CP-122 HSE Code of Practice - PDO

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Establish and maintain documented Management Of Change Procedures to cover permanent changes, temporary changes, and emergency changes, which: Define Change Approval Authorities and communicate who they are. Describe the stages in the Management Of Change process and approval steps: - review and approval of the concept or proposal, - review and approval of the design or plan, including Hazard screening and Risk analysis, - review and approval of any scope or design changes arising during the work, - readiness review, handover, and acceptance for use, and - close-out and learning capture. Inform and train the people affected by the change about what they have to do differently. Manage Temporary Changes, including expiry dates and approval for extensions. Manage Emergency Changes, including authorization to postpone the MOC process until control is regained. Track the development and progress of change proposals from initiation to closeout. In the MOC process, it is important to recognize that all changes have a “source.” These sources are many and can include: Corporate requirement Budgetary / financial needs Engineering modification Operational needs and expenditures Accidents / incidents / emergencies Competency gap Hazard identification and risk assessments Strategy / policy / objective change Merger / Acquisition / Divestment Legislation / regulations Recognized need to improve Capital expenditure project External influence Inspection / audit / assessment findings Inadequate systems, procedures, processes, practices Opportunity analysis Problem solving results Anything deemed as “new” and required by PDO. The change source and the request to make the change, if approved, then requires careful planning. The major outcome of this activity should be a documented, risk-based “Change Plan.” At PDO, the relevant management of change procedure(s) used should include requirements for preparing change plans and control the process up to this stage. These procedures should be suitable to address the HSE issues involved, according to the nature of the changes and their potential consequences, and should deliver change information addressing: Identification and formal approval of the proposed change, Documentation of the proposed change and its implementation for its entire life cycle, guaranteeing sufficient traceability and history of the change over time, Responsibility and accountability for reviewing and recording the potential HSE hazards from the change and its implementation for its entire life cycle, A documented Change Plan, including change communication requirements and change goals, objectives, and targets for action tracking, verification, and close-out. July 2011 Page 44
HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual In PDO HSE-MS Process 6, Implementation and Operation, general requirements for implementation of the change is presented. 5.3.6 Technical Integrity Technical Integrity and management of HSE risks are closely linked. Maintaining Technical Integrity is a key element of Process Safety Management, the overall PDO HSE-MS, and is a major control mechanism to prevent and mitigate loss of containment and high risk process hazards (i.e., those with Severity 5 in the PDO RAM). PDO has chosen to align and measure its process safety management system and activities, including technical integrity, with The Center for Chemical Process Safety (CCPS) and their 20 Elements for Process Safety. These elements include, 1) Process Safety Culture; 2) Compliance with Standards; 3) Process Safety Competency; 4) Workforce Involvement; 5) Stakeholder Outreach; 6) Process Knowledge Management; 7) Hazards Identification and Risk Analysis (Renamed by PDO as Hazards and Effects Management Process - HEMP); 8) Operating Procedures (Renamed by PDO as Plant Operating Procedures); 9) Safe Work Practices (Renamed by PDO as Permit to Work); 10) Asset Integrity and Reliability (Renamed by PDO as Technical Integrity); 11) Contractor Management; 12) Training and Performance Assurance; 13) Management of Change; 14) Operational Readiness; 15) Conduct of Operations; 16) Emergency Management; 17) Incident Investigations; 18) Measurement and Metrics; 19) Auditing; 20) Management Review and Continuous Improvement. These Elements are embedded in the overall PDO HSE-MS and address Process Safety as and where relevant to PDO operations, assets, and activities. PDO has developed various types of documentation (Codes of Practice, Procedures, Specifications, Guidelines, etc.) to address Technical Integrity, and these are listed in the References section of this process chapter and others as relevant. The PDO Technical Integrity system addresses areas such as design integrity, start-up, operating integrity, structural integrity, process containment, ignition control, and systems for protection, detection, shutdown, emergency response, and life saving. This system ensures that HSE critical facilities and equipment which are designed, constructed, procured, supplied, commissioned, operated, maintained, and/or inspected by PDO are suitable for their required purpose and comply with defined criteria. Only designated personnel can permit deviation(s) from approved technical integrity design practices and standards, and after a rigorous review and approval process, using the Management of Change process and relevant procedure(s). This is shown in the barrier diagram below. July 2011 Page 45
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CP-122 HSE Code of Practice - PDO

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