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MANAGEMENT OF CHANGE
(Deviation Control)
DRAFT 24/03/03
CONTENTS
1.0 Introduction
2.0 Deviation Procedure
3.0 Recurrent Deviation Requests
LIST OF ABBREVIATIONS
This procedure is part of a suite of procedures that underpins the Parker Drilling (New
Zealand Operations) Health, Safety, and Environmental Management System (HSE-MS)
It is to be read in conjunction with the Health Safety and Environmental Protection
Program (HSE-PP) Section A. pages 15 –17.
This procedure covers the process that PDNZ has implemented in order to handle
requests to deviations (or relaxations) from HSE requirements.
This procedure applies to PDNZ and Contractors and to onshore and offshore work
locations.
The deviation procedure is shown in flowchart form in Figure 1.0. The steps in the
flowchart are described in Table 1.0.
Note the procedure assumes that the deviations being considered are one-off situations.
Note also that the level of documentation, justification and authorization increase with
the potential HSE severity of the deviation. This is described in Table 1.0.
Where deviations from a particular requirement, are requested frequently, for justifiable
operational reasons, and where the alternative/modified controls are adequate to manage
the associated hazards, then the logic underpinning the original requirement should be
challenged. If the original requirement is found to be overly onerous, outmoded or no
longer applicable, for whatever reason, then the requirement should be modified to reflect
the practice usually adopted in the deviated situation. However, if the original
requirement remains valid, then the current operating mode, equipment used, work
practices employed, etc. should be changed, in order to remove the need to generate
recurrent deviation requests.
FIGURE 1.0: DEVIATION FLOW CHART
Confirm that a
Deviation is
required
(1)
Formulate modified or
alternative controls.
(4)
No
Authorize the deviation, in
accordance with table 3
Authorization Matrix
(8)
Implement the
agreed controls
(9)
Undertake the
operation.
(10)
TABLE 1.0: FLOWCHART SUPPORT NARRATIVE
Flowchart Description of Flowchart activity
Symbol No.
1 Deviations from clearly stated requirements in procedures or manuals should only be
made in exceptional and justifiable circumstances. The person requesting the change
(“The Requester”) should satisfy his (or her) self that a deviation really needs to be made
before commencing the deviation request process.
2 The first question that the Requester needs to ask is: “Why is the original requirement
was put into place – i.e. what undesirable consequence is it meant to prevent?” In most
cases this should be obvious, but if any doubt exists the requester should consult with his
immediate supervisor.
3 Once the Requester understands the reason for the requirement, then he should be able to
determine the worst-case consequences, with reference to table 2.0 (see below).
4 The Requester needs to formulate modified or alternative methods and controls to those
originally required.
5&6 The Requester needs to assess whether the modified or alternative controls are adequate
to prevent the worst-case consequences being “realized”. There are various assessment
methods available, ranging from the very straightforward to the very complex. Typical
techniques include Job Safety Analysis, HAZOP, Bow-Tie analysis, Quantitative Risk
Assessment, etc. In general, the higher consequence the deviation can result in the more
sophisticated the method needs to be. The Requester should seek specialist advice, on
these techniques, as necessary. Where the method and controls are deemed unsatisfactory
then the Requester needs to formulate further/better methods and controls, until a
satisfactory solution is achieved. If this is not possible then the request for deviation
cannot be justified.
7 After the Requester has satisfied himself that the modified or alternative methods and
controls are adequate to prevent the worst case consequences being “realized”, he then
needs to ensure that the methods and controls have not introduced a new set of
consequences not envisaged by the original requirements. This involves an iterative
process like that described for steps 5&6. If this is not possible then the request for
deviation cannot be justified.
8 Once the Requester is satisfied that the deviation request is robust (i.e. satisfactorily
completing steps 1-7, above. He needs to have the deviation authorized. The level of
authorization and justification increases commensurate with the worst-case consequences
– refer to the Authorization Matrix (Table 3.0).
9&10 Once authorization has been given, the agreed methods and controls should be
implemented and the operation conducted in accordance with the relevant procedures.
Lifts of equipment where rig lifting 2 The controls are operation specific and need to be Lifts of equipment where
certification has expired and has to be determined on a case by case basis. rig lifting certification has
returned to New Plymouth for re- expired and has to be
certification returned to New
Plymouth for re-
certification
FIGURE 2.0: PROFORMA PDNZ DEVAITION REQUEST
Description of Deviation: