Management of Change

Section 2 Subsection 7

POLICY
A system must be in place to recognize change and manage the associated risks.

PURPOSE

The purpose of this policy is to ensure personnel understand the process to manage
change and to prevent unplanned events.

SCOPE

This policy covers all Company personnel that work at any Company location.

REQUIREMENTS

Change of Task Plan

While executing a task, the plan must be monitored for any changes or deviations. All
changes or deviations must be appropriately managed, and risk assessed.

The Change of Task Plan process consists of the following:

1. Identifying a change or deviation (i.e. personnel involved in the task, weather,

equipment, etc.).
2. Calling a TOFS.
3. Assessing changes and re-evaluating the risk using the Simple Risk Assessment
Card or TBRA. Changes must be documented in the TBRA, if in use.
4. Communicating the revised plan and risk assessment to all involved personnel.
5. Debrief and update the TBRA in Dashboard, if required.

By implementing the Change of Task Plan while executing a task we effectively manage
a change or deviation and its associated risks.

Management of Change (MOC) Assessment

The MOC Assessment form must be used for, but not limited to, the following:

Changes to Task Plan that require additional resources, equipment and/or support that
is not immediately available.

Changes to the Installation structure.

Changes to equipment or equipment design.

Changes to the maintenance regime or procedures.

If additional resources or support are required, in addition to the MOC Assessment form,
the change must be formally tracked using the appropriate tool.

Examples of these tools are:

Dashboard DELTA Item.

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Section 2 Subsection 7

REA (Request for Engineering Assistance).

The OIM and Rig Manager must sign the MOC Assessment form if the change is not
tracked using DELTA or REA.

Short Term Non-Compliance

A Short Term Non-Compliance must be applied for:

If you intend to comply with a management system requirement but cannot do so

immediately as additional resources are necessary.

Any deficiency .

Preventative Maintenance of Safety Critical Equipment overdue by 30 days (i.e.

lifeboats, liferafts, fire pumps, well control equipment, etc.).

Preventative Maintenance of Operationally Critical Equipment overdue by 60 days.

Periodic Third Party surveys or inspections overdue by 1 day (i.e. dropped objects,
lifting gear, etc.).

Any overdue emergency drill.

A deficiency or change in the Safety Critical Equipment.

A deficiency or change in the Safety Critical Positions.

Refer to eLibrary for the Safety Critical Equipment and Safety Critical Positions.

Short Term Non-Compliances must have an interim plan which:

Meets the intent of the policy statement.

Is registered, submitted, tracked and approved in Dashboard

Includes DELTA action(s) if applicable.

Does not exceed 3 months.

Is supported by a MOC Assessment and uploaded in Dashboard.

Is reviewed and signed by the OIM.

Is approved and signed by the Rig Manager and Director of Operations.

If needed, Short Term Non-Compliances may be extended in Dashboard

and approved by the Rig Manager.

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Figure 2.7.1 Short Term Non-Compliance Flowchart

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Section 2 Subsection 7

Exemptions
If you cannot comply with a requirement, an exemption must be requested. No exemptions
are granted to Policies.

Examples for exemptions:

Local Regulatory Requirements.

Customer Management System conflicts.

Installation established requirements.

Exemptions must have a plan which:

Meets the intent of the policy statement.

Is registered, submitted, tracked and approved in Dashboard.

Does not exceed 12 months.

Is supported by a MOC Assessment and uploaded in Dashboard.

Includes DELTA action(s) if applicable.

Is signed by the OIM, Rig Manager and Director of Operations/Designee.

Where necessary, Subject Matter Expert is assigned to the Exemption for review and
comments.

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Section 2 Subsection 7

Figure 2.7.2 Installation Exemption Flowchart

Installation Exem ption

Corporate Function
Department Supervisor OIM Rig Manager Director of Operations
Head

Installation Exemption
Required

Reviews with OIM

requirement for
Exemption

Completes MOC
Reviews MOC
Assessment
Assessment and
and creates new
Exemption request
Exemption request,
with Supervisor
including DELTA actions

Reviews and signs

Signs Exemption and
Request for
submits case for Rig
Exemption and MOC
Manger review
Assessment

Approval Request for Installation

granted? Exemption Denied

Reviews and signs

Yes request for Exemption
and MOC Assessment

No
Approval
granted?

Reviews and signs

Yes request for Exemption
and MOC Assessment

Request for Installation Approval No

Exemption Approved Yes granted?

Monitor DELTA
actions completion

Close Exemption case Exemption Closed

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Section 2 Subsection 7

RESPONSIBILITY

Department Head

Submit request for Short Term Non-Compliance (including MOC Assessment and
DELTA action(s)).

Submit requests for Installation Exemption (including MOC Assessment).

OIM
Ensure the appropriate tools are used to implement Change of Task Plan.

Review and sign requests for Short Term Non-Compliance (including MOC
Assessment and DELTA action(s).

Review and sign requests for Exemption (including MOC Assessment) to the Rig
Manager for further approval.

Rig Manager

Review and sign requests for Short Term Non-Compliance, including MOC
Assessment and DELTA action(s).

Review and sign Requests for Exemption (including MOC Assessment) and submit to
the Director of Operations for further approval.

Director of Operations
Review and sign Short Term Non-Compliance (including MOC Assessment).

Review and signs Request for Exemption (including MOC Assessment).

Ensure that the Exemption meets the intent of the company policies.

Corporate Function Head

Review, sign and approve Request for Exemption, including MOC Assessment.

DOCUMENTATION
The form indicated below is available in SharePoint intranet eLibrary and is not to be
modified from the original format. The form has been developed by Corporate HSE and is
a requirement of this policy. The form must be reproduced and made available to all
installations/facilities by their Country offices. Forward any suggested improvements to
this form via the Smart Feedback Process, [email protected].

Management of Change (MOC) Assessment, Form No. COR-HSE-RE-01 FM 2.07.1.

MOC Assessment must be uploaded to the STNC / Exemption case in Dashboard.

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