOP, Bow-Tie analysis, Quantitative Risk
Assessment, etc. In general, the higher consequence the deviation can result in the more
sophisticated the method needs to be. The Requester should seek specialist advice, on
these techniques, as necessary. Where the method and controls are deemed unsatisfactory
then the Requester needs to formulate further/better methods and controls, until a
satisfactory solution is achieved. If this is not possible then the request for deviation
cannot be justified.
7 After the Requester has satisfied himself that the modified or alternative methods and
controls are adequate to prevent the worst case consequences being “realized”, he then
needs to ensure that the methods and controls have not introduced a new set of
consequences not envisaged by the original requirements. This involves an iterative
process like that described for steps 5&6. If this is not possible then the request for
deviation cannot be justified.
8 Once the Requester is satisfied that the deviation request is robust (i.e. satisfactorily
completing steps 1-7, above. He needs to have the deviation authorized. The level of
authorization and justification increases commensurate with the worst-case consequences
– refer to the Authorization Matrix (Table 3.0).
9&10 Once authorization has been given, the agreed methods and controls should be
implemented and the operation conducted in accordance with the relevant procedures.

TABLE 2.0: POTENTIAL CONSEQUNCE RATING

Consequence People Environment Reputation Assets
Rating (P) (E) (R) (A)
0 No Injury No Effect No Impact No Damage
1 Slight Injury Slight Effect Slight Impact Slight Damage
2 Minor Injury Minor Effect Limited Impact Minor Damage
3 Major Injury Localized Effect Considerable Impact Localized Damage
4 Single Fatality Major Effect National Impact Major Damage
5 Multiple Fatality Massive Effect International Impact Extensive Damage
 TABLE 3.0: DEVAITION DOCUMENTAION & AUTHORIZATION
Rating Approval Level Consult As Necessary Documentation/Formalization Controls
Verification
0,1 Rig Manager Operator Co Man, HSE JSA, PTW. Procedures. Yes – By rig
Rep. Work Instructions. Morning mgr ONLY
Report.
2 Rig Manager Operator co.Man, HSE HSE Meeting.
Rep. Toolbox Talk Notes
E-mail. Fax
3&4 Rig Manager and Field Operations Manager Deviation Request Form – See Yes –
Supt. HSE Department Figure 2.0 formal,
PDNZ Client Contract documented
Holder
5 Regional Manager Corporate HSE Deviation Request Form – See Yes –
Department. PD Ops Figure 2.0 formal,
General Manager documented

TABLE 4.0: RESONABLY FORESEEABLE DEVIATIONS IN ROUTINE OPERTIONS

DEVIATION RATING CONTROLS AUTHORIZATION

Lifts of equipment where rig lifting
certification has expired and has to be
returned to New Plymouth for re-
certification
2 The controls are operation specific and need to be Lifts of equipment where
determined on a case by case basis. rig lifting certification has
expired and has to be
returned to New
Plymouth for re-
certification
 FIGURE 2.0: PROFORMA PDNZ DEVAITION REQUEST

PDNZ DEVIATION FROM REQUIREMENTS FORM

Deviation Risk Rating: Risk Assessment Attached?
No.
Procedural Documentation Amended?

Date: Deviation from Document (Title/Number/Revision)

Description of Deviation:

Justification for Deviation:

REQUESTED Name: Signature:

Date: Position Company:

CONSULTED: Name: Signature:

Date: Position Company:

APPROVAL Name: Signature:

Date: Position: Company: