HMS Directive No.

34 - Management of Change

Prepared by: Livar Haga Revision number: 3 Classification:

Verified by: Kjetil Serigstad Issue date: 2009-12-30 Public/unclassified

Approved by: Anne Myhrvold Next review date: 2010-12-31 Confidential Secret

BP internal

HMS Directive No. 34 - Management of Change [Subtitle/Chapter title] Authority: Engineering Authority Issue date: 2009-12-30

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Document control sheet
Document owner Review period Deviation management Revision history Livar Haga 1 Year Ref. HSE-Directive No. 35

3 02 01 Rev.no

2010 2009 2008 Issue date

HMS Directive No. 34 - Management of Change HMS Directive No. 34 - Management of Change HMS Directive No. 34 - Management of Change Description

Livar Haga L.Haga L.Haga Prepared by

Kjetil Serigstad L.Haga L.Haga Verified by

Anne Myhrvold H.Halvorsen H.Halvorsen Approved by

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Table of content
1 2 3 General..................................................................................................................................................4 Responsibility ........................................................................................................................................6 Processes .............................................................................................................................................8 3.1 Plant/Equipment Change..............................................................................................................8 3.2 Process/System Change ..............................................................................................................9 3.3 People/Organisational Change .....................................................................................................9 4 Demand Analysis ................................................................................................................................10 5 Risk Evaluation....................................................................................................................................11

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HMS Directive No. 34 - Management of Change [Subtitle/Chapter title] Authority: Engineering Authority Issue date: 2009-12-30

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1
Purpose

General
The purpose of this directive is to ensure that all proposed temporary and permanent changes within BPN are systematically evaluated to ensure that the risk related to people, plant or processes are assessed, communicated and controlled to an acceptable level. The mindset is that the responsible person has intent to make a change. This directive and attached forms will be used to identify and document the risks related to the change and any steps necessary to mitigate those risks. If remaining risks are unacceptable, the change must not be implemented. This directive meets the expectations set forth in Getting HSSE Right, Element 7 Management of Change (MoC) and Integrity Management Standard element 7: Management of Change.

Scope

The directive applies to changes within BPN related to plant, process and/or people. All changes will be managed by utilizing a risk based&controlled decision-making process. The level of rigor involved should be commensurate with the level of risk. The directive applies to any temporary or permanent physical alteration that deviates from the design intent, any deviation from the documented safe operating limits or procedures, any change in process outside the design specification, any change in management systems, or a significant change in organization or personnel that leads to a loss or transfer of people with particular knowledge or experience. This directive lists factors for each type of change, to consider whether the change requires a MoC. Consult relevant change with your supervisor. If in doubt whether the change requires MoC contact person with adequate experience/expertise. (I.e. HSSE representatives, lead discipline engineer, technical authority, etc.) The directive applies to all parts of BPN activities - onshore and offshore. The directive and its appendices should be used for generic MOC. In situations for which dedicated processes and procedures have been prepared satisfying the key requirements of MOC, namely robustly documented risk management process, such should be used for managing changes fitting their scope.

References

 The framework regulations The PSA regulations  The Management Regulations The PSA regulations  BP “Getting HSSE right”  BP “Integrity Management Standard”

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     

BP Golden Rules for Safety – “Management of Change” BPN Directive 35 “Processing unwanted events and exemptions” BPN Directive 36 “Risk analysis and acceptance criteria” BPN Projects & Modification Procedure 1.70.005 BPN Control of Temporary Equipment 1.70.007.

Definitions and abbreviations

Golden Rule

BPN “Handover document - Transition of Roles and Responsibilities.”  Acceptance criteria are criteria used to express an acceptable level of risk in activities  ALARP (As Low As Reasonably Practicable) -means that the risk level has been reduced through a documented and systematic process to such a level that it is no longer possible to identify cost-effective measures that can further reduce the risk  Critical work process includes work processes where lack of control of changes may lead to moderate or high risk (combination of consequence and probability) of:  accidents, harm to people and/or damage to the environment  economic loss, and/or  impairment of BP's reputation  HAZID (HAZard IDentification) is a method used to identify potential elements of risk  HSSE (Health, Safety, Security and the Environment) The term also includes emergency preparedness, working environment and security  MoC implies a documented Management of Change process as described in this directive.  Plant  Is in this directive related to plant, facilities and equipment such as buildings, structure, piping, safety equipment, escape routes, tie-ins, by-passes, etc.  Process  Is in this directive related to work processes or systems such as procedures, software, conditions or requirements (work-flow)  People  Is in this directive related to organizational change processes  Risk - Expression of the combination of probability and consequences of one or more accident/incidents happening  Risk analysis - An analysis covering systematic mapping and description of risk to personnel, the environment and material assets. Work arising from temporary and permanent changes to organization, personnel, systems, process, procedures, equipment, products, materials or substances, and laws and regulations cannot proceed unless a Management of Change process is completed, where applicable, to include:  a risk assessment conducted by all impacted by the change  development of a work plan that clearly specifies the timescale for the change

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Identify need for MoC

and any control measures to be implemented regarding:  equipment, facilities and process  operations, maintenance, inspection procedures  training, personnel and communication  documentation authorization of the work plan by the responsible person(s) through completion Evaluation of the need for MoC should be done in all phases from the planning stage and all the way through the actual execution. It is a duty of everyone involved in the planning, approval and execution of work to evaluate the need for MoC. A generic MoC process is required when change introduce risk factors that are not sufficiently identified, documented and controlled through other relevant procedures/directives, exemplified in chapter 3. E.g. Safe Job Analysis (Directive #11), Projects & Modification (Procedure 1.70.005) etc. Detailed descriptions of changes requiring and not requiring documented MoC process are specified in chapter 3 (Plant, Process and People). For changes repeated frequently it may be worthwhile to establish described work processes which are reused and robustly documented. This will probably be more effective than to use this generic method each time such change is to be managed. Terms Of Reference (TOR) Plant / equipment change checklist Process / system change checklist People / organisation change checklist Risk assessment table MOC Report MOC Poster The following should be registered in Traction:  Terms of Reference MoC Report with attachments 

Appendices

Records

2

Responsibility

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Responsibility table

Type of Change People - Organization Process - Systems or Directives Plant – Equipment Chemicals/Substance/Materials Codes and Regulatory Requirements Emergency Preparedness Logistics and Contracts

Accountability/ Approver Manager of the new organization or Line supervisor of the position affected Work Process owner Equipment owner (OIM, area responsible, , etc.) Appropriate Plant, product or Process owner (incl. Directive owner, Industrial hygienist). Directive Owner, Technical Requirements Authority (TA) or HSSE Manager OIM, Emergency Controller and/or Security & Emergency Advisor Logistics- and PSCM Manager

Managers

HSSE Manager

Client/Approver

MoC leader

have accountability for:  knowing the legal compliance requirements related to the operations and assets for which they are responsible  and for ensuring that changes in legal and regulatory requirements affecting their accountabilities are monitored, communicated and implemented effectively. is responsible for  verifying that the risk evaluations carried out are in accordance with BP's expectations and that adequate risk-reducing measures have been identified  ensuring management systems are in place for monitoring changes to health, safety, security and environmental laws and regulations, communicating the changes, assessing the impact assuring that implementation plans and monitoring methods are put in place to assure compliance. is the person requesting and approving the final MoC.  shall ensure that the directive is followed and that the MoC team is familiar with the directive.  shall ensure that identified measures are implemented prior to making the actual change. The client shall assess whether the MoC shall be led by an independent party. is responsible for  Establishing a MoC team which will identify risks and risk-reducing measures.  Prepare MoC report and record actions in Traction. The person who is appointed to plan and lead a MoC process shall have the relevant background from similar analyses, e.g. HAZOP, HAZID, etc.

Engineering Authority MoC team's HSSE representative

shall ensure that logged MoC’s are reviewed annually to assess the cumulative impact of all changes. is responsible for 

making sure that the risk evaluation reflects BP's requirements and HSSE expectations

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3
3.1
Definition

Processes
Plant/Equipment Change
 Plant/Equipment change process may include any changes in the following, but not limited to  Change to the platform/building structure  Change in equipment location requiring changes in piping or utilities  Changes in operating conditions outside normal operating or design envelopes, such as pressures, temperatures, etc.  Change to any safety equipment, safety related device, safety system, escape route or hazardous area classification  Changes which could affect the capacity or design basis  Changes in maintenance, inspection or testing  Equipment modification (e.g., alarms, instrumentation, etc.)  Addition of equipment that may contribute to greater relief requirements  New projects that involve tie-ins or equipment modification on existing units  Use of new technology, new materials, new equipment  Change to hired or temporary equipment  Bypass connections around equipment that is normally in service unless the change is covered in a normal operating procedure  Change to chemical inventory and chemical use  Deferral of planned major maintenance and modification activity Changes for which other robustly documented risk managing processes, procedures/directives exist should be managed using this when the situation fit the scope (e.g. modification procedures, risk analysis methods, SJA, work processes integrated in Computerized Maintenance Management System (CMMS), Maint Web, Critical Protective System Register (CPSR) process, etc.).  In general, the following changes would not need a documented MoC:  Changes like-for-like in kind (equipment, consumables, or parts)  New equipment that has no impact on existing operations  Routine maintenance of equipment  Change that is consistent with the design parameters.  Minor changes that do not affect HSE, personnel, or customers. (e.g. a change in supplier for materials without HSE-impact ).

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The effects of the change

 Based on a detailed description of the plant/equipment changes the MoC leader will, in cooperation with relevant skilled personnel, consider the effects by using Appendix 2 Checklist – Plant/equipment changes  Check against other checklists attached for relevance.  If the change will cause deviation from requirements, either internal or external, BPN Directive 35 “Processing unwanted events and exemptions” must be followed.

3.2
Definition

Process/System Change
 Workprocess/System change process may include any changes in the following, but not limited to  Changes in legal and regulatory requirements, technical codes, standards with safety, health and environmental effects. o New legislation o Changes to existing legislation o Legislation compliance issues raised by regulatory body inspection and progress the update of outstanding inspection-related issues.  Change in procedure, sequence, or change in steps  Use of new or upgraded software, etc.  Changes in emergency preparedness and response Changes for which other robustly documented risk managing processes, procedures/directives exist should be managed using this when the situation fit the scope (e.g. risk analysis methods, SJA, work processes integrated in Computerized Maintenance Management System (CMMS), Maint- Web process, etc.).  In general, the following changes would not need a documented MoC:  Minor changes that do not affect HSE, personnel, or customers  Based on a detailed description of the process/system changes the MoC leader will, in cooperation with relevant skilled personnel, consider the effects by using Appendix 3 Checklist – Process/system changes.  Check against other checklists attached for relevance.  If the change will cause deviation from requirements, either internal or external, BPN Directive 31 “Exemptions” must be followed.

The effects of the change

3.3
Definition

People/Organisational Change
 People/Organisational change process includes any changes in the relationship between work tasks and available resources such as  An established job type is removed from the

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HMS Directive No. 34 - Management of Change [Subtitle/Chapter title] Authority: Engineering Authority Issue date: 2009-12-30

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organization, or a new job type is added Changes in the organization structure and/or reporting relations  Changes in competence requirements for identified roles  Changes in activity level (changes in work descriptions for the existing organization)  Change of major supplier, including relevant subcontractors (changes in the supply chain)  Changes to logistics such as significant change in transportation route, loading/ discharge location.  Individuals are required to take on significantly new responsibilities demanding skills and competencies unconnected with those required previously  Individuals relinquish responsibilities for tasks related to HSSE compliance or other critical business processes without those tasks being reallocated  Changes to outsource a function that was previously performed by BPN personnel Changes for which other robustly documented risk managing processes, procedures/directives exist should be managed using this when the situation fit the scope (e.g. risk analysis methods, SJA, “Handover Document - Transition of Roles and Responsibilities” available via HR’s intranetpage under “Forms”, “Handover”, etc.).  In general, the following changes would not need a documented MoC:  Change in a contractor providing an existing low risk service, subject to normal pre-qualification.  Minor changes that do not affect HSE, personnel, or customers  The effects of the change  Based on a detailed description of the organisational changes the MoC leader will, in cooperation with relevant skilled personnel, consider the effects by using Appendix 4 Checklist - Organisational changes  Check against other checklists attached for relevance.  If the change will cause deviation from requirements, either internal or external, BPN Directive 31 “Exemptions” must be followed.

4
Introduction

Demand Analysis
In connection with management of change processes, the MoC leader shall make sure that the changes are described in detail in order to  ensure a sufficient evaluation basis  ensure that the analysis basis is documented so that the relation between the analysis basis and the results (measures) are traceable The descriptions should describe the current situation and the desired future situation.

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Terms of reference

The individual who is proposing the change shall complete the following sections of the Terms of Reference for the Management of Change (Appendix 1.)  Name and the date.  The description of the change.  The purpose of the change.  Type and Duration of change (permanent/temporary)  Target date for the change  MoC team  Approver The approver is the individual who will ultimately approve the relevant change.  In emergency situation, the person in charge is authorized to execute changes to maintain the safety of the facility without following the fully documented MOC directive. After the emergency situation is cleared, properly documented MOC processes should be handled.  If the change is intended to be temporary, a time limit must be set on when the original design intent (ie equipment, operational conditions, organizational structure, etc) will be restored, and the management system (Traction) should be used to ensure that the time limit and any other conditions are not violated.(Normally less than 6 months).  Extension of temporary change shall be reviewed and approved by the next higher level of management before pre-authorized time-limit expire.  Special precautions to maintain safe operations while a temporary change is in effect shall be periodically reviewed for effectiveness.  Facilities are brought back to normal or permanent mode before a temporary MOC is closed.  When evaluating the impact on critical work processes, the main focus must be on identifying changes which may lead to  Related activities being completely left out due to lack of resources or lack of awareness of the importance of the activity  Related activities being performed, but with reduced quality. This may be due to inexperienced personnel performing the work or taking "shortcuts" as a result of imbalance between the workload and available resources  Losses which may occur because personnel perform activities for which they are not sufficiently skilled, thus leading to the work being done incorrectly The evaluation of critical work processes must also include indirect effects. Engineering Authority shall ensure that each organizational unit reviews the MoC’s logged in Traction annually or more frequently if appropriate, to assess the cumulative impact of all changes.

Duration of change

Main focus

Creeping changes

5

Risk Evaluation

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Introduction

Identifying elements of risk

 Risk evaluations of MOC processes shall be done by a MoC team.  The MoC team ought to consist of  representatives of the critical work processes identified as being affected by the change  personnel with HSSE competence  employees' elected representative and/or safety delegate (shall be invited.)  In selecting a team, the following mix of attributes must be considered:  Adequate technical expertise/experience.  Adequate understanding of the risks  Adequate organizational and business understanding.  Arrangements for employee contribution  This team will propose measures, which limit any risks to an acceptable level in accordance with BPN ALARP principle (ref. Directive 36 “Risk analysis and acceptance criteria).  The MoC team will identify potential elements of risk using  HAZID , etc or  other systematic methods which stimulate creativity, i.e. which gives the participants the opportunity to identify circumstances that are outside their own scope of experience by using appropriate checklist (appendix 2-5) and other tools available for Hazard recognition  The team should consult as widely as is necessary to allow them to come to an informed decision on the risks associated with the change. Affected persons including contractors, sub-contractors, vendors, and customers may be consulted as necessary.  When identifying potential elements of risk, a risk evaluation needs to be carried out in which the elements are ranked into the following categories:  High potential which means that risk-reducing measures need to be implemented  Medium potential which means that risk-reducing measures can be implemented if deemed necessary based on a cost/benefit evaluation  Low potential which means that no further measures are deemed necessary  The risk of an unintended incident occurring can be estimated by means of BPN risk matrix, available through directive 35 “Unwanted Events”, or by using the more advanced & detailed methodologies and acceptance criteria in HSSE Directive no. 36, Risk Analysis and Acceptance Criteria.

Identification of risk-reducing measures

 Based on a systematic evaluation of the elements of risk involved in an management of change process, the MoC team is to identify  probability-reducing measures intended to prevent an incident from occurring and/or

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consequence-reducing measures intended to reduce the consequences of an incident that has occurred  Of these two, probability-reducing measures are to be prioritized Based on the risk and risk reducing measures the MoC team shall confirm whether or not the change should be implemented.  The MoC team shall prepare a plan for implementation of the measures. The plan is to propose deadlines and the person responsible for each of the measures  This should include how the change is to be effectively communicated to the workforce and other affected persons (such as contractors, sub-contractors, customers, and vendors).  Special competence requirements must also be considered and completed prior to implementation of the changes.  The MoC approver shall assess whether any proposed change requires a prestart up review to confirm that the MoC system has been correctly applied, that the change is safe to commission and that it meets applicable legal obligations.  Records, procedures and drawings shall be updated to reflect the MoC.  MoC systems shall be designed to ensure that all actions are closed out and achieves the necessary effect. The results of the review should be well documented and retained for future verification. This is important even if the review did not require any additional action to be taken.  MoC report, using template in appendix 6, shall be developed describing the following sections:  Participants  Risk assessment method  Accept criteria  Actions: summary and number of identified actions/barriers.  Assumptions: number of established assumptions.  Drawings: summary of drawings utilized.  Documents: summary of documentation utilized.  References  The approver shall sign completed MoC report to indicate acceptance or nonacceptance of the review findings.  The MoC leader must ensure  documentation of the risk evaluation in accordance with Appendix 5 Risk Assessment Table  documentation of measures identified as part of the risk evaluation in Tr@ction The MoC report together with measures identified shall be recorded in Traction under “Other events”, Event type: “MoC”. The Traction shall be recorded under the specific asset or if of general nature under BUR (Business Unit Resources). Traction list of Management of Change processes shall be reviewed at least annually to assess cumulative impact of all changes. The use of MoC-system shall be assessed by processes which:

Implementation of measures

Documentation

Logged MoC’s

Performance management

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1. Confirm the change achieve its original intent 2. Confirm the changes are executed correctly 3. Confirm the actions are closed 4. EA or delegated audit MOC-processes at least annually

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Flow chart:
Client identifying need for change Describe the change The change does not require a MoC when:  the change does not introduce any risk factors.  the change is covered in chapter 3 stating MoC not required.

Client and supervisor, and person with adequate experience/expertise

Does the change require a Management of Change process?


no Should you be in doubt whether the change requires MoC, please contact a person with adequate experience/ expertise (directive owner, HSE department, teamleaders etc.)

yes Client Complete Terms of Reference for MOC or initiate other robustly documented risk management process.

MoC team

Identify potential elements of risk using of the change by using appropriate checklist

MoC team

Identify probabilityreducing measures and/or consequencereducing measures

Are the reducing measures sufficient?

no

yes MoC team Establish plan for implementation of actions identified

MoC team

Complete MoC Report

MoC approver

Follow up actions in Traction

MoC approver

Verify implemented riskreducing measures.

Engineering Auth (EA) &/ HSSE Manager

Review the management of changes within their function annually to assess the cumulative impact of all changes.

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