SEMS Element 4 – Management of Change

Recognizing the need to initiate a Management of change (MOC) process is vital to implementing not only day to day changes, but also to implement corrective actions as a result of your audit process. This is why I recommend initiating a MOC process for your MOC process sooner rather than later. The previous SEMSinar™ 13 blogs have, in part, prepared your organization for the development of a well-designed MOC process.

30CFR 250.1912(a) states that an MOC process must be initiated for the following reasons:

§ 250.1912   What criteria for management of change must my SEMS program meet?

a) You must develop and implement written management of change procedures for modifications associated with the following:

(1) Equipment,

(2) Operating procedures,

(3) Personnel changes (including contractors),

(4) Materials, and

(5) Operating conditions.

The API RP 75, which is the basis for the Subpart S BSEE SEMS regulations, states all changes may have the potential for disruption, injury, or loss of business and should be managed through a MOC program. Including minor changes with little likelihood of compromising safety or environmental protection. Section 4 of the API RP 75 covers quite a number of items that require a MOC process be initiated.

1)       Technical Innovations

2)       Mechanical Improvements

3)       Temporary Repairs, connections,  and bypasses (Piping or Hoses)

4)       Changes in Produced Fluids, process additives, product specifications, by-products, waste products, design inventories, instrumentation and control systems, construction materials

5)       Construction of new production or process facilities

6)       Production or process tie-Ins, equipment reconfiguration or modification

7)       Changes to facility or equipment design, structural support, layout or configuration

8)       Production increase projects or change in produced fluids

9)       Changes in operating conditions (pressures, temperatures, flow rates)

10)   Equipment changes (New, modified) including alarms, instrumentation, and control schemes

11)   Process or equipment modifications which cause changes in pressure relief system requirements

12)   Bypass connections

13)   Operating outside normal operating parameters (Start-up, Normal Shutdown, Emergency Shutdown)

14)   Changes required as a result of a hazard analysis

15)   Introduction of new or modified process chemicals (corrosion control agents, anti-foulants, anti-foam agents), drilling muds or workover/ completion fluids

16)   Temporary electrical equipment or utility connections

17)   Modifications to drilling diverter systems that have not been previously approved

18)   Modifications to BOPs that have not been previously approved

19)   Modifications to drilling top drives that have not been previously approved

Section 4.3 of the API RP 75 relates to personnel changes as is also addressed by item #3 from 30CFR 250.1912(a)(3). This requirement includes substitution/ replacement of personnel, changes in management and even position vacancies. NTL2011-N09 goes on to clarify that company mergers and acquisitions are required to have a MOC process initiated. However, a MOC process is not required for a 12 hour crew rotation or a shift rotation of 7, 14 or 21 days. The process is also not required when replacing equipment with another piece of equipment of like kind. So if the replacement equipment has the same operating characteristics as the original piece of equipment, including the manufacturer, then no MOC process is required.

I feel that you should start refining your MOC program now before your BSEE audit identifies all of those opportunities for improvement (non-conformities). If you don’t have a ‘well oiled’ MOC program in place when your BSEE audit is completed, you will have much difficulty in successfully implementing all of those opportunities for improvement.