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SUMED R B PETROLEUM PIPELINES COMP NY
Management Of hange 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 forinherent hazards that may result from the change.
To assess the impact of change and to monitor its implementation a policy and procedure forManagement 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, andoperating procedures without authorization from a responsible manager or his delegate.
Proposed modifications must be evaluated for Safety, Health and Environmental impact and a signeddocument should be available before the change can be implemented.
The Management of Change Procedure (MOC) is geared to safe process and equipmentmodification.
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 thesame 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 analysisof the cause and MOC.
2.2 Small/large change
Large changes usually involve many modifications to system and administrative procedures, andtherefore should receive a full MOC review. However, small changes may not be reviewed with thesame rigor because they can be implemented quickly and do not appear to make a significant impacton the way a plant operates. MOC reviews, at least through a checklist, should accompany evensmall changes.
2.3 Emergency change
Emergency change is one that has to be made very quickly when someone in authority decides thatthe 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 thenormal systems for hazard identification. After the fact, every emergency change should be reviewedby the formal MOC procedure to ensure that no unforeseen problems exist and to ensure the changeis documented and monitored.
2.4 Temporary change
In many instances temporary changes also are emergency changes. They usually are implemented tokeep an operation running while a piece of equipment is repaired or replaced. A temporary changeshould 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 themodification does not work properly.
2.5 Infrequently repeated change
Infrequently repeat changes are those that have occurred at least once before and are repeated atinfrequent intervals. If a change has been carried out before, and if it was properly managed, theMOC process generally will not need to be repeated. However, it needs to be stated in the MOCrecords 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 initialrequest 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 facilitysafer, cleaner or more profitable. Participation of all employees is crucial if continual improvementsare 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, thenecessary action can be taken without further review or analysis, and the formal Management ofChange 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 attachedform).
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 besolved or outline the opportunity for improved performance. This will be the basis for other evaluationsof 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 ofthe following reasons:
Safety
Environment
Operations
o Increased production
o Increased productivity/efficiencyo 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 differentdisciplines according to the nature of the change.
Sector manager or higher authority should nominated the team (committee) and also nominate thechange manager assigned to follow up the change, the change manager may be the team leader orone of the team members or the initiator.
The team members should have experience and knowledge of the process under review andknowledge 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 theproposed change.
The team shall make an initial assessment of the chnage and the proposed solution and add relevantinformation 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 andestablish a schedule that will make sure the evaluation stays on track while also making sure thatpeople have enough time to think about what is being proposed. Scheduling may require coordinationwith other departments or functions.
Once the Reviewers have completed their analyses, a final report shall be issued by the evaluationteam with all of the comments and ideas that have been generated, and summarize and analyze themand 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 involvedparties and also the final report.
3.3 Approval
Before a change can be implemented, it must be formally approved and accepted by themanagement.If more than one solution is presented, the management shall select the most appropriate of thosepresented.
3.4 Implementation
Once the change is approved the change implementer(s) with change manager shall developimplementation 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 managershall 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 therestart 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 relevantrequirements 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 allsafety 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 CHANGECHANGE 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 ChangeName 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 orsolution to a problem is
conceived
Prepare Request ForChange (RFC) form
Initiator /supervisor
Change Evaluation /
Modification / Adaptation
Sector Manager
Is the change within sectormanager Authority?
Sector Manager
Create a review team (committee)from all involved department.
Assign a change manager and/orchange coordinator
Refer to other /higher Authority
Documentreason and
archive
Reject
YES
NO
Accept
Issue a report to managementwith results and requesting
Approval
Change manager + committee
ApprovalRequest
NO
1YES
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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 training33. 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.