GNwafor MOC

Management of Change & Exemption

Godwin Chidiebere NwaforSD-1 #71108, MLC UAE

Schlumberger Private

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Outline

Introduction

Objectives

Methodology

MOC & Exemption Processes

Management Level Review

Compliance Monitoring

The Scenario

Conclusion


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Introduction Management of Change (MOC) is the process to manage

significant changes associated with deviations from contractual terms and conditions, work-scope, historical norms, procedures and work instructions.

Exemption is the process to obtain appropriate approval for deviation from Schlumberger policies and standards for a specific period of time.


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Introduction Significant Change: Any change that introduces new

hazards, or any change that causes an increase in the level of the risk, that has the potential to result in an HSE accident or an SQ non-conformance. Such changes may be incremental, but over time can be significant.

A change is not only from procedures and work instructions but also from historical norms in terms of work-scope, activities and conditions, job programs, quality plans, personnel changes, equipment changes.

Environment, Equipment, Personnel & Process


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Introduction Originator: The individual employee who makes the documented

‘Management of Change’ or ‘Exemption’ request. The Originator is generally a Line Manager with responsibility for the work area or process where the deviation has been identified.

Approver: The individual(s) with the ultimate responsibility to approve or reject the request for a deviation:

For the Exemption process, generally a line manager in the organization in which the policy or standard was published.

For the Management of Change process, generally found in the engineering, technical or operations management chain that originally approved/signed off the contract, equipment, job, etc.


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Objectives Description of what to do when significant change is

introduced following deviation from: Contractual terms and conditions, work-scope, historical

norms, procedures, work instructions, using the Management of Change process; Policies and standards; using the Exemption process.

All significant changes to design, equipment, and operations, as well as deviations from policies and standards, must be justified, approved, recorded, and monitored in a controlled and effective manner


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Methodology The Originator identifies or acknowledges the deviation and

the nature of the significant change The Originator and where applicable, his/her direct line

manager set up a risk assessment team The risk assessment team performs a comprehensive initial

risk assessment to determine the potential risk if the activity /process continues without any further measures being applied to control the deviation/significant change (Guide: SLB-QHSE-S020 & SLB-QHSE-S002)

The risk assessment team develops a risk control plan, including both prevention and mitigation measures


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Methodology The risk assessment team completes the risk assessment by

defining the residual risk that will exist if the activity /process continues with all planned risk control measures implemented and followed

The Originator requests approval from the relevant Approver The Approver(s) reviews all the details of the request Upon approval, the Originator must ensure that the

Management of Change and/or Exemption details are thoroughly communicated to all those involved, including third parties, and also including any newcomers that may arrive after its initial implementation


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Methodology The activity is performed at the defined residual risk level

with all agreed control measures in place Upon completion of the deviated activity or on expiry of the

request validity period, the Originator must ensure that the Management of Change and/or the Exemption is closed out appropriately

If rejected then the request is closed and any subsequent request for approval is documented on a new request document


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MOC Process


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Exemption Process


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Compliance Monitoring To allow compliance monitoring, all Management of Change

and Exemptions shall be logged into QUEST at originating location; if not feasible, request shall be logged into QUEST by the HSE function at the appropriate level:

Geomarket HSE Manager for exemptions approved by Geomarket Manager or Operations Manager;

Area HSE Manager for exemptions approved by Area President or Area Business Manager;

Segment HSE Manager for exemptions approved by Segment President.


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The Scenario Land operation, 7” production casing Rig just completed running the casing. When the rig finished

the mud circulation, just about starting the cement job, found well flowing and H2S detected on the return.

Supervisor in charge has expired Well Control Certification Job previously has been assessed with normal condition Unit was rigged up as per normal condition Spare treating iron was expired last week


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The Scenario – Corrective Tools SLB-QHSE-S010 – MOC & Exemption WS Appendix for SLB QHSE S010 Cementing KSQR WS QHSE Std 05 (Job Checklist) WS QHSE Std 23 SLB QHSE Std 20 – HARC SLB QHSE Std 002 – Event Reporting & Management

(SQ/HSE) SLB QHSE Std 15 – H2S SLB QHSE Std 003 – PPE Must Do Bulletin 1316 - License to Operate Certification


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Conclusion

Management of Change (MOC) and Exemptions apply to all

Schlumberger operations and for all deviations from policies,

standards, contractual terms, work-scope, historical norms,

procedures and work instructions generated at any level,

whether generic or process-related and where significant

change has been introduced.

Documents

GNwafor MOC