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AI-PS Element Guide

Element 13: Management of


Change

Doc. Reference: GU-XXX-13


Version: Issue 1.0
Date: 10 August 2011
Doc. Owner: Head of Technical Safety Engineering
(MSE4)
Element Owner: Head of Production (UOP)

AI-PS Element Background


AI-PS in PDO
Assuring the safety of our people, our assets, the
environment and the companys reputation is a core
value of PDO and providing assurance that we are
managing our major process safety risks is a critical
aspect of our corporate governance. Asset Integrity
Process Safety (AI-PS) describes the way we manage
our assets so that the process risk is As Low As
Reasonably Practicable (ALARP).
What it is
Asset Integrity Process Safety (AI-PS) is the means of
ensuring that the people, systems, processes and
resources, which deliver integrity, are in place, in use
and fit for purpose throughout the whole lifecycle of
the asset. The aim is to be able to confidently state
that our assets are safe and we know it.
Asset Integrity Process Safety Management is a
complex area of expertise covering a wide range of
components, all of which are essential to ensuring
systems, processes and equipment perform as
required. There are a number of Elements which make
up the Asset Integrity Process Safety management
system.
Structure of AI-PS Assurance in PDO
PDO has a three-tiered approach to AI-PS assurance:
Level 1: Includes audits conducted on behalf of PDO's
Internal Audit Committee (IAC) as part of the

Integrated Audit Plan. This includes independent audits


carried out by external bodies, such as Shell.
Level 2: Includes audits carried out on behalf of Asset
Managers as part of their own Asset level assurance
processes.
Level 3: Includes task verification and assurance
activities that supplement the formal audit process.
There are 20 elements in total within the PDO AI-PS
Management System as follows:
Elements list:
Element 1: Process Safety Culture
Element 2: Compliance with Standards
Element 3: Corporate Process Safety Competency
Element 4: Workplace Involvement
Element 5: Stakeholder Outreach
Element 6: Process Knowledge Management
Element 7: HEMP
Element 8: Plant Operating Manuals
Element 9: PTW
Element 10: Technical Integrity
Element 11: Contractor Management
Element 12: Training and Performance Assurance
Element 13: Management of Change
Element 14: Readiness for Start Up
Element 15: Conduct of Operations
Element 16: Emergency Management
Element 17: Incident Management
Element 18: Measurements and Metrics

Element 19: Audit and Verification of Level 2 Process


Element 20: Management Review and Continuous
Improvement

Element 13: Management of Change


Background to Element
When changes are introduced, it is essential that new
risks are not unknowingly incurred, or that the
prevailing risk profile is not adversely changed without
appropriate mitigation. This is when Management of
Change (MOC) is required.
The MOC Process ensures that business risk related to
change (especially AI-PS), is identified, mitigated and
accepted prior to a change physically occurring.
Aims and Objectives of Element
The MOC element helps ensure that changes to a
process do not inadvertently introduce new hazards or
unknowingly increase the risk of existing hazards.
Scope of Element
The MOC process covers the full life cycle of Assets
and all disciplines. MOC is the risk assessment and
mitigation process that supports many other
processes, e.g. engineering modification, data,
drawing and document update, Organisational Change
management.

AI-PS Element Guide Implementation

Aims and Objectives of AI-PS Element Guide


The aim of this AI-PS Element Guide is to provide
background to AI-PS and a structured and consistent
approach to carrying out Level 2 Self Assessments and
Level 3 Verification for all AI-PS Elements within PDO.
The intended audience for the guide are the members
of the AIPSALT although this can be used as a basis for
training and awareness for all staff at the asset.
Responsibilities and Accountabilities for AI-PS
Element Guide Implementation
The Operations Manager is accountable for the Level 2
Assurance process at the asset.
Completion of the Level 2 Self Assessment and Level 3
Verification Checklists, as provided in this element
guide, is the responsibility of the Element Champions
and AIPSALT. The Delivery Team Leader (DTL) is
accountable for the AIPSALT.
AI-PS Assurance Leadership Team (AIPSALT)
The AIPSALT is comprised of the asset DTL and Process
Safety Element Champions (PSEC).
The DTL and PSEC roles include: reporting the status of
the Level 3 Verification activities for the relevant
Element at the AIPSALT meeting; maintaining Key
Performance Indicators (KPIs) for the Element;
monitoring the effectiveness of the Level 3 Verification
activities in assuring AI-PS, and recommending
changes to improve effectiveness and efficiency as
appropriate; monitoring the progress of corrective

actions and improvement plans associated with that


Element; and leading Level 2 Self-Assessment of
compliance with the requirements of that Element.

Level 2 Assurance

The frequency of Level 2 Self Assessment should also


reflect how well the asset is performing against all AIPS Elements and be performed no less than on an
annual basis (ahead of the Level 2 Audit).

Level 2 Self Assessment and Audit

Level 3 Verification Checklist

Level 2 assurance is provided by a series of AI-PS


audits carried out on behalf of Asset Directors and
Operations Managers as part of their own DirectorateLevel assurance processes.

Level 3 Verification Description

Level 2 Audits (and Level 2 Self Assessments) are


conducted at each Directorate using standard
protocols and templates described in this series of AIPS Element Guides.
The Level 2 Self Assessment Checklist (provided in this
AI-PS Element Guide) can be viewed as a health
check of asset performance again the element.
Completing the Level 2 Self Assessment will help the
asset to identify areas for improvement ahead of the
Level 2 Audit.

Frequency of Level 2 Assurance


Level 2 Audits are conducted annually at each
Directorate but the frequency and duration may be
adjusted to reflect either positive or negative trends,
recent audit findings, emerging risks and alignment
with other audit activities. The schedule of Level 2
audits is set in the Directorate HSE Plan.

Level 3 Verification demonstrates compliance with the


asset HSE Case barriers, HSE Critical Tasks,
operational procedures and other requirements
defined in the HSE Management System. These
activities provide an ongoing check that the
procedures, tests and inspections necessary to
maintaining the functionality of Safety Critical
Elements and systems are completed as required so
that process risk is managed to a level that is As Low
As Reasonably Practicable (ALARP).
In summary, the Level 3 Checklists are an operational
level sample check or mini audit completed by the
asset against PDO and asset based procedures. The
effectiveness of the Level 3 Verification process is
assessed during the Level 2 Self Assessment process
and ultimately via the Level 2 Audit programme.
Verification Checklists
Level 3 Verification checklists have been developed for
each AI-PS Element within PDO in order to provide a
structured and consistent approach to Level 3
Verification across all assets. The Level 3 Verification
checklists are structured as a sample check or specific
and localised audit of the Element in question.

By successfully verifying that the Level 3 Verification


activities are being completed correctly it provides a
strong indication that the element is being
implemented at the system level (assessed via the
Level 2 Self Assessment and Level 2 Audits).

The Level 2 Self Assessment and Level 3 Verification


checklists for this element are provided below.

Level 2 Self Assessment


SN
13.1
13.1
.1
13.1
.2
13.1
.3

13.2
13.2
.1
13.2
.2
13.2
.3
13.2
.4
13.2
.5
13.2
.6
13.2
.7

Protocol
Has MOC been applied to the following
types of changes at the facility in the last
twelve months:
Process changes (hardware,
process control, process condition
changes)?
Procedural changes that affect AIPS critical content?

Organisational changes that affect


AI-PS activities (PDO or
contractor)?

Does the asset have dedicated MOC


Process Owner(s) for the following MOC
Processes:
Facility Change Proposals (FCP)

Temporary override of
safeguarding systems
Operations procedure temporary
variance
Asset abandonment and
restoration
Asset and (maintenance &
Inspection) activity registration and
deletion
Control of portable temporary
equipment
Other changes, e.g. critical
drawings and document
amendments, organisational
changes, etc.

Y / N / NA & Evidence

Possible approaches

Ask the Senior Operator (or equivalent) if


there have been any process changes in
the past 12 months.
Review critical documents to identify those
that have been changed in the last 12
months. Ask about the MOC process that
was followed for the change(s).
Review the organogram in the asset HSE
Case. Review the Operating Philosophy.
Ask a selection of senior asset personnel in
HSE Critical Positions how long they have
been in the role.

Refer to PR-1001a
Refer to PR-1001c
Refer to PR-1001e
Refer to PR-1164 and PR-1419
Refer to PR-1344 and PR-1528

Refer to PR-1960
E.g. ask who is the asset focal point for
updates to critical drawings and
documents, etc.

SN
13.3
13.4
13.4
.1
13.4
.2
13.4
.3
13.4
.4
13.4
.5
13.4
.6
13.4
.7

Protocol

Y / N / NA & Evidence

Possible approaches
Ask the PSEC.

Is there a schedule of Level 3 AI-PS


Verification for Element 13 MOC? And is
the schedule being followed?
Are MOC Registers available for the
following MOC Processes and do they
show current status:
Facility Change Proposals (FCP)

Refer to PR-1001a
Refer to PR-1001c

Temporary override of
safeguarding systems
Operations procedure temporary
variance
Asset abandonment and
restoration
Asset and (maintenance &
Inspection) activity registration and
deletion
Control of portable temporary
equipment
Other changes, e.g. critical
drawings and document
amendments, organisational
changes, etc.

Refer to PR-1001e
Refer to PR-1164 and PR-1419
Refer to PR-1344 and PR-1528

Refer to PR-1960
E.g. ask to see a register of the critical
drawings and documents currently being
updated.

AI-PSM Level 3 Management of Change Verification Checklist

Facility _________________________________________________________________
Change Description__________________________________

SN

Question

From the last 12 months, identify a completed


Process Change, or a Procedural or
Organisational Changes that has an AI-PS
impact.

Date____________

Change Ref.__________________________

Yes

No

Remarks

SN
13.1

13.2

13.3

13.4

13.5

13.6
13.7

Question

Is the asset MOC Process Owner aware of the


change?
E.g. for a change that should be covered by a
Facility Change Proposal (FCP), is the change
owned by the asset FCP coordinator?
Is the change recorded in the MOC Register
for the MOC Process?
E.g. for a change that should be covered by a
Facility Change Proposal (FCP), is the change
covered in the Facility Upgrade Management
System?
Has the MOC Request been reviewed to
identify hazards and assess AI-PS risk?
All process MOC Requests are expected to be
subject to a Hazard Screening and a HSE Risk
Review whether a formal HAZOP, a simple
Process Hazard Analysis or an even simpler
What If? analysis.
Was the selection of the HSE Risk Review(s)
methodology identified by a competent
person?
Was a Readiness Review completed prior to
going live to confirm that:
The change is installed and executed
as approved;
The Secondary Changes executed;
Competence requirements updated;
and
The change communicated to affected
staff and staff trained to use the
changed status.
Have all staff or contractors, affected by the
change been informed?
Was anyone affected by the change trained
and be deemed competent to work with the
change before it went live?

Yes

No

Remarks

SN
13.8

13.9

13.1
0

Question

Was a Readiness Review carried out prior to


Going Live, to verify that the change is
installed as approved and that the facility
and/or organisation was prepared for the
change?
(For closed MOC Requests): Are all of the
requirements of the implementation stage are
complete?
Was the MOC Request approved at the
appropriate level of the organisation?

Auditor overall comments

Yes

No

Remarks

Auditor Name________________ Signature _______________ Indicator


________________

Date_____________