Management of Change

Prepared and Issued by:

Andrew Merrison, Group Head HSE

Reviewed and Authorised by:

Adnan Naji, Chief Operating Officer – Saif Bin Darwish

Revision History:
Revision Date Description
01 Oct 2013 Rename SMS & SMSP
02 July 2017 Revised in line with OSHAD Ver 3.0 & Changed the Group Head HSE
03 March 2019 Revised the procedure in line with ISO 45001 and OSHAD
requirements

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1.0 PURPOSE

The purpose of this procedure is to ensure that all potential OSHE risks associated with
changes or modifications in products, services, equipment, legal requirements are
recognised, documented and formally reviewed to have minimal impact on OSHE
performance.

2.0 SCOPE

This procedure is applicable to all SBD projects and divisions where any temporary,
permanent or emergency change occurs with potential health, safety and environmental
implications. This includes changes to systems, processes, procedures, equipment,
products, materials or substances and laws and regulations.

3.0 DEFINITIONS

Replacement in Kind (RIK): An item (equipment, process, procedure etc) that meets
the design specification of the item it is replacing such as like for like or any other design
alternative.

Temporary Change: Any change that will not remain in effect indefinitely. A point in
time will be specified when the process will return to its normal state/original conditions.
A temporary change will be subject to the same evaluation as permanent changes.

Emergency Change: Action necessary to remedy an Emergency situation that poses

imminent impact to OSHE.

Review Committee: The review committee specifically for this procedure shall consist
of Division Manager, Supervisors, site HSE, QA/QC personnel, others/specialists as
required as per the change.

Change Initiator: An individual or department who identifies the need for change or an
opportunity for improvement.

4.0 RESPONSIBILITIES

(RACI Table) R: Responsibilities (who will actually do the action), A: Accountability (who is answerable for
the process) C: Consulted (who must be consulted in the activity), I: Informed (who must be informed)

 
Functions and Responsibilities
 
Activities
  Project
Change Review HSE In
Manager/De Employees
Initiator Committee charge
partment
Head
Initiate the change / modification /
A I C I
RIK R

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MOC review A R R I
R
Give recommendations to reduce
A R R R C
all potential risk
Approval of Changes R I R R I
Implement recommendations A R I C I
Record and Review the changes A I R R C

5.0 Management of Change (MOC)

MOC shall be implemented for all changes in organisation, personnel, plant, machinery,
equipment, materials, documentation, processes and procedures.

5.1 Personnel or Organisational Change

The MOC sheet shall be completed for all changes involving personnel identified as being
in Safety Critical Position. Examples of personnel or organizational changes include:
 Creation of a new Safety Position or removal of an established safety position in
any operating area;
 Transfer of duties from a safety critical individual such as from HSE staff/ team to a
non-safety person/team;
 Change in responsibilities or exposure to hazardous environment for an unskilled
employee

5.2 Plant, Equipment, Machinery

A management of change sheet along with risk assessments shall be prepared for
installation of all new machineries.
Any major engineering change or modifications to the existing machinery apart from
changes mentioned in the manufacturer guidelines shall be required to follow the MOC
procedure. The modifications shall be inspected by approved third party before use and
suitability certificate maintained.
For any replacement in kind (RIK) the MOC is not required.

5.3 Change to procedures and processes

Any major change to routine procedure or process shall be required to complete MOC.
The risk assessment for the specific activity shall be reviewed and updated to ensure all
risks associated with the change are suitably addressed.

5.4 Emergency MOC

An emergency MOC is any change that requires quick initiation and implementation for
safety, environmental or potential equipment damage circumstances once the area
Emergency Response Plan has been implemented.

Managing an Emergency MOC

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 The Project Manager has the authority to review the emergency and approve a change
for implementation where required. The steps taken will be:

a) Once the emergency is declared the Emergency Response Plan shall be

activated and measures will be taken to prevent injury/harm to employees,
environment and mechanical integrity of the asset.
b) Implement the necessary change to mitigate the hazard and follow up as soon
as possible once the emergency is under control. If any change has been made
and placed into operation, the MOC shall be completed.

5.5 Temporary Change

All temporary changes must be documented using the MOC Process. The specific point in
time when a temporary change is scheduled to return to original condition is called the
“Temporary to” date.

If any temporary change is going to become a permanent change it shall be stated on the
MOC and all requirements shall be fulfilled.

6.0 CHANGE PROCESS

Changes evaluated in an orderly and controlled manner will keep any potential risks to a
minimum by giving all interested parties an opportunity to review and contribute to the
process.

6.1 Change Identification and Classification

The Change Initiator (Individual/Department) shall evaluate the proposed change with the
following in mind:
 Are there any safety, regulatory, contractual or environmental considerations?
 Is the change necessary to meet the operational requirements?
 Does the change make sense from a business prospective?
 Is this a change or replacement in kind (RIK)?

Once classified as a change the MOC process shall be initiated. The initiator shall fill in all
details required in the MOC sheet and attach all supporting documents which may include
but are not limited to:
 Equipment specifications for new equipment;
 MSD’s for new chemicals;
 License information / regulatory requirements
 New process details

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 The Initiator categorizes the changes as one of the three types:
1. Permanent;
2. Temporary, or;
3. Emergency

6.2 Change Evaluation

The MOC review committee evaluates the change to include the potential
consequences, risk assessments, and mitigation measures.

The level of evaluation given to a change must be consistent with level of risk exposure
and involve representatives from all groups affected by the change. The process of
evaluating a change will include the following factors, as applicable.

a) HSE impacts.
b) Technical considerations.
c) Impact on existing critical safety items, devices or requirement for new designs or
new devices.
d) Impact on existing documentation including contracts, procedures manual, hazard
assessments, project plans, technical data etc.
e) Training requirements for personnel.
f) Special precautions required to maintain safe operations during implementation.
g) Mitigation measures that will lower the risks associated with the change.

6.3 Implementation and documentation

The changes shall be communicated to all interested parties, any additional training,
procedures, written documentation and signed off by appropriate personnel.

6.4 Review and Record

Most of the review requirements are to be applied during the evaluation stage as
described within 6.2. A technical review is required to ensure compliance to regulations
(Acts / Licensing / Regulatory conditions of approval), corporate standards, and
operational constraints and to ensure a thorough hazard assessment.

Reviewers will be assigned according to the scope of the change and shall assess the
completed Process Hazards Analysis (PHA) and / or equivalent documentation as part of
the review process

7.0 DOCUMENTATION/FORMS

 OSHEMSP72/F01 - Management of Change Sheet

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8.0 REFERENCES

 OSHAD SF Element 9 – Compliance and Management Review

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