Guidelines for Management of Change

IMCA HSS001 Rev. 1.2

May 2024
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IMCA HSS001 Rev. 1.2

Document designation: This document is categorised as Recommended Practice

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Version History
Date Reason Revision
January 2024 Document QA check – preface and layout updated; no change to content Rev. 1.2
July 2020 Minor amendments made Rev. 1.1
February 2017 To include more material and detail Rev. 1
April 1999 Initial publication as S&L 001
Guidelines for Management of Change

Table of Contents

1 Introduction ...............................................................................................................4
1.1 Objectives of the Management of Change Process .............................................................4
2 Glossary .....................................................................................................................5
3 Managing Change – Which Changes May Occur?.........................................................6
3.1 Reasons for a Change...........................................................................................................6
3.2 Technical Change .................................................................................................................6
3.3 Organisational Change .........................................................................................................7
3.4 Operational Change .............................................................................................................7
3.5 Environmental Change.........................................................................................................7
3.6 Regulatory or Policy Change ................................................................................................8
4 Management of Change – Responsibilities ..................................................................9
4.1 Changes in Management System Documents .....................................................................9
4.2 Changes to Equipment .........................................................................................................9
4.3 Changes in Project Scope during the Preparation Phase of a Project ...............................10
4.4 Changes during the Execution of the Work .......................................................................11
4.5 Appointed Responsible Manager (of Change) ...................................................................11
5 The Management of Change Process ........................................................................ 12
5.1 Identifying the Requirement for Change ...........................................................................12
5.2 Assess Impact of Change ...................................................................................................12
5.3 Validate Change Actions and Approve ..............................................................................13
5.3.1 Set Up Management of Change Procedure ..........................................................14
5.4 Plan Change .......................................................................................................................14
5.5 Implement Change.............................................................................................................15
5.6 Record Change ...................................................................................................................15
5.7 Tracking and Verification of Change Actions .....................................................................15
5.8 Restore Original Situation ..................................................................................................15
5.9 Lessons Learnt ...................................................................................................................16
6 Change Request Form............................................................................................... 17
7 Change Register ....................................................................................................... 18
Appendix 1 – First Evaluation Scenarios ........................................................................... 19
Appendix 2 – Sample Change Request Form (CRF) ............................................................ 20
Appendix 3 – A Typical Management of Change Flow Diagram ......................................... 23

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 Guidelines for Management of Change

1 Introduction

Experience has shown that major incidents have occurred when changes have been made to
procedures, equipment, activity, approved practice, organisational structure, or personnel without
proper evaluation of the potential impact of those changes. Failure to identify and manage significant
change may compromise safe and efficient operations. Operational changes of all kinds may pose a
hazard and increase risk exposure, requiring a reassessment of control measures to maintain
acceptable levels of safety, to prevent equipment damage, and to prevent or limit environmental and
health impacts.

Management of Change (MoC) is the process by which potential changes, both permanent and
temporary, are analysed, their likely effects reviewed, consequences mitigated, and their
implementation executed and communicated. Effective MoC is essential to ensure that hazards and
risk arising from change are dealt with properly.

IMCA has developed the following guidance for MoC, covering how to manage operations which
deviate from the original execution plan in a systematic and effective way, and providing assistance
for members in the requirements for the application of a formal MoC process.

It is envisaged that this guidance may be applied to the management and documentation of:
 technical change to equipment and infrastructure, engineering and/or design
 organisational change to team structures, competence and crewing
 operational change to the way equipment is operated, to work methods and/or agreed
practices
 environmental changes, e.g. to tides, sea conditions or weather.

This more comprehensive guidance on this vital topic replaces IMCA S&L 001 – Guidance for the
management of change in the offshore environment, first published in 1999. The document underwent
further scheduled review and minor revision in 2017 and 2020.

1.1 Objectives of the Management of Change Process

Risks may arise when changes occur. Failure to identify and manage changes in a timely way
may compromise health, safety, environment, operability, schedule, costs and reputation. To
minimise risks, changes should be identified, analysed, reviewed and managed. Personnel
should be appropriately trained in their respective roles and in management of change.
Procedures for managing change should be documented, communicated and periodically
reviewed and updated. The objectives of an MoC procedure are to:
 provide a systematic process to identify, evaluate, approve, notify, implement and
monitor changes
 prevent changes that may threaten the achievement of company goals or project
objectives
 permit changes that add value to the company, its assets or projects
 identify responsibilities for review and approval of proposed changes
 define change approval criteria and authorities
 establish a register to track and document change requests (CRs)
 restore original situation in case of temporary changes.

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Guidelines for Management of Change

2 Glossary

Several specialised terms are used in this document. It is assumed that readers are familiar with most
of them – however, whilst they have been in use for many years, they could potentially be
misunderstood. For clarity, these terms are defined below to ensure that readers understand what is
meant by them in this document.

CR Change Request

CRF Change Request Form

ERP Enterprise Resource Planning

FMEA Failure Modes and Effects Analysis

FMECA Failure Modes, Effects and Criticality Analysis

HSE Health, Safety and Environment

IMCA International Marine Contractors Association

JRA Job Risk Analysis

JSA Job Safety Analysis

MoC Management of Change

OEM Original Equipment Manufacturer

Originator The person who proposes the change, which could be anybody in the
company

QA Quality Assurance

Responsible person(s) The person(s) responsible for the implementation of the change

SIMOPS Simultaneous Operations

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 Guidelines for Management of Change

3 Managing Change – Which Changes May Occur?

A change is a substitution, alteration, or variation. Change can, and often does, occur in almost
everything we do. Changes may be instigated by our own personnel, contractors, or clients for a variety
of reasons. Change can also occur over time without immediate recognition and can be complex in
nature.

Changes can be categorised as:

 technical
 organisational
 operational
 environmental
 regulatory or policy.

3.1 Reasons for a Change

There may be many different reasons that necessitate change. Some examples are:
 change of legislation, industry good practice, or codes and standards
 additional or revised scope of work by a client
 a change of a work location
 change to environmental conditions beyond existing, agreed, or acceptable limits
 change to the sequence of work scope
 late deliveries
 required modification to project installation aids
 unexpected equipment breakdown, requiring replacement
 changes to personnel assignments
 technological developments.

3.2 Technical Change

A technical change is a change to any item of plant or equipment. The change may be a result
of:
 alteration to the original or subsequent design basis
 alteration that is inconsistent with the original design or design intent
 a replacement of parts with parts of non-original or different specification or those not
manufactured by the original equipment manufacturer (OEM)
 alteration of the operation of plant or equipment differing from the manufacturer’s
recommendations or design parameters
 change of the rigging parameters for equipment differing from the original design
requirements

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Guidelines for Management of Change

 changes to any safety system, limit, alarm, indicator, or other element within such
context
 alteration of the integrity of a plant and/or piece of equipment as a result of wear and
tear, corrosion or any other deterioration
 the addition of new technology to original equipment configuration.

(Note: Any alterations could also be temporary ones.)

3.3 Organisational Change

An organisational change involves a change to the organisational structure, either corporate-

or project-related, and may include:
 change to the roles and responsibilities of personnel
 change to reporting lines and/or communication lines
 change to roles critical to safety, health, environment or quality
 ‘bridging’ of management system elements when different organisations work together
 changes in organisational interfaces between parties – for example, between the
company and its (sub)contractors, client, authorities or any other stakeholders
 changes in information systems/key software/ERP systems/reporting systems.

3.4 Operational Change

An operational change involves a change to operational practices of (for example) a vessel and
its equipment, and may include changes to:
 work methods
 change to the corporate or project management processes, procedures or standards
 transport or installation sequence
 equipment operating procedures
 voyage planning
 changes in planned simultaneous operations.

3.5 Environmental Change

An environmental change involves a change beyond existing agreed or acceptable limits in the
conditions under which the work is being executed. This may include significant changes in:
 climate – e.g. cold, heat, dry, wet, snow, ice
 weather – e.g. wind, rain, snow, fog
 air – e.g. dust, smell
 sea state – e.g. currents/tides, waves, swell
 seafloor – e.g. profile, rock, sand, mud.

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 Guidelines for Management of Change

3.6 Regulatory or Policy Change

A regulatory change involves change to the regulatory or statutory regime under which the
work is being executed, or changes to company policy, and may include significant changes in:
 operating parameters resulting from changes to regulatory requirements
 operating procedures resulting from changes to company policy and protocols
 security policy arising from a change to the security threat level affecting resources and
procedures.

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Guidelines for Management of Change

4 Management of Change – Responsibilities

It should be the responsibility of everyone at work to bring any significant change to the attention of
supervisors, managers, or persons in charge and, at times, receive formal approval of the change.
Formal responsibilities for MoC should be identified and documented. However, these responsibilities
will often depend upon:
 organisational structure
 type of change
 where and when the change will take place.

When an organisation prepares procedures for managing change, criteria should be specified, which
can be used by personnel at all levels to evaluate, identify and request a change.

The following sections give a number of examples.

4.1 Changes in Management System Documents

Changes in management system documents might include changes to company procedures or

work instructions. Roles and responsibilities in this process are often clear and outlined in
existing company procedures.

The following roles could be involved:

 quality assurance (QA) manager, ensuring compliance with quality policies and
standards (depending on the subject, the discipline manager could be the QA manager,
HSE manager or QHSE manager)
 safety professionals, ensuring compliance with health, safety & environment policies
and standards, and ensuring that risk assessments have been conducted as required
 technical discipline manager(s), often the owner(s) of the processes involved, ensuring
that the change is correctly reflected in the relevant documentation and that the change
is correctly implemented, e.g.:
− communication of the change to relevant personnel
− verification that the change is being fully understood
− verification that action required for full implementation of the change has been
taken.

Changes to management system documents not including alteration of company procedures

or work instructions may be managed via a document control system.

4.2 Changes to Equipment

The reasons for changes to equipment could be replacement, modernisation, capacity

upgrade, etc. There may be project-related schedules and processes (procedures, work
instructions) in place which may influence how, when, and by whom any changes to
equipment are made.

Changes that include non-Original Equipment Manufacturer (OEM) parts or equipment must
be assessed in detail to ensure safe, reliable operations and ensure warranties are maintained.

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 Guidelines for Management of Change

The following roles could be involved:

 asset manager
 equipment manager
 operations manager
 technical experts (structural, mechanical, electrical, systems control, etc.)
 location manager – e.g. a plant, yard, or offshore unit
 purchasing manager
 QA manager
 safety (HSE) manager.

All roles listed above have defined responsibilities for ensuring that change takes place in a
safe way and that reliable and safe operations continue.

4.3 Changes in Project Scope during the Preparation Phase of a Project

There could be many reasons for this type of change, but it often relates to changes in client
requirements or to regulatory changes. As with changes to equipment, changes to the project
scope need to fit into the project schedule. There may be a project-level MoC process in place
to control when, how and by whom, any actions are taken. Also, a client verification process
may also be in place, or changes may require client approval.

The following roles could be involved:

 project manager, ensuring:
− good understanding of the required change and managing the change process in
the project team
− compliance with quality policies and standards (in consultation with the QA
manager)
− compliance with health, safety and environment (HSE) policies and standards, and
risk assessments have been or will be conducted as required.
 project engineer, covering the engineering aspects of the change and ensuring that the
change is correctly incorporated in work manuals
 onshore management
 technical authorities and subject matter experts
 offshore management team, including offshore construction manager
 vessel management (captain, chief engineer, chief officer)
 offshore client representative
 original requester.

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Guidelines for Management of Change

4.4 Changes during the Execution of the Work

Required changes during the execution phase of a project are often of an operational nature.
Examples could include:
 breakdown of critical equipment
 last minute discovery of non-conformances requiring correction
 late deliveries necessitating changes in activity sequence.

A characteristic of this type of change is that it is unexpected and there is a significant element
of time pressure. The issue must be resolved on the spot. A possible example might be a late
request by the offshore client representative, resulting in additional costs or standby time,
which the client later disputes – as being uninvolved in the MoC process.

It is important in these circumstances to give particular attention to ensuring that HSE risk
levels remain within acceptable limits.

The following roles could be involved:

 vessel master
 offshore construction manager or superintendent
 offshore client representative
 chief engineer
 field engineer
 project manager
 work supervisors and foremen
 vessel safety officer.

4.5 Appointed Responsible Manager (of Change)

MoC procedure should be clear about who should be responsible for managing a particular
change. Depending on the type of change this could be a discipline manager, project manager,
asset manager or other person in the company.

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5 The Management of Change Process

5.1 Identifying the Requirement for Change

The MoC process starts when a problem or opportunity requiring a change is identified by
somebody (hereafter called the originator). The identified change might be deviation from
approved procedure, or a technical modification to equipment, systems or assets, or it might
be changes to personnel required to complete a task or project safely.

The originator should be ready to provide justification for the requirement, including an
estimated scope of work including cost and schedule if applicable. Also, the originator should
be ready to identify:
 whether or not a stop the job is required
 does the work site need to be made safe whilst the MoC is raised and dealt with?
 sufficient detail of the proposed change to allow a good assessment to be made
 if the change is temporary or permanent
 what are some of the possible consequences?

The next step is for the originator to discuss this potential change with their supervisor who
should assess the possible impact of the change and advise on the follow up.

5.2 Assess Impact of Change

Appropriate supporting information should be collected to support the risk assessment and
decision-making process. The originator, their immediate supervisor and onboard
management (as required) might then conduct a thorough assessment of the change scope. It
is important to assess all the possible outcomes of the task with the change implemented,
identifying any possible consequences of the proposed change.

Additionally, it is important to assess the physical implementation of the proposed change.

For example, it might be that the approved rigging arrangement is not suitable for the task.
The task of removing the existing arrangement and fitting alternative rigging should also be
assessed. Both elements should be considered in the MoC risk assessment.

This discussion should include:

 impact of the proposed change on all associated personnel, systems, equipment,
processes, and procedures; the following criteria may prove useful:
− low risk – the consequences of the proposed change do not introduce additional
risk to personnel, environment, or equipment; in this case, it may be appropriate for
the change to be authorised by onsite management
− medium risk – the consequences of the proposed change increases risk to
personnel, environment, or equipment, or introduces significant impact on other
operations; in such cases, it may be that the MoC should be authorised onshore
− high risk – the consequences of the proposed change impose an intolerable further
risk to personnel or environment; before proceeding further, this risk should be
mitigated further or the activity/task cancelled
 how critical or important is the proposed change

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Guidelines for Management of Change

 risk assessment:
− possible cumulative effect of multiple MoC processes
− consequences on any SIMOPS ongoing
− possible consequences of implementing and/or not implementing the change
− possible impact on crew/personnel.
 whether or not there are further training requirements.

The results of that initial assessment could be:

 a decision that change is not required or not safely achievable
 the change can be made without further assessments required
 submit the formal MoC request and impact assessment and refer to the appointed
change manager.

5.3 Validate Change Actions and Approve

The originator, in conjunction with their supervisor, should collect all the relevant information
and report to the appointed change manager. At this stage, the process may still be handled
by offshore or vessel-based management. The proposed change should be discussed with
representatives of all the technical disciplines involved, and a first evaluation should take
place. This consultation or discussion of potential change may take a variety of forms and
follow a number of stages.

It is important to have an understanding of the criticality of the proposed change. Even small
or seemingly insignificant changes can have a major impact, so consultation may have to
involve a wide range of personnel with the experience, knowledge and authority required to
judge:
 the validity of the change request – by reviewing the proposed modification scope and
identified consequences
 how the change can be most safely implemented
 operational impact
 how the change can be made most effective
 any required changes to training or competency
 budget impact.

If the criticality or importance of the change is high enough, then the change request may
need to be sent ashore to more senior management for approval, rather being approved by
the offshore management team.

In some cases, this consultation may result in the decision that change is not required or is not
safely possible. The affected areas and processes should be determined (e.g. health, safety,
security, environment, costs, or schedule). Such evaluations should preferably be
documented.

Appendix 1 gives some case studies of possible change scenarios and how evaluation of the
change could take place.

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 Guidelines for Management of Change

The outcome could be:

 change proposal and formal MoC process to be approved and handled offshore
 change proposal and formal MoC process to be approved and handled by more senior
management ashore
 change rejected, after which the reason for rejection should be fed back to the
originator.

Whether the change is approved or rejected, it will be necessary to ensure that the
appropriate people are informed.

Please see Appendix 2 for a sample Change Request Form (CRF).

The following should normally be considered as a minimum, depending on the type of change
and the actual circumstances in which the change would take place.
 Hazard identification and risk assessment – identify items or areas affected by the
change under consideration.
− Use appropriate risk assessment tools and techniques to determine the potential
impacts of a proposed change, e.g. perform a hazard identification study or job
safety analysis (JSA).
 Development or revision of control measures – determine appropriate measures with
which to manage the assessed risk.
− This may include revised procedures or plans, equipment modifications and staff
training.
 Approvals and authorisation of change – with reference to the management system
within your organisation, ensure that change is sanctioned by personnel with relevant
experience, authority and accountability.
 Communication and implementation of approved activities/procedures – take practical
steps to create awareness, build support, promote participation and ensure compliance
with approved changes by all relevant personnel.

5.3.1 Set Up Management of Change Procedure

The MoC procedure should be documented and should reflect the specifics of the
organisation. For a good understanding of the process visually, a flow diagram could
be helpful.

Refer to Appendix 3 for a typical MoC flow diagram.

5.4 Plan Change

The planning should identify prerequisites and deliverables required as a result of

implementing the change, and specify when the deliverables are required, before, during and
after the change. There should be a clear understanding of the budget, resource, and schedule
requirements for the proposed change. Quality assurance and measures and documentation
requirements should be verified. At this stage, a suitable and sufficient job risk assessment
(JRA) should take place.

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5.5 Implement Change

It is important that any changes carried out are in accordance with the approved plan. Ensure
that all affected personnel are advised of any working restrictions that are to be applied during
the time of change.

Take care to ensure that any training and familiarisation takes place in good time.

5.6 Record Change

All associated records and supporting information should be updated. This could include:
 drawings
 certification
 operating procedures
 maintenance records
 asset registers
 vessel specification and maintenance requirements
 operational and critical spares inventories
 FMEA/FMECA (where appropriate)
 changes to training and competence requirements
 personnel assessment reports and certification.

It may be appropriate to ensure that hard copies of some of this information is available at the
work site or on the vessel.

5.7 Tracking and Verification of Change Actions

Following the change, care should be taken to ensure that the change or modification was
implemented in accordance with the agreed plan and that the change achieves its objectives.
This is an important part of the Management of Change process and can often be forgotten.
It is particularly important to check the following:
 Do all affected systems and equipment operate within performance requirements and
specification?
 Have all deliverables and documentation been received, reviewed, and filed
appropriately?

5.8 Restore Original Situation

In case of a temporary change, the original situation should be restored in a controlled

manner:
 cancellation of temporary controls
 verification
 communication.

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5.9 Lessons Learnt

Lessons learnt from the whole Management of Change process should be shared appropriately
to those who would benefit. Particular consideration should be given as to whether or not the
same change or modification is required elsewhere.

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6 Change Request Form

Refer to Appendix 2 for a typical example of a CR form.

The adopted form should be company specific with reference to the corresponding company MoC
procedure.

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7 Change Register

Proposed changes should be administered in a dedicated register that could include information
regarding:
 change request (CR):
− originator
− change manager.
 the status of evaluations
 decision; and in case of implementation:
− responsible person(s)
− tracking of required actions.
 close out.

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Appendix 1 – First Evaluation Scenarios

Scenario First Evaluation Outcome
Late delivery of vendor supplied The installation method will This needs to be managed
items has an impact on the require redesign and rewriting of according to the formal MoC
installation sequence plan. several installation procedures. procedure.
There could be both commercial
and HSE risks.
The customer requested the This change does not alter escape No further formal MoC required.
relocation of personnel escape routes or conflict other structures Impact to the construction
capsules on a platform being as defined in the general sequence is clear. General
designed. arrangement. Functionality of the arrangement drawing can be
Engineering was requested to capsule remains the same. No changed. Details can be worked
review change proposal. commercial impacts foreseen as out during further design.
detailed designs were not yet
made.
The customer requires another The paint was ordered but for the No further formal MoC required.
colour for painting some structures. vendor it was no problem to deliver Purchase order can be changed.
another colour.
Just prior to mobilisation of a This could have an impact on the This should be managed according
marine installation spread, revised physical and administrative to the formal MoC procedure.
vessel importation and clearance requirements for clearing in the
regulations were issued by the vessel and the time this will take.
country in which the work was to be If it takes longer then there could be
carried out. a potential impact to the offshore
schedule with significant cost
impact.
A winch used for installation works The word perhaps already indicates This should be managed according
offshore breaks down. It is perhaps the outcome of this evaluation. A to the formal MoC procedure.
possible to use another one. rerouting of winch wires over the
deck is required. Is that safe? Can it
be made safe and efficient? Is it all
strong enough? Is the wire in good
condition?
A closed diving bell’s internal This can have an impact on the This should be managed according
pipework needs to be replumbed divers’ ability to locate and isolate to the formal MoC procedure.
to accommodate relocation of valves during an emergency in the
electrical equipment. bell, particularly if visibility in the
bell is hindered.

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Appendix 2 – Sample Change Request Form (CRF)

Change title
CRF no. Vessel or project Date

Requestor name Job title

Project no. Worksite
Project name Client
Change effective Change
from effective until
Original situation Yes ☐ No ☐
restored (yes/no)

1.0 Requirement for change

State the description of change and the reasons why

Project Change ☐ Company Change ☒ Category Choose an item.

Permanent ☐ Contingency/Temporary ☐

Please add:
Change effective from:…
Change effective until:…
Original situation restored: yes/no

1.1 Affected documentation

List all documentation affected by this change

2.0 Change plan

Detailed description of how the proposed change will be implemented
Attach supporting information

3.0 Assess impact of change

CRF risk assessment number
Consequences of the change risk assessed Yes ☐
Implementation of the change risk assessed Yes ☐

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3.1 Change impacts

Personnel ☐ Equipment/system capability ☐ Interfacing procedures ☐
Resources ☐ Emergency/contingency procedures ☐ Sequence of events ☐
SIMOPS ☐ Existing MOCs ☐ Schedule _______hrs ☐
Others Cost _______ ☐

3.2 Onboard departments affected

Summary of impacts Existing MoCs affected (if any)

Change criticality
Low 1-8 ☐
Medium 16-32 ☐
High 64-256 ☐

Project discipline experts consulted (if required) Technical authorities consulted (if required)

Other Other

4.0 Approval (* where appropriate/ ** if risk is medium or high)

Job title Name Approval Signature
Requestor
Master
Chief Engineer
OCM
Client Rep
Third Parties
Onshore Manager
(delete as appropriate)

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5.0 Implement change

6.0 Records and deliverables

List documentation updated and/or received relating to the change.

7.0 Completion and verification

Was the Change effective? Yes ☐ No ☐
Are all affected systems and equipment operating within specification? Yes ☐ No ☐
Have all deliverables been received, reviewed and filed? Yes ☐ No ☐
Additional Comments.

8.0 Lessons learnt

Is the change applicable to other projects or vessels? Yes ☐ No ☐
Lesson recorded in database and/or debrief report? Yes ☐ No ☐

9.0 Completion sign off

Job title Name Completed Signature
Requestor

Scan and send completed CRF to onshore manager.

Page 22 of 23 © IMCA IMCA HSS001 Rev. 1.2 – May 2024

Guidelines for Management of Change

Appendix 3 – A Typical Management of Change Flow Diagram

Input Action Output Responsibility
Originator
Change
Specify register ⬧ Identifies need for change
⬧ Specifies proposed change and informs responsible manager
Responsible manager
⬧ Enters change in register

Responsible manager
⬧ Considers proposed change
Relevant Analyse
input impacts
⬧ Identifies all that can be affected by the change
⬧ Gathers relevant input to assess possible impacts of the change
⬧ Proposes control measures regarding equipment, facilities, processes,
operation, maintenance, inspection, health, safety & environment,
training, communication, and documentation
⬧ Informs people involved, including his/her manager (responsible
manager) and the initiator
Responsible manager
⬧ Reviews and approves/rejects change
⬧ If approved: determines actions required to implement change
No Close out
Approve (change itself and control measures)
change? change
⬧ Informs people involved

Yes

Responsible person
⬧ Executes actions determined by responsible manager
Implement ⬧ Informs manager on location/department when action is completed
change

Responsible manager
Verify control
measures and ⬧ Verifies effectiveness of control measures
review impact of ⬧ Reviews impact of change
change
⬧ Informs senior manager

Responsible manager
Verify control
Restore
measures and
original
review impact of
situation (as
change
appropriate)

Responsible manager
⬧ Closes out action when all outstanding actions were closed or when
the change was rejected
Close out Change
change register

IMCA HSS001 Rev. 1.2 – May 2024 © IMCA Page 23 of 23