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PCSB Production Operations

Management of Change (MOC)


Briefing to Key Resources
for MOC Implementation
22 September 2005

2005 PETRONAS CARIGALI SDN BHD (PCSB)


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Presentation Outline

INTRODUCTION

INTRODUCTION
Objective and Expectation
Objective
To brief the audience on the new MOC Procedure for
Production Operations, roles and responsibilities and
highlight the status of its implementation
Expectation
Audience are aware of the procedure requirements,
their R&R and the overall status with regards to the
rollout and implementation.

INTRODUCTION TO MOC
OVERVIEW

Change is inevitable and necessary.

Change is desirable.

However, uncontrolled change can introduce new


risks, invalidate previous work, and lead to
undesirable results.

Why we need MOC?

PCSB management of change practices are governed by


PCSBs HSEMS - Element 4 - Management of Change
Cover changes in people, plant, processes and procedures with a
view to prevent any adverse HSE consequences
including contractors and third parties associated with Company
activities.

BACKGROUND

Why we need a new MOC?


AIMS Phase 1 Audit (Mar Jul 04) findings
PMO

MOC process must be improved to assess and manage risks. It


must be fully used for all required changes.

SKO

The MOC process should be improved to assess and manage


risks. It should be fully used for all required changes, including
overdue tasks, managing deficiencies and temporary changes.

SBO

Lack of a universal MOC procedure which covers the full


range of changes from temporary modifications to capital
improvement projects.

DD

MOC process not assessed, Post Team Finding MOC in place.

XD

MOC process not assessed, Post Team Finding MOC under


Review.
7

Why we need a new MOC?


1

OPU left to develop own MOC procedure that does not always meet world class standards (No
one common PCSB MOC procedure)

Generally low understanding and poor practice of the MOC system

Roles & Responsibilities in MOC procedure not consistently defined across PCSB

Technical Authority roles not clearly defined, more link to LOA levels

Risk assessment management system not in place.

Not clear on risk assessment methods and applications. This is especially true for scenario based
risk assessment process

Monitoring/tracking of MOC needs to be improved

Management reporting lacking

Keeping of records needs to be improved

10

Not aware when to use or not use the MOC procedure

11

Independency questionable due to lack of structured and transparent MOC system

12

Final approval authority not defined

13

MOCs triggered revisions of stds/specs/procedures not obvious

14

Too many other change procedure e.g. TAM, COPM, OSC, WRW,etc.
8

MOC Development
Mandate from CMC

Close the assessment gaps on MOC system and


practices

Develop a Corporate MOC System that covers


the entire lifecycle of an Asset

Develop a common procedure for Production


Operations

MOC Fundamental Principles

All Changes shall be fully

a) Evaluated
b) Reviewed
c) Approved
at a level commensurate with the risk involved.
Based on risk involved, actions shall be taken to
control and eliminate potential risk to As Low As
Reasonably Practicable (ALARP)
10

MOC Development Approach

MOC Procedure was developed based on


collection of practices within PETRONAS OPUs,
Partners and other International Oil & Gas
Operators.
Reviewed, validated and tested by PCSB end
users and stakeholders

11

HSE Document Hierarchy & Custodian

Level 1

HSE-Policy

Level 2

Custodian
MD

Level 3

e
re
Th i e r e n t
T m hy
cu rc t
Do iera cep
H on
C

HSE-MS
Manual
Supplement
HSE-MS
MOC System

TA Framework

DD
MOC

XD
MOC

Others
MOC

Prod Oprns
MOC Procedure
Manual

Proposed
Custodian:
CHSE Manager
Custodian:
DOM

12

SCHEDULE
Milestones Achieved

Sept 04
Jan 05
Mar 05
Apr 05
Apr 05
May 05
Jun 05
Jun 05
Aug 05
Aug 05

Team set up
Completed draft MOC System and procedure manual
Feedback sessions with stakeholders (PMO, SBO, SKO)
Procedure Manual Validation Workshop
Presentation to PCSB Petroleum Asset Mgmt Forum
Finalisation of the MOC Procedure Manual
Finalisation of Tech Authority Framework Document
Completed MOC Procedure and Training Pkg validation
Approval of MOC Procedure and Rollout Plan by AIMSC
Launching of MOC Procedure during Operation Forum

13

SCHEDULE
Rollout Plan

Aug 05
Aug 05
Aug Dec 05
Sep Dec 05
Oct 05

Launching of new MOC Procedure


Train the trainers by INSTEPl
Level 1 training by INSTEP and Line Trainers
Level 2 and Level 3 training by INSTEP/ Trainers
Proposed Target for MOC implementation at PMO

14

MOC PROCEDURE COVERAGE

15

MOC Procedure Coverage


Purpose & Scope of MOC
Purpose:
To describe the MOC process of identifying, evaluating and managing
risks associated with the change.
Change is defined as any deviation or modification with potential
integrity implication to Facilities , or previously approved documents,
plans, procedures, processes and critical positions.
Scope :
All changes are subject to the principles established by the HSEMS
Management of Change.
The MOC Procedure Manual is addressing specific MOC requirement
and describes the principles and procedures by which change can be
managed in PCSB domestic production operation, supporting
maintenance and technical services.

16

MOC Procedure Coverage


Key Resources for MOC Implementation

Procedure custodian
Senior management personnel
Platform and facility OIM & other line
management
Functional technical authorities
Procedure administrator
MOC Coordinator
MOC Panel

17

MOC Procedure Coverage


PROCEDURE CUSTODIAN

Head of Domestic Operations (DOM)


Ensure proper functioning of MOC procedure
Ensure MOC processes rigidly followed by line
management across domestic operations

18

MOC Procedure Coverage


PROCEDURE ADMINISTRATOR

An assigned XTS4 Section Head


Administer the procedure
Endorse changes to the MOC procedures
Maintain database of all MOC change reports forwarded by
MOCC
Verify MOC rigidly followed
Ensure lesson learned are shared via SKILL
Generate monthly MOC reports & KPIs

19

MOC Procedure Coverage


MOC COORDINATORS (MOCC)

Prepare and maintain detailed procedures used by the functional


group (Asset team/Department)

Maintaining the functional groups MOC log

Tracking the progress of MOCs within the functional group

Preparing change reports for submission to the Procedure


Administrator

20

MOC Procedure Coverage


Technical Authority

Competent personnel Trained for Risk Assessment


Provide recommendations to the Approving Authorities to approve
or reject change requests :
affecting the technical integrity of the facility
which deviate from PTS, PCSB guidelines or
mandatory practices in the expertise areas.

Identify mitigations measures to reduce the risk level to


ALARP

21

MGMT ROLES AND RESPONSIBILITIES


APPROVING AUTHORITY

Authorities who are accountable for approving


changes at appropriate risks level pertaining to
design, technical and operation integrity.

Term Of Reference
(Table 2.3 Approvals Required for Production
Operations MOC Procedure)

22

MGMT ROLES AND RESPONSIBILITIES

MOC Panel Members


Chairman : Technical Services Manager
Members:
(i) Safety manager (Alternate Chairman)
(ii) Area Operations Manager
(iii) FIP Coordinator.
(v) MOC Coordinator
(vi) Head of Surface Engineering
(vii) Head of Subsurface Engineering
(viii) Head of Specialist Maintenance
(vii) Appointed Technical Authorities and Discipline Engineers (As and when required).
Secretary :
MOC Administrator(TS4)
Quorum
The following composition made up the quorum of the MOC panel:
(i) Chairman or Alternate Chairman.
(ii) Relevant Area Operations Manager / Area Head of Operations.
(iii) Representative from Safety.
(iv) FIP Coordinator.
(v) MOC Administrator

Frequency Of Meeting : Monthly.


23

MGMT ROLES AND RESPONSIBILITIES


MOC PANEL TERM OF REFERENCE
Objectives:

To steward the Production Operations


Management Of Change Procedure
implementation and ensure that change is
properly managed in accordance with the
requirement of the procedure.

To approve / reject the proposed FIP


recommendations in line with FIP procedure
and ensure HSE / economics are justified.
24

MOC Procedure Coverage


Nature of Change
Five main categories:

Equipment / Hardware

Procedural

Chemical / Hazardous materials

Operating parameters

Critical positions

25

MOC Procedure Coverage


Equipment / Hardware
Facilities modification that includes changes in piping
arrangement, equipment layout and specifications,
instrumentation and materials of constructions

Examples :
facility additions
changes to piping e.g pipe, valves and fitting

26

MOC Procedure Coverage


Procedural
Changes

or deviations to approved procedures,


processes and plans.

Examples:

Operating Procedure
Changes to approved maintenance
procedures
Changes to approved inspection
procedures
27

MOC Procedure Coverage


CHEMICAL / HAZARDOUS MATERIALS
MOC

for changes to chemicals and hazardous material Mercury,


H2S, CO2), its injection & treating rates, handling (including
increase from the original design).

The

original health risk assessment, safety risk assessment and


environmental impact assessment may need to be re-evaluated

Examples:

Changes in the type / amount, or frequency of corrosion


inhibitor.
Changes to type / amount of lube oil used in compressor
Changes to type / amount, or frequency of demulsifier
Changes to location and quantity of chemical injection
Blasting materials
Hydrogen sulphide
Mercury

28

MOC Procedure Coverage


OPERATING PARAMETERS
MOC

for changes to facility operation physical parameters, control


system parameters, safety protection systems.

Includes

bypassing of these devices for more than 48 hours. The


Permit To Work system bypass certificate maybe used to manage
bypasses up to 48 hours if appropriate mitigation measures are put
in place.

Notes:

Changes in operating parameters require a MOC request if the operating


parameter is to be set outside the normal operating range of an equipment
/ process.
MOC is also required for "software" changes to the control system logic or
the control configuration .
Routine control loop tuning does not require a MOC.
Special attention is required for changes / deviations to "critical operating
parameters (described in the Operating Manual for each facility).
29

MOC Procedure Coverage


OPERATING PARAMETERS/Cont..
Examples:

Change in shutdown settings (outside the operating


envelope)
Change in alarm settings (outside the operating
envelope range)
Change in the set pressure of a Pressure Safety Valve
(PSV)
Change in the control system logic or configuration.
Change outside PCSB approved requirements such as
discharge water quality, flaring, and product quality.

30

MOC Procedure Coverage


CRITICAL POSITION
Competent

personnel need to be assigned in key


supervision and management positions, and to carry out
integrity critical tasks.

Change

and movement of PCSB and Contractor staff


routinely occurs.

The

MOC procedure shall be used to manage the HSE risks


of changes related to integrity critical technical, supervision
and management positions.

31

MOC Procedure Coverage


CRITICAL POSITION /Cont..
Examples:

Junior personnel assinged to work in positions with qualifications


and experience outside the stipulated job description qualification
and experience levels.
Relief assignments for critical positions such as OIM, Head of
Operations, Asset Manager, Section Head when they on leave or
away from the office.
Transfer of personnel to a new location without the required
competency or experience on the new locations HSE critical
equipment or operations.
Assign dual skilled person to lead work higher than level 2 of his
second skill that is outside the normal scope of duties assigned to
this position.
Transfer or promotion of personnel to new jobs an assignments
Contractor staff changes due to the awarding of a new contract
Contractor staff changes due to contractor replaces them with
new personnel

32

MOC Procedure Coverage


TYPE OF CHANGES
Permanent change- change that is intended to remain in
place indefinitely

Temporary change - Change intended to remain in place for a


specified period only, must not be more that 6 months.

Emergency change - Change to be undertaken immediately to


avoid, mitigate, or control an incident.

Urgent change - Change to be made promptly to take


advantage of a limited business opportunity, capture the
expected benefits of the change, reduce the financial impact of
adverse events. or avoid significant negative business impacts

33

Differences.....
Emergency

change relates to immediate


actions to control or prevent an HSE incident.

Urgent

change is required to take


advantage of a limited window of opportunity
that is business related.

34

MOC Process
Basic Steps of MOC Process
PROCESS 1

IDENTIFICATION

PROCESS 2

EVALUATION

Recognizing & Initiating


Change
Endorsed by Supervisor
Change Review and
endorsement
Authorisation of change

PROCESS 3

APPROVAL

PROCESS 4

IMPLEMENTATION

PROCESS 5

CLOSE -OUT

Construction
Update Pre-Startup Documentation
Communicated to all parties
Completion of Change
Documentation & Lessons
learned.
35

MGMT ROLES AND RESPONSIBILITIES


APPROVAL REQUIREMENTS
Risk
Category

Position

Obviously
No Risk

No MOC formal
evaluation required by
Technical Authority.
MOC must be raised.
Impacted OIM(s) or
appropriate functional
group(s) supervisor(s)

Impacted Asset
Manager(s) and
Functional Manager(s)

Endorse

Approve

Copied

36

MGMT ROLES AND RESPONSIBILITIES


APPROVAL REQUIREMENTS
Risk
Category

Position

Low Risk

Immediate Supervisor

Endorse

Appropriate Technical
Authority(s)

Impacted Asset
Manager(s)

Copied

Impacted OIM(s) or
appropriate functional
group(s) supervisor(s)

Head Of Operations or
appropriate functional
group(s) Section Head

Approve

37

MGMT ROLES AND RESPONSIBILITIES


APPROVAL REQUIREMENTS /Cont..
Risk
Category

Position

Medium
Risk

Immediate Supervisor

Impacted OIM(s) or
appropriate functional
group(s) supervisor(s)

Head Of Operations or
appropriate functional
group(s) Section Head

Appropriate Technical
Authority(s)

Impacted Asset
Manager(s)
Impacted General
Manager(s)

Endorse

Approve

Copied

38

MGMT ROLES AND RESPONSIBILITIES


APPROVAL REQUIREMENTS
Risk Category

Position

High Risk

Immediate Supervisor

Impacted OIM(s) or
appropriate functional
group(s) supervisor(s)

Head Of Operations or
appropriate functional
group(s) Section Head

Appropriate Technical
Authority(s) (CTE principal)

Impacted Asset Manager (s)


CHSE Manager
Impacted General Manager(s)
DOM and DD Manager

Endorse

Approve

Copied

X
X
X
39

MGMT ROLES AND RESPONSIBILITIES


APPROVAL REQUIREMENTS
TEMPORARY CHANGE
Temporary Change shall NOT exceed six (6)
months.

For

each extension, risk has to be reassessed


and approval must be obtained from next higher
level of management.

40

Risk Matrix
RISK MATRIX
Increasing Probability
A

Consequences
Severity

PEOPLE ASSETS ENVIRON REPUTATION


MENT

Potential
Impact
USD

No Injury

No
No Effect
Damage

No Impact

Zero

OBVIOUSLY NO RISK

Slight
Injury

Slight
Damage

Slight
Effect

Slight Impact

Minor
Injury

Minor
Damage

Minor
Effect

Minor Impact

<100,000

Major
Injury

Localize Localized
d
Effect
Damage

Considerable
Impact

<1,000,000

Single
Fatality

Major
Damage

Multiple Extensiv
Fatalities
e
Damage

Major
Effect

Massive
Effect

Has Occurred Has Occurred in Has Occurred


Never Heard of
Heard of
Division
in
E&P Incident in E&P in Groups
at Location
and/or OPU
Industry
Industry

<10,000

Shall manage for continuous


improvement
Shall Manage For Continuous Improvement

National Impact <10,000,000

International
Impact

Incorporate
Incorporate risk reduction measures

Risk
Reduction

Intolerable

>10,000,000

Intolerable

Measures

41

MOC Process
PROCESS 1 - IDENTIFICATION
Recognize that a change or deviation may be desirable and to
determine if the change or deviation is:
Subject to the change management process
Covered by the MOC Procedure, or addressed elsewhere
To be classified as temporary, permanent, urgent, or emergency

42

MOC Process
PROCESS 1 - IDENTIFICATION
Endorsement:
Initiators supervisor must endorse all changes sent in for
evaluation.

In the event the supervisor does not endorse the suggested


change, the Initiator shall be advised in writing of the
reason for declining the evaluation.

For changes that are endorsed by the Initiator's supervisor,


the MOC Coordinator (MOCC) shall:
Assign the MOC number
Register the change in the MOC log
Track until final closeout, or rejection of the change
43

MOC Process
PROCESS 2 EVALUATION

Suggested Change judged to be


"Obviously No Risk"
by Initiator and Initiator's
Supervisor
An MOC is required. However a formal risk
evaluation is not required.
The MOC form shall be forwarded directly
to the parties potentially impacted by the
change for their endorsement.
The
impacted
Asset
Manager
and
appropriate functional manager must be
sent a copy of

Suggested Change for all


other risk categories

An MOC is required.
A formal risk evaluation shall be
completed under the direction the
Technical Authority personnel who
have been trained and assessed
competent
in
risk
evaluation
techniques by CHSE

44

MOC Process
PROCESS 2 EVALUATION

Qualifications :
OIM and Technical Authorities shall be trained and
assessed as competent in risk assessment
/evaluation techniques by CHSE

MOCs with a Low, Medium and High level of risk


requires a Technical Authority (TA) trained in risk
evaluation methods to evaluate the risk, identify
risk reduction mitigation actions and endorse if
within acceptable limits prior to approval.

45

MOC Process
PROCESS 2 - EVALUATION

Risk Evaluation Form :


Appropriate methods for conducting risk assessments shall
be used - depends on the risks associated with the change.
Examples of risk assessment and analysis methods:

Hazard & Effect Management Process ( HEMP )


Hazard Identifications (HAZID)
Hazard and Operability Studies (HAZOPS)
Quantitative Risk Assessment (QRA)
Fire Protection Analysis
Failure Mode and Effect Analysis (FMEA)
46

MOC Process
MOC RISK EVALUATION FORM
P e t r o n a s C a r i g a li S d n B h d
M O C R IS K E V A L U A T IO N
1

L o c a t io n :

S c e n a r io T it le

M O C N o .:

T ype

P e rm a n e n t

T e m p o ra ry

6
D e s c r ip t io n o f S c e n a r io

10

R is k E v a lu a t io n

E m e rg e n c y
U rg e n t

P r io r it y

N o rm a l
N a tu re o f C h a n g e :
H a rd w a re
P ro c e d u ra l
C h e m ic a l
O p e r a t in g p a r a m a t e r s
C r it ic a l p o s itio n s

B a s e d o n Q u e s t io n n a ir e s , is
M O C r e q u ir e d ?
Yes
No

I n it ia l R is k E v a lu a t io n
C onsequence
P r o b a b ilit y
A

0
1
2
3
4
5

11

12

M it ig a t io n A c t io n

R is k E v a lu a t io n A f t e r
M it ig a t io n
C onsequence
P r o b a b ilit y

13

14

T A E v a lu a t io n & M it ig a t io n

F in a l E v a lu a t io n

C onsequence
P r o b a b ilit y
15

F IP P ro c e s s ?
Yes

P re p a re d b y :
I n it ia to r :
D a te :

A p p ro v a l
T e c h n ic a l A u t h o r it y :
D a te :

No

O IM :
D a te :

47

MOC Process
PROCESS 3 APPROVAL

The approval process is designed to make approvals of high


to medium risk changes are assessed by the appropriate
level of authorities.

The higher the risk, the greater is the need for mitigation to
lower the risk, and special procedures to control the risk.

Refer to Table 2.3 Approvals Required for MOC Procedure

48

MOC Process
PROCESS 4 IMPLEMENTATION

Once approval obtained, appropriate functional group shall


implement the change.

All requirements (such as training, PTW, PSSR checklist) shall


be fulfilled prior to implementation.

The implementation process shall include all appropriate


steps necessary to ensure that PCSB Systems and Standard
Procedures are followed.

Figure 4.5.A Implementation(Process 4A)

49

MOC Process
PROCESS 5 CLOSE OUT
Line management shall verify with all affected parties that the
change has been implemented as planned, including the
updating of appropriate on-site documentation (for example,
redline drawings).

All appropriate parties shall be notified of the change.

MOCC ensures that all appropriate documentation is


completed and then "closes out" in the MOC database.

MOC Report shall be sent monthly to the MOC System


Administrator.

The procedure administrator communicate lessons learnt to


PCSB & PETRONAS.

50

TECHNICAL AUTHORITY
DISCIPLINES

DISCIPLINE

TA

ALT TA

SECTION/UNIT

Matl, Corrosion,
Inspection

Ghazali M Zin

Ruzlan Hashim

PTS4

Electrical

M Fadzhli
Hassan

Iskandar Anopera

PTS2 / PTS23

Control &
Automation

A Razak Warris

M Selvaraj

PTS2 / PTS23

Mechanical
Static

Ernesto C
Geronimo

Ferdinand A Mamaril

PTS2 / PTS22

Mechanical
Rotating

Al Bahri
Syahbana

M Arshad A Nawawi
M Syukri Hitam

PTS3 / TMG

Civil / Structural
Engng

M Nordzi M
Rafdzi

M Ashri Mustapha

PTS2 / PTS21

51

TECHNICAL AUTHORITY
DISCIPLINES

DISCIPLINE

TA

ALT TA

SECTION/UNIT

Process Engng

Nik M Sapawi

Nazarudin
Ahmad

PTS2 / PTS22

Pipeline Engng

M Ashri
Mustapha

Zahrin Zain /
M Rosli M Ali

PTS2 / PTS21

Well Services /
Engng

PTS1 / Well Svcs

TBA
TBA
TBA

52

MOC COORDINATORS (MOCC)


Roles & Responsibilities
Prepare

and maintain detailed MOCC related procedures for the


functional group.
Coordinate change processes within their functional group.
Maintain necessary change documentation for their functional group,
including:
Change database and status reports
Close-out reports
MOC files
Prepare

Change Report Summaries and send them to


the Procedure Administrator
Management reporting on MOC performance
Coordinate the PCSB change processes with the MOC Procedure
Administrator

53

MOC COORDINATORS (MOCC)


Roles & Responsibilities
Approved

Revisions of Procedure shall be scheduled for


implementation and tracked, which include:

Circulation of newly updated documents.


Training of personnel in the improvement.
Implementation and control of any temporary measures
prior to completing the improvement.
Exchange of communication regarding best practices within
and between units and with other Corporate functions.

54

MOC RECORDS
Roles & Responsibilities
Good

documentation filing system and database is required for


proper tracking and closeout of changes.

MOC

Manual Documentation Filing :

MOC Forms are sent to the MOCC, who is responsible for


the "official" MOC documentation, when the change is
complete.
A copy of the MOC form can also be kept at the facility
where the change was made.
MOC documentation shall be kept consistent with the
Information and Documentation Manual.
55

MOC RECORDS
Roles & Responsibilities

MOC Database
MOC shall be kept both in hard copy and on a
shared drive that is accessible to all personnel
within the OPU.
In future - MOC database shall move to an
electronic computer database accessible via the
PCSB LAN Local Area Network. The database
shall be designed to record and track all PCSB
wide MOC forms that have been assigned a
unique MOC number. Database input is provided
by the information recorded on the MOC Log Form

See Appendix II for an example of the MOC Log Form.

56

MOC RECORDS
Roles & Responsibilities
MOC Database / Cont..

Database provides the capability of ensuring that


appropriate documentation is being maintained while
providing a tool for system audits.
Database shall be capable of sorting, filtering the data, and
generating reports to meet the requested needs of the user
or auditor.
Access to Database :
Read-only access - available to most individuals within
PCSB.
Write access - MOCC, Procedure Manual Administrator,
and Manual Owner.
Others - may contact the Procedure Manual Owner or
Administrator for permission.
57

MOC Audit / Review

The primary objectives of the audit is to review :


Actions are evaluated in a structured manner to determine if
MOC is applicable,
Changes are correctly evaluated for risk and approved at
appropriate levels
Implementation and close out are properly documented i.e

MOC request logs


Management of Change form
risk evaluation form
filed documentation of completed changes

Audit frequency shall be annually and included in the HSE Audit


Plan
58

RISK ASSESSMENT AND ENDORSEMENT


MOC RISK EVALUATION FORM
P e t r o n a s C a r i g a li S d n B h d
M O C R IS K E V A L U A T IO N
1

L o c a t io n :

S c e n a r io T it le

M O C N o .:

T ype

P e rm a n e n t

T e m p o ra ry

6
D e s c r ip t io n o f S c e n a r io

10

R is k E v a lu a t io n

E m e rg e n c y
U rg e n t

P r io r it y

N o rm a l
N a tu re o f C h a n g e :
H a rd w a re
P ro c e d u ra l
C h e m ic a l
O p e r a t in g p a r a m a t e r s
C r it ic a l p o s itio n s

B a s e d o n Q u e s t io n n a ir e s , is
M O C r e q u ir e d ?
Yes
No

I n it ia l R is k E v a lu a t io n
C onsequence
P r o b a b ilit y
A

0
1
2
3
4
5

11

12

M it ig a t io n A c t io n

R is k E v a lu a t io n A f t e r
M it ig a t io n
C onsequence
P r o b a b ilit y

13

14

T A E v a lu a t io n & M it ig a t io n

F in a l E v a lu a t io n

C onsequence
P r o b a b ilit y
15

F IP P ro c e s s ?
Yes

P re p a re d b y :
I n it ia to r :
D a te :

A p p ro v a l
T e c h n ic a l A u t h o r it y :
D a te :

No

O IM :
D a te :

59

MOC APPROVAL PROCESS

The

approval process is designed to make approvals of


high risk changes - and to a slightly lesser extent,
medium risk changes - difficult.

The

higher the risk, the greater the need for mitigation


to lower the risk, and special procedures to control the
risk.

Even

with mitigation and special procedures, medium


and high risk changes require higher levels of
management approval and more stringent
documentation and justification.

60

MOC APPROVAL PROCESS

MOCs

with a Low, Medium and High level of risk requires a


Technical Authority (TA) trained in risk evaluation methods
to evaulate the risk, identify risk reduction mitigation actions
and endorse if within acceptable limits prior to approval.

Table 2.3 Approvals Required for Production Operations MOC Procedure

61

MOC APPROVAL PROCESS


The Review for Approval
The Initiator, with the Supervisor's assistance, needs to identify
the appropriate parties to review and approve change. A review
for regulatory compliance is required.

If the proposed change results from or requires a deviation from


a requirement in a law or regulation, there are two options:

- Reject the change


- Apply for exemption
NOTE:

To apply for an exemption, refer to Regulatory Compliance Procedures .The


changes must not be implemented until the exemption is granted by the
appropriate regulatory body.
62

MOC APPROVAL PROCESS


Approval and Rejection

Rejection and Possible Modification

In the event of the change being rejected, the suggested MOC


form shall be returned to the Initiator and the change log entry
shall be closed.
Approval:

After the appropriate reviews and endorsements are


obtained, the change is approved by the proper level of
management. The change shall then be forwarded for
implementation.

63

MOC Procedure Coverage


MOC PROCEDURE KEY INTERFACES
Procedure/Manual

PCSB Facilities Improvement


Proposal (FIP) Guide

Description / Interface

Additions , replacement and upgrades


to equipment, process, and facilities

MY ALL E 08 001, Rev. 2 Dec


2000
OIM MY CHO E 07 001,

Offshore Installation Manager in PCSB

Rev. 0 Apr 2001


Permit To Work Manual
Technical Autority Framework
MY ALL S 07 003
Rev. 0 March 2001
MY ALL S 07 004
Rev. 0 April 2001

Table 22

N/A
TBA
HSEMS 2.1 Supervisory Safety
Procedures Manual
HSEMS 2.2 - Work Place Safety
Procedure Manual
64

P C S B M O C S Y S TE M M A N U A L
M A N A G E M E N T T R A IN IN G
ASSESSM EN T

N AM E
P O S IT IO N
D EP A R TM EN T
DATE
S IG N A T U R E

Q u e s t io n s

No

U n d e r s ta n d th e k e y p e r s o n n e l r o le s a n d r e s p o n s ib il it ie s

U n d e r s ta n d y o u r o w n r o le s a n d r e s p o n s ib ilit i e s a s a n a p p r o v in g
a u t h o r ity

U n d e r s ta n d th a t D O A s h a ll b e a q u a lif ie d p e r s o n to a p p r o v e th e M O C

U n d e r s ta n d y o u r o w n r o le s a n d r e s p o n s ib ilit i e s a s a n M O C P a n e l
M ember

U n d e r s ta n d th e tr a n s it io n fr o m c u r r e n t p r a c t is e i. e . F I P /T A M to th e
M O C s y s te m

U n d e r s ta n d th e M O C P r o c e s s

U n d e r s ta n d th e te c h n ic a l e n d o r s e m e n t p r o c e s s fo r p r o p o s e d c h a n g e

U n d e r s ta n d th e M O C r is k m a t r ix

U n d e r s ta n d th e a p p r o v a l r e q u ir e m e n t s fo r c h a n g e s a t d if fe r e n t r is k
le v e ls

10

U n d e r s ta n d th e a u d it r e q u ir e m e n ts a n d fr e q u e n c y

11

U n d e r s ta n d th e M O C c o v e r a g e

A ns w e r
YES

NO

N /A

65

Take-Aways?

66

TERIMA KASIH

67