MANAGEMENT OF CHANGE PURPOSE This standard describes es the the quali quality ty assura assurance nce (QA) (QA) and HSE HSE management of change (MOC) standard operating operating procedure procedure (SOP) describ process for identifyin identifying, g, assessing, assessing, managing, communi communicating, cating, and documenting documenting a permanent permanent or temporary temporary change. The MOC process process is design designed ed to prevent prevent inci inciden dents ts or losses losses by ident identif ifying ying and control controlli ling ng new or or altere altered d circumst circumstance ances, s, including including control control of quality, quality, health and safety safety hazards, hazards, security issues, and environmenta environmentall impacts.
Note
Definitions for terms and acronyms, which are presented in italics, can be found in the following hyperlinked documents: Ensign HSE Gloss Glossary ary of Terms and Acrony Acronyms ms and ISO 9000. 9000. Hyperlinks Hyperlinks to other documents documents associated with this SOP are found on the the HSE website. A user guide, overview, and forms are found in in the Global Risk Management System (GRMS).
ROLES AND RESPONSIBILITY Division: Departmental Vice President P resident The departmental vice president is responsible for the following: •
Support the general, area, or regional manager.
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Ensure the MOC procedure is used used in the department.
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Ensure resources are available for reviewing, approving, and implementing changes. changes.
Business Unit: General, Area, Area, or Regional Regional Manager The general, area, or regional manager is responsible for the following: •
Ensure the MOC procedure is effectively applied. This This includes working with the the Change Advisory Board (CAB) and monitoring the change improvement loop and all cr itical success factors.
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Chair CAB meetings. meetings. Convene the the members of CAB, and provide provide them with the necessary resources needed to review and approve changes.
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Approve all significant MOCs in their area of responsibility, and ensure all necessary reviews and approvals have been completed by CAB before implementation.
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Seek approval from the departmental vice president for significant MOCs that are outside their area of responsibility.
Operational Unit: Line Management Line management is responsible for the following:
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Implement the MOC process to ensure planned and unplanned changes are evaluated for control of quality, health and safety hazards, security issues, or environmental impacts and appropriate controls are put in place.
Employees and Contractor Employees Ensign employees and contractor employees are responsible for the following: •
Initiate the MOC process for changes, and report changes that may affect worker health or safety, the work area, or the environment .
HSE Representative The HSE representative is responsible for the following: •
Provide technical HSE support for implementing a change.
QA Representative The quality assurance representative is responsible for the following: •
Provide technical QA support for implementing a change.
Lead Process Owner The lead process owner is responsible for submitting the request for a change and implementing the change. The lead process owner is the person most closely associated with a particular change, and the lead process owner includes but is not limited to the following people: rig manager, maintenance supervisor, mechanic, electrician, driller, crane operator, project manager, engineering manager, department manager, or department specialist.
Management of Change Coordinator The MOC coordinator is responsible for the following: •
Administer the MOC process, and report to the business unit manager.
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Nominate the CAB chairperson (when applicable).
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Ensure all records and tasks associated with the MOC process are kept up to date (i.e., records, categorization, and reports about change metrics).
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Log, track, and distribute all change requests (CRs).
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Ensure all required document fields are completed in each stage of the MOC process, whether scheduled or unscheduled, and whether successful or not.
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Ensure all officially requested and proposed changes are processed according to this procedure and implemented according to the documented approval.
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Ensure all affected stakeholders are kept informed about the proposed change and receive the necessary documentation. -2-
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Verify that proposed or completed changes have no unforeseen or detrimental effects.
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Monitor and audit the implementation of the change.
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Categorize all changes for trend analysis using the following categories: –
Incidents
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Procedures
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Engineering
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Environmental
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Regulatory inspection
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Audit
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Corrective action
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Preventive action
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Review these changes at management review meetings to help set annual HSE goals or specific workplace goals.
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Carry out trend analyses of the proposed completion dates of approved changes.
Project Manager (PM) The selection of a project manager (PM) reflects the scale and nature of the proposed change and the project approval process. PMs can be the initiator of the MOC process or nominated by the approver. The PM is responsible for the following: •
Ensure the smooth implementation of the proposed change.
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Establish a set of clear objectives for the proposed change for senior management approval.
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Obtain a commitment to the change project from stakeholders affected by the change.
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Consult with other departments and staff affected by the change.
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Approve the evaluation criteria and method for assessing the proposed change, and ensure the assessment is completed in a timely fashion.
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Determine the appropriate level of detail to be included on the Corrective and Preventative Action (CAPA) form, and ensure the CAPA is developed in a timely fashion.
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Implement the change process effectively in order to achieve agreed-upon objectives. When applicable, coordinate a Pre-Startup Safety Review (PSSR).
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On significant MOCs, complete an After-Action Item Review with stakeholders.
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Provide and ensure all applicable documents are uploaded to GRMS, and close out the MOC.
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Change Advisory Board (CAB) CAB is used when there are multiple stakeholders who need to be part of the MOC review and approval process. A CAB includes but is not limited to representatives from manufacturing, engineering, maintenance, QA, HSE, operations, and human resources, and it is responsible for the following: •
Ensure the effective application of the MOC process, including monitoring each stage of the process to identify and resolve issues and remove bottlenecks.
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Ensure there is a representative from all the primary groups that may be affected by proposed significant changes.
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Review MOCs, and provide an assessment of the expected business, technical, and operational risks associated with the change.
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Provide feedback to the PM and appropriate manager about the implementation schedule to ensure all undesired interactions of the proposed change are minimized.
PROCEDURE There are eight steps in the Ensign MOC process.
Change Request Phase
Implementation Phase
Step 1: Identify the Need for a Change and Propose the Change
Identify the need for a change and submit a change request that requires a formal MOC evaluation. Document and record the MOC details on the MOC form found on the GRMS website. An MOC user guide and a MOC Process Overview are found on the GRMS website, and specific guidance for each division is provided in the MOC Trigger Guide.
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The MOC process can be used for all planned and unplanned changes, other than real-time troubleshooting. Examples of when an MOC is required include but are not limited to the following: •
Customer request for an MOC investigation
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Unplanned changes to the following:
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Personnel, training requirements, and competency standards
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Operating conditions and environment
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Technology, materials and metallurgy, and equipment, including process chemicals and maintenance equipment
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Deviations to the following:
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Customer/operator procedure or well program
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Standard operating procedure (SOP) or safe work procedure
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Government regulations
As a result of an Ensign stop work order or JSA (job safety analysis) review
To ensure the safety of personnel and eliminate or reduce the potential for an environmental incident, Ensign employees will default to the MOC process when it is unclear if it is required.
A formal MOC evaluation is usually not required for changes in kind (i.e., like for like). Examples of when an MOC is not required include but are not limited to the following:
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Equipment that has the same technical specifications
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Operating procedures that align with approved operating practices
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Minor operational changes in the customer-approved scope of work
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Minor variations to mud weight and bottom hole assemblies
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Conventional fishing activities
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Bit selection
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In kind planned personnel changes
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In kind replacements
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Emergencies (e.g., well control)
Upload applicable or supporting attachments (e.g., photos) to the MOC form on the GRMS website. Submit the MOC form to the business unit’s MOC coordinator.
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Step 2: Approve to Initiate an MOC Review The MOC coordinator receives the change request and reviews and edits it before assigning it to a project manager (PM). Each business unit has a designated MOC coordinator. The PM position is not permanently assigned to one person, which enables the MOC coordinator to select the appropriate person for each change request. An MOC coordinator can reject a change request and send it back to the initiator for further clarification. If a change request is rejected, it is mandatory for the MOC coordinator to provide a reason for the rejection. This reason will be documented on the form history tab. Note
A change request can be cancelled during this step or at any point after an approval. If there is a cancellation, it is mandatory to provide a reason for the cancellation. This reason will be documented on the form history tab.
Step 3: Impact Analysis The PM must identify all stakeholders affected by the change and obtain their input about the project. Stakeholders must review government regulations, company procedures, and industry standards to ensure the change complies with any applicable regulations, procedures, and standards. The PM must ensure the lead process owner and subject matter experts (SME) complete a Hazard Identification Checklist and risk assessment (minimum requirement is a JSA ) to identify all hazards and potential control measures. The PM must also request costing from the applicable engineering or maintenance department or vendor.
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High risks must be analyzed using a safety risk assessment procedure such as a Failure Modes and Effects Analysis (FMEA) or Hazard and Operability Study (HAZOP).
Each SME will upload any relevant documents to the MOC form on the GRMS website, and the PM will upload the CAB meeting minutes and decisions to the MOC form on the GRMS website.
Step 4: Stakeholder Reviews Stakeholders must review the change request and upload their documentation, comments, and recommendations to the MOC form on the GRMS website. Stakeholders can, when necessary, add CAPAs to the MOC form.
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When there are disagreements or unacceptable risks are identified by the stakeholder review, the PM will request a formal CAB review. The CAB review ensures all issues are analyzed and the best course of action is forwarded for approval.
Step 5: Approval The final approval workflow is specific to each business unit. The MOC coordinator or PM can appoint additional second approvers. The approver(s) reviews the impact investigation, stakeholder reviews, and the proposed change.
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When applicable, financial approvals occur at the same time as the approval of the change.
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Appropriate approvers approve the change electronically in GRMS. When an MOC investigation reveals the change will directly impact a customer, approval from the customer must be obtained before implementing the proposed control measures. Customers do not have access to GRMS; therefore, Ensign sales staff or the local manager must inform the customer about the change and obtain their approval. Proof of approval must be documented and uploaded onto the GRMS website.
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GRMS notifies all stakeholders and the PM when the change is approved. When applicable, a Materials and Service Requisition (MR) form, purchase order (PO), and asset tracking form must be initiated and finalized.
Step 6: Implement the Change Implement the change, and ensure all control measures are adequate:
The PM assigns a CAPA or multi-CAPAs for the change.
CAPAs includes all the documentation needed for full implementation: –
Assigns a person of authority to conduct a PSSR (a final check) before accepting the change.
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Assigns a preventative maintenance program in other systems (e.g., Equipment Asset Management [EAM]).
Inform personnel about the change.
Provide training when applicable.
Monitor implementation to ensure responses to the change are completed and effective.
Step 7: Awaiting Closure Awaiting Closure status is achieved when a change has been approved to be implemented. When multiple assets are involved in the change, the change will remain in progress until it has been implemented successfully (e.g., issues identified by the PSSR are resolved) and evaluated for effectiveness. An After-Action Item Review must be completed when an impact investigation finds that a change still has a medium or high level of risk. The After-Action Item Review must be completed for the following reasons: •
Evaluate the effectiveness of the implemented control measures
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Identify lessons learned to improve the MOC process
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Step 8: Close the MOC Process The MOC process is ready for closure when a significant number of CAPAs have been completed and the project has been evaluated for effectiveness. All documentation related to the MOC process must be stored in the MOC form on the GRMS website. In addition, final documented customer approval must be obtained if applicable.
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CAPAs have their own workflow; therefore , projects with active and inactive operational units will be tracked to closure by the GRMS CAPA system.
The following must be completed for temporary changes:
The change must be reviewed within 60 days.
Renewal approvals must be conducted by the next manager above the original approver.
A maximum of two renewals are allowed per change. A temporary change will be considered permanent after the second renewal, and the MOC process will be considered closed. A new change request will need to be issued for future changes.
RESOURCES
API E & P. (December 2008). Onshore operations safety handbook .
Global Risk Management System.
International Association of Drilling Contractors (IADC). (July 2009). Health, Safety, and Environment Case Guidelines for Land Drilling Contractors , Issue 1.0.1. Oil and Gas Producers (OGP). Guidelines for the development and application of health, safety, and environmental management systems (Report No. 6.36/210).
FORMS AND RECORDS
After-Action Item Review form
Job Safety Analysis (JSA) form
Management of Change form
WORK INSTRUCTIONS
Management of Change (MOC) User Guide Management of Change Process Overview
TRAINING
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Training must be provided at the frequency e stablished by Ensign. This training must address the following:
MOC awareness
MOC Trigger Guide
MOC approver and end user
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