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Management Of Change Procedure

0 25-May-12 First Issue
Rev Date Revision Prepared By Approved By


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TABLE OF CONTENTS
1 INTRODUCTION ............................................................................................................... 3
2 TYPE OF CHANGES ........................................................................................................ 3
3 PROCESS OF MOC .......................................................................................................... 5
4 PROCEDURE .................................................................................................................... 7
5 CHECKLIST ...................................................................................................................... 7
APPENDIX 1 - MANAGEMENT OF CHANGE FORM ......................................................................... 8
APPENDIX 2 - MANAGEMENT OF CHANGE FLOW CHART .......................................................... 10
APPENDIX 3 - MOC SAFETY CHECKLIST GUIDELINES .............................................................. 13



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1 INTRODUCTION
Any facility or operation is subject to continual change. Changes often are made in equipment,
materials and processes to increase productivity or to correct hazards. In some cases, temporary
adaptations, connections, bypasses or other modifications are made to the facility or process.
Although some changes are more critical than others, each modification should be analyzed for
inherent hazards that may result from the change.

To assess the impact of change and to monitor its implementation a policy and procedure for
Management of Change (MOC) is applied to all SUMED managed sites and operations.

No modification shall be made to a plant, equipment, control systems, process conditions, and
operating procedures without authorization from a responsible manager or his delegate.

Proposed modifications must be evaluated for Safety, Health and Environmental impact and a signed
document should be available before the change can be implemented.

The Management of Change Procedure (MOC) is geared to safe process and equipment
modification.

2 TYPE OF CHANGES
2.1 In-Kind/Not In-Kind change
In Kind change is a replacement that satisfies the design specifications.
If it is proposed to replace a piece of equipment with another that is functionally identical and of the
same specifications, the change is In-Kind and does not require an MOC process.

Equipment replacement is considered In-Kind if it meets the following criteria:
Material specifications (dimensions, weight, etc.) are the same.
The service for which the equipment is being used remains unchanged. All process conditions
must remain the same as for those of the original item. Inspection and maintenance
requirements should not change.
The replacement is part of routine maintenance. The In-Kind item is being replaced because it
has a known life span.
Replacing In-Kind equipment that is failing without known cause requires investigation and analysis
of the cause and MOC.

2.2 Small/large change
Large changes usually involve many modifications to system and administrative procedures, and
therefore should receive a full MOC review. However, small changes may not be reviewed with the
same rigor because they can be implemented quickly and do not appear to make a significant impact
on the way a plant operates. MOC reviews, at least through a checklist, should accompany even
small changes.

2.3 Emergency change
Emergency change is one that has to be made very quickly when someone in authority decides that
the dangers of doing nothing are greater than those possibly associated with the proposed change.
An emergency change may be justified for reasons such as the following:
danger to personnel
potential for major equipment damage

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potential for major operational loss
serious environmental impact
serious community complaint
regulatory violation
Every effort must be made to minimize the number of emergency changes, because they bypass the
normal systems for hazard identification. After the fact, every emergency change should be reviewed
by the formal MOC procedure to ensure that no unforeseen problems exist and to ensure the change
is documented and monitored.

2.4 Temporary change
In many instances temporary changes also are emergency changes. They usually are implemented to
keep an operation running while a piece of equipment is repaired or replaced. A temporary change
should have a termination date.
A temporary change of even a short duration should go through at least a Safety Review Checklist
(see Appendix). A new procedure should be written and an emergency response prepared in case the
modification does not work properly.

2.5 Infrequently repeated change
Infrequently repeat changes are those that have occurred at least once before and are repeated at
infrequent intervals. If a change has been carried out before, and if it was properly managed, the
MOC process generally will not need to be repeated. However, it needs to be stated in the MOC
records that this is the case.



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3 PROCESS OF MOC
The process for management of chnage is described as follow:

3.1 Initiation
Generation of an improvement idea or a solution to a problem. The person who makes the initial
request is called the Initiator. Usually the Initiator is a manager, a supervisor or an engineer. However,
all employees and contractors should feel free to propose changes they feel will make the facility
safer, cleaner or more profitable. Participation of all employees is crucial if continual improvements
are to be made.
The proposed change should be discussed within the department team and department supervisor.

Determine if the change is In-Kind/Not-In-Kind. If the decision is made that the change is In-Kind, the
necessary action can be taken without further review or analysis, and the formal Management of
Change process is not pursued.

If proposal is feasible then a formal Management of Change process shall be initiated.

The formal MOC process is initiated by issuing a Request for Change (RFC) form (as per attached
form).

The form shall contain the following information:

Administrative information

The first part of the form provides all the administrative information and the basis for the proposed
change and includes the following:
Change proposal title.
Change category (Technical, Organizational or Administrative or Other).
RFC number to be assigned by change coordinator, location, department, and date.
Type of change whether the change is deemed emergency, permanent or temporary and, if
temporary, its time frame.
Criticality (risk ranking) of the problem.
Change description /description of the problem

The person(s) requesting the change shall clearly define the idea to be implemented or problem to be
solved or outline the opportunity for improved performance. This will be the basis for other evaluations
of the situation. Also where applicable attach associated drawings and P&ID(s).

The Initiator shall explain why he believes action must be taken. This could be for any combination of
the following reasons:
Safety
Environment
Operations
o Increased production
o Increased productivity/efficiency
o Reduced energy consumption/losses
Maintenance

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o Reduced maintenance costs
o Reduced spare parts inventory
Public relations
o Public response
o Other plants in the area
o Other companies using similar technology
Regulatory requirements
Risk vulnerability (refers to those changes that are made to reduce risk, even if an incident has
not yet taken place)
3.2 Detailed evaluation
Evaluation and review of technical, operational, safety, environmental, quality and economical
aspects of the change, the evaluation is performed by a team ( committee) representing different
disciplines according to the nature of the change.

Sector manager or higher authority should nominated the team (committee) and also nominate the
change manager assigned to follow up the change, the change manager may be the team leader or
one of the team members or the initiator.

The team members should have experience and knowledge of the process under review and
knowledge of similar problems that occurred in the past and actions that were taken to solve them.
The Team members should have multidisciplinary technical knowledge in areas related to the
proposed change.

The team shall make an initial assessment of the chnage and the proposed solution and add relevant
information and suggestions based on knowledge and experience.


Having selected the Review Team, the next step for the change manager is to plan the work flow and
establish a schedule that will make sure the evaluation stays on track while also making sure that
people have enough time to think about what is being proposed. Scheduling may require coordination
with other departments or functions.

Once the Reviewers have completed their analyses, a final report shall be issued by the evaluation
team with all of the comments and ideas that have been generated, and summarize and analyze them
and the action that should be proposed. This report will be presented to the management.

Attach to the MOC form all related team minutes of meetings (MOM) and opinion of all involved
parties and also the final report.

3.3 Approval
Before a change can be implemented, it must be formally approved and accepted by the
management.
If more than one solution is presented, the management shall select the most appropriate of those
presented.

3.4 Implementation
Once the change is approved the change implementer(s) with change manager shall develop
implementation plan, purchasing & contracting specification and all other related activities.

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3.5 Information Updating
After implementation and completing outstanding work, implementation team and change manager
shall update all relevant documentation such as product specifications, operating procedures, control
logic documentation, alarm trips schedules, drawings and manuals, pressure test certificates,
cleanliness certificates, training records, etc.

3.6 Training
Ensure that affected employees and contractors are trained on the impact of the change prior to the
restart of the changed process.

3.7 Verification
The change must be verified to ensure that it is in accordance with the change note and all relevant
requirements prior to restarting the Changed Process.

4 PROCEDURE
A typical Management of Change flow chart and RFC (Request For Change) Form are attached.

5 CHECKLIST
The suggested Management of Change checklist should be used in the initial stage to ensure that all
safety aspects are covered and no omissions have been made.


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APPENDIX 1 - MANAGEMENT OF CHANGE FORM


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REQUEST FOR CHANGE
CHANGE PROPOSAL TITLE:
Technical MOC RFC NUMBER:
Organizational MOC

LOCATION:
Administrative MOC

DEPARTMENT:
OTHER:

Emergency Permanent Temporary
From: To:
Risk rank :
Low Medium High

Change Description /Description of problem: use extra sheet if required and associated drawings






Target Outcome / benefits



Proposed by: Date:

Reviews
Functional Area Name Agree / Disagree / NA By initials & dates





Review meeting MOM and signed final report can be attached instead of filling the previous table.

Approval of Change
Name Title Signature Date

In case of rejection Reason for rejection:



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APPENDIX 2 - MANAGEMENT OF CHANGE FLOW CHART

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An Idea to Implement or
solution to a problem is
conceived
Prepare Request For
Change (RFC) form
Initiator /supervisor
Change Evaluation /
Modification / Adaptation

Sector Manager
Is the change within sector
manager Authority?

Sector Manager
Create a review team (committee)
from all involved department.
Assign a change manager and/or
change coordinator

Refer to other /
higher Authority
Document
reason and
archive
Reject
YES
NO
Accept
Issue a report to management
with results and requesting
Approval

Change manager + committee
Approval
Request
NO
1
YES

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Review completed work
Release final ok

Change implementer(s) +
Change Manager
Complete
outstanding work
NO
Information Update
Training
Verification
Change implementer(s) +
Change Manager
Implementation
Implementation plan developed
purchasing & contracting Spec.
etc.

Change implementer(s) + change
manager

YES
NO
Release for
operation
YES

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APPENDIX 3 - MOC SAFETY CHECKLIST GUIDELINES

1. Location - evaluation
Explosion/fire
Noise
Utilities available
Ground stability - foundation
Drainage
neighboring activities
Mobile crane and FLT accessibility
Site traffic control
Third party risks
Hazard quantifications
Soil contamination

2. Equipment selection specifications

Pre-purchase analysis
meeting design criteria and purchase order specifications

3. Material selection specifications
Compatibility with product use
Meeting/exceeding wall thickness and/or desired pressure
cleaned when required
Electrical motors, panels, components and wiring conform to standards
Fitness for intended purpose

4. Codes
do equipment and/or processes comply with applicable codes
Pressure vessel and piping codes
Fire protection
Electrical
Noise
Emissions (air, water)

5. Cleaning procedures
oxygen cleaning
scrapped equipment to be cleaned

6. Welding/ brazing/testing procedures
Special welding requirement with regard to materials, procedures or operating conditions
Welding certificate
Radiographic inspection requirement
brazing material, cryogenic/non cryogenic
Welders qualifications

7. Pressure testing
Approval test procedures available
Hydraulic testing required
Pneumatic testing
Recording of testing done
Pre-tested piping used - certificates yes/no

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Safety distances
Certification by official bodies

8. Pressure protection
Relief valves / bursting disc required due to pressure - temperature
Relief valve in cryogenic piping between isolation points
Relief devices on liquefied gas lines
Over-protection pressure gauges
Pressure protection vacuum system
Under pressure protection system
are pressure protection reliefs and bursting discs suitably sized + safety routed/vented

9. Temperature protection
safeguard personnel from hot/cold surfaces
alarms provided for high/low temperature in process
low temperature embrittlement of materials possible
materials protected against high temperature

10. Electrical system
Electrical system conforms to regulations
Grounding protection
Identification voltage
Main shut-off switch
lock/out capability
Emergency switch
Remote start/stop switches
Electrical isolation considered
Back-up system
overload protection electrical equipment
HV-transformers and cabling adequately isolated
Equipment adequate protected against collision damage

11. Process equipment isolation
Easy access to manual isolation valves
Response time automatic isolation valves sufficient
fail safe isolation requirements met

12. Fire protection
Hydrant available/accessible
Fire hose lengths adequate to reach equipment area
Fire extinguishers
Alarm system at or near equipment area
automatic systems required
fire detectors

13. Equipment guards - protective shields/barriers
Machine guards on rotating equipment
guard rails
Bumper posts
oxygen flash protective shields/barriers
noise reduction

14. Ventilation/air monitoring

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Release of inert/toxic flammable gases possible
Present natural ventilation sufficient
forced ventilation required
TLV values considered
monitoring required (e.g. 02 level)
Local aspiration required

15. Access to control equipment
locate to be maintained easily
install stationary ladder, platform, guardrails

16. Labeling (piping, panels, etc.)
Process identification by labeling
Chemical lines
Process piping
High voltage identification
Flammable storage
Toxic storage

17. Drawing updates
Construction drawing
P&I diagrams
Electrical diagrams
Instrument loop diagrams
Fire protection diagrams

18. Warning signs/warning devices
Mandatory signs in place : atmospheric hazard warning chemical hazard warning flammable
Product warning automatic machine start warning
Back-up (power, instrument air)
Alarms and signalization

19. Environmental emissions/ Permits
noise within limit (industrial residential)
air emission control/testing; required permits available
water discharge
contamination municipal sewer possible contamination canals, etc. possible
permits available
contaminations of soil or groundwater possible
control of combustion equipment (boilers, etc.)
Spillage Control

20. Hazardous waste
waste accumulation and quantity
permits required
storage and disposal procedures
disposal route according law
disposal of non hazardous

21. Product control measures
MSDS for Chemicals available.

22. Access and Egress

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Exit doors not blocked by equipment or piping
equipment room doors equipped with panic bar
area lighting adequate, emergency lighting available
eliminate tripping hazards on exit routes
where required, stairs and/or permanent ladders provided to aid egress
two exits where necessary

23. Tripping hazards
conduits, pipes, valves, etc. not located in walkways
eliminate tripping potential
floor opening covers level with grade
storage does not protrude into walkways

24. Sharp edges - Protruding obstacles
round off sharp edges or give protection
Clearance on overhead pipes etc.
valve handle direction away from persons

25. Equipment lockout capability
electrical
mechanical

26. Emergency shower/eve wash
chemicals used requiring special wash

27. Emergency procedure
emergency plans to be revised
special training required

28. Operating procedure
operating procedure to be revised
additional job training necessary
safety aspects recognized
revision of pre-start and post stop instructions
Workplace risk assessments/Job Safety Analysis available or completed.

29. Contractors
selection
training
co-ordination
supervision
work permits

30. Operators training
training should include but is not limited to:
start-up/shutdown procedure
instrumentation control method
operating temperatures and pressures
alarms and shutdowns
vibration control
electrical isolation procedure
normal log control - i.e. daily temperatures/pressures, etc.
confined space entry procedure

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emergency procedures

31. Personal protection equipment
other than "normal" equipment required
respirators
fire resistant clothing
Chemical protecting garments etc.

32. Lifting devices - Lifting
well balanced eyebolt or similar on equipment
Warning : single point hoisting/lifting might overstress the lifting device, causing rupture
Control weight restrictions and movement.
FLT training
33. Control of constructors
introduction training, incl. asphyxiation- and fire hazards
work permit
control of cranes
product hazards
digging operation/excavations

34. Software Changes
Control loop changes
Addition or deletion of software modules
Restructuring of loops
New control loop
Putting loops on or off.

35. Critical Trips/Interlocks.

36. Spare Parts Identified and ordered.