QSP-511-01 Management of Change
QSP-511-01 Management of Change
QSP-511-01 Management of Change
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Quality System
Procedure
QSP- 511-01 Management of Change
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Effective Date: February 14, 2014
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Purpose
The purpose of this procedure is to establish the minimum requirements to be followed when PT
Borneo Mandiri Investment employees and supplier/ contractor personnel conduct activities that
result in temporary or permanent changes to organization, personnel, process, procedures,
equipments, products etc.
Key Responsibilities
The person responsible for initiating the organizational or personnel change (Change Initiator):
a. Shall be familiar with this MOC Procedure; and
b. Shall complete and submit all forms as required to begin the MOC approval process; and
c. Shall manage the implementation of the change process to ensure that all specific MOC
requirements are met.
For the approver who is a member of management or senior officer has the below responsibilities:
a. Reviews this initial change form to confirm the need for change and validate the
preliminary impact assessment and the implementation plan.
b. If the change has major impacts and it is particularly complex, the approver is strongly
suggested to request further detailed risk assessment. Ultimately, the approver decides if
the change can be executed.
General
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MOC Implementation
PT BORNEO MANDIRI INVESTMENT shall use the MOC process for any of the following
that may negatively impact the quality of the product:
a.
b.
c.
d.
4.1
Modifying the structure of an organization, regardless of its size, is a major change, and requires
appropriate impact analysis. Typical organizational changes include:
Whether restructuring the organization or adjusting the number of staff, there is a potential for
impacting every prevention program and emergency response program element.
This includes changes in essential personnel staffing that can adversely affect the product quality
during its production process. Essential positions are those who are directly involved in the
production process (e.g., Assembler, supervisor etc.). The management of change procedure shall
be followed when:
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For example: Fewer operators may necessitate procedure revision or greater automation. More
operators may necessitate a revision of responsibilities in procedures. Fewer maintenance
personnel may necessitate the need for additional contractor assistance. Reorganization under a
different manager may necessitate implementation plan revisions and additional training. The
MOC must prompt for evaluation in these types of circumstances and require remedial action as
necessary.
Any change in organizational structure, it shall refer to the procedure in section 5.0 of this QSP.
4.2
Change in key or essential personnel including changes in staffing levels and staff experience.
Any changes in key personnel should be referred to procedure in section 5.0 of this QSP
4.3
4.3.1
Types of Change
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However, some changes are not subjected to the MOC if a replacement satisfies the design
specifications. For example, replace one ball valve with another of exactly the same manufacturer
and model is likely a Replacement in Kind. However, replacement of one ball valve with a ball
valve of different manufacture may or may not be Replacement in Kind. Some review to
determine if the replacement meets all of the original valve design specifications (material
construction, design ratings, etc.) is necessary. If the valve meets all of the original valve design
specifications, then it would be determined to be Replacement in Kind and the MOC evaluation
would not be necessary.
4.3.2
Procedure
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The supplier is responsible for controlling and notifying the PT Borneo Mandiri Investment of all
changes to the approved part design, manufacturing process, or site.
4.3.3
The supplier shall have a process to ensure that relevant versions of applicable documents
furnished by PT Borneo Mandiri Investment (as well as those specified of external origin) are
available at points of use.
The supplier is responsible for the timely review, distribution and implementation of all PT
Borneo Mandiri Investment engineering standards/ specifications and changes in accordance with
the schedule required by PT Borneo Mandiri Investment. The supplier shall maintain a record of
the date on which each change is implemented in production. Implementation shall include
updated documents.
4.3.4
Suppliers shall not make changes to their processes, location, facilities, equipment, material,
product design (or any change which may affect product design or function) without written
approval from the PT Borneo Mandiri Investment for:
Any planned changes by supplier to the design, process or manufacturing location, such
as:
a. Use of other material than used in previously approved part or product
b. Production from new, additional, replacement or modified tools, dies, molds,
patterns, etc.
c. Production following upgrade or rearrangement of existing tooling or equipment
d. Production from tooling and equipment transferred to a different plant site from an
additional plant
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Description
Responsibility
1.
2.
Purchasing
Department
will
department,
contact
4.
Manager
and
Operation Manager
6.
7.
8.
Operation Manager
9.
Manager
and
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Purchasing Department
10.
and
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Purchasing
A supplier change request is obtained by the Supplier Change Request Coordinator or Change
Initiator and is logged in the Supplier Change Request Tracking Log on the shared drive. Unique
consecutive numbers are assigned to each change request in the following format:
YY-SCRF-XXXX, where YY represents the last two digits of the year in which the change
request was initiated and XXXX is a consecutive number starting at 0001. SCRF designates
Supplier Change Request Form.
At the start of each calendar year the consecutive number recycles to 0001. When a change
request is initiated the next available number is assigned.
At a minimum, the following information should be documented in the Supplier Change Request
Tracking Log:
Supplier name
Parts affected
Change initiator
Request status
Approval date
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Changes to the management system procedures, including changes resulting from corrective and
preventive actions, its procedure refer to section 5.0 of this QSP.
5
MOC Procedure
The approved sequence through which changes are initiated, evaluated, authorized, implemented
and followed-up. The intention of an MOC procedure is to ensure that changes are reviewed and
approved by people with appropriate knowledge and experience. These people will then be
accountable for effective implementation of the changes.
Regardless of a companys culture, organization, values, and programs, the key steps discussed in
this subsection should be considered when designing any formal management of change program.
The process set forth in these steps as follows:
i.
Initial review
ii.
Senior review
iii.
iv.
Approval
v.
Implementation
vi.
An overview of the MOC process is depicted in the flowchart of Figure 1 (Appendix A).
5.1
This step involves stating the justification for the change, as well as developing an initial
assessment of the hazards associated with the change and proposing an implementation plan with
risk control options.
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An Initial Review would typically involve completing a checklist or initial sections of the MOC
form to guide the user through the required analysis. It would typically address the following
aspects:
i.
ii.
Preliminary Impact Assessment What are the potential impacts of the change? The
change owner and initiator are required to brainstorm the potential consequences of the
change. In particular, the possibilities of significant safety, environmental, economic, and
business implications should be listed.
iii.
Implementation Plan What controls are proposed to reduce the risk associated with
identified impacts? How will the change be properly executed to minimize additional
risk? A draft implementation plan should be set forth to indicate the way in which the
change will be executed, including administrative or engineering control measures
recommended to mitigate risks caused by the change. The plan should also detail actions
concerning the update and development of documentation to support the design and
operation of the revised system.
The MOC process described herein is targeted for permanent changes. However, two special
types of changes, emergency and temporary, need to be controlled but demand slight
modifications to the standard approach. It is very important to identify in this initial review if the
change is emergency or temporary so that they are handled appropriately. The MOC process
variations for controlling emergency and temporary changes is addressed in Section 6.0, whereas
detailed guidance for conducting the Initial Review is given below.
5.1.1
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The initial reviewer should verify the applicability of the change within the MOC program by
confirming that the change is a type of change covered within the companys MOC program and
is not a replacement-in-kind. It is covered under the section of IA Request for Change in the
Management of Change Form (MOC-511-01).
5.1.2
Once it is decided that the change is a type that needs to be managed within the MOC program,
the next task is to be brainstorm the potential impacts associated with the change. A change is
normally proposed because it is advantageous. However, a change that is not properly evaluated
can also bring negative impacts that outweigh its benefits. The ultimate goal of an MOC program
is to control the changes process to minimize or eliminate any detrimental impact on product
quality, safety, property, and the environment, as well as quality, security, or any other aspect of
interest to the company.
The preliminary impact assessment is very important in an MOC program, and it should
appropriately identify all potential impacts associated with change. A sample preliminary impacts
checklist and MOC form can be found in Appendix 1 and Appendix 2, respectively. It is covered
under the section of IB Preliminary Impact Assessment in the Management of Change Form
(MOC-511-01).
On the other hand, a change that has been preliminary assessed during the Initial Review as
having major potential impacts is likely to need further assessment to more clearly identify the
potential outcomes and measures to mitigate the risks. These detailed risk assessments usually
escalate the amount of resources and subject matter experts needed for the assessment, as well as
the depth of the analysis, as described in Section 5.3.
Personnel and organizational changes require a special approach to identify risks. One such
approach is mapping of tasks and individuals from the existing situation to the proposed one. The
mapping involves identifying all personnel affected by the change and identifying the tasks each
person carries out. The list of tasks must include their primary tasks and any special roles such as
emergency responder, in addition to competences needed and time expected to be spent on each
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task. This information is then carefully compared checking that for each individual the workload
is reasonable, simultaneous tasks can be realistically accomplished, that the competencies match
the requirements for the task or identifying the training needed to enable the personnel to carry
out the expected tasks.
5.1.3
Implementation Plan
The implementation plan describes how the change will be executed and identifies specific
actions, time limits and responsibilities for addressing any negative impact prior to the change
being implemented. Typical action items in an implementing plan would be to determine the
specific controls to mitigate risks associated with the change, the types of notification needed,
training, documentation, etc.
An implementation plan shall not only indicate the actions needed for the execution of the
change, but also assign responsibility for each action and identify a timeline for the actions to be
completed. It is covered under the section of IC in the Management of Change Form (MOC-51101).
5.2
Once the impacts are assessed in the Initial Review, the final review step involves presentation of
the initial analysis to the designated approval authority. It is covered under the section of II Final
Review in the Management of Change Form (MOC-511-01).
Before a change can be implemented, the approver should review and concur with the basis for
the change, confirm that the preliminary impact assessment did not identify significant concerns
warranting cancellation of the proposed change, and provide agreement with the implementation
plan. If the approver has a concern regarding the outcome of the Initial Review, one of several
alternatives can be chosen:
The Initial Review is repeated but with a focused objective to provide substantial input in
addressing the concerns raised by the approver, or
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The change is rejected, and the MOC form is considered closed and retained for future
reference.
A more detailed form of risk assessment is requested to be developed and the resulting
implementation plan approved before the change may be executed, as described in Step 3.
5.3
When the preliminary impact assessment identifies that the change has potential for major
consequences, or the complexity of the change warrants it, then a greater degree of scrutiny is
required to assess the potential risks. In these cases, the change owner or the approver is strongly
advised to request a second more thorough and comprehensive risk assessment.
One of the main differences between the preliminary impact assessment and the detailed risk
assessment is the number of people involved. The detailed risk assessment would be carried out
by a team including subject matter experts from various disciplines. This detailed risk assessment
should provide further clarification into the nature of risks to be controlled and as an output,
produce a list of requirements or controls to be implemented before effecting change. It is
covered under the section of III Detailed Risk Assessment Review in the Management of Change
Form (MOC-511-01).
The risk assessment should be based on failure scenarios that force the risk analyst to think in
terms of what could go wrong. The potential failure modes and impact in a facility will vary
depending on the operations it is undergoing when the failure occurs, thus all relevant operations
are to be considered.
The full benefits of change management are only realized when the risk analyst takes a life-cycle
approach in identifying issues associated with the change. The risks resulting from the change can
occur before, during, and after change implementation. For example, before a change that
involves tapping into an existing system is implemented, preparation activities can negatively
affect an interconnected system. While the change is being executed, there are typical safety
concerns for the people involved in the repair, as well as potential effects on the interconnected
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systems. After the change is implemented, the added load can result in problems with the existing
system.
Typical failure scenarios should not only consider failures, associated with all modes of
operations, but also potential failures or impacts throughout the entire life cycle, such as:
Change in place
Safety and environmental concerns associated with decommissioning when end of life is
reached.
This is substantially more than just considering how the new system can fail and the
consequences arising therefrom.
Once failure scenarios are identified, the consequences can be assessed on the basis of negative
impacts to health and safety, environment, facility security and financial values.
A wide range of risk assessment tools can be used to determine the extent of the potential risks
(i.e., consequences and likelihood of occurrence). The following tools and techniques are typical
examples of type of risk assessments performed for managing change:
Hazard identification and assessments, such as What-If, HAZID, HAZOP, for equipment
changes.
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The first step of a risk assessment is to identify all likely potential undesirable events and then to
evaluate the risks they present in terms of how they are likely to happen and how severe the
consequences will be if the loss occurs. Once this information is ascertained, the next step is to
determine how the risk, and therefore the change, will be managed. The detailed risk assessment
outcome will typically lead to options such as:
i.
ii.
Managing the risk of the change using good technical experience, controls, procedures,
engineering controls, etc., or
iii.
An important element in the decision is evaluating the costs of the selection and weighing them
against the risks so that a reasonable decision can be made.
If the option to manage the risk is the one recommended by the detailed risk assessment, an
implementation plan must be developed. Such a plan should describe how the change will be
executed, what specific actions must be carried out, including the risk control options, as well as
time limits and responsibilities for addressing any HSQE issue or any negative impact prior to the
change being implemented.
5.4
Approval (Step 4)
If the implementation plan presented in either the Preliminary Impact Assessment or the Detailed
Risk Assessment is approved, the change may be executed. It is covered under the section of IV
Approval in the Management of Change Form (MOC-511-01).
It is strongly recommended that the results of the initial impact analysis be confirmed and
validated by the approver. A change whose potential impacts have been poorly analyzed may
result in insufficient implementation planning. This will increase risk exposure and the likelihood
of significant and detrimental impacts.
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In order to adequately perform the technical review, it is critical that the approver be competent in
the field or domain where the change is occurring.
If the approver does not concur with the outcome of the assessments and the proposed
implementation plan, he or she can reject the change and close out the MOC or ask for the
Preliminary or Detailed Assessment to be revisited.
5.5
Implementation (Step 5)
The implementation step is about executing the change and implementation plan. It also includes
updating the documentation to reflect the change, communicating the change, and training
personnel on the change.
5.5.1
Documentation
Management of change requires effective documentation control. Documents from different areas
such as drawings, procedures, checklists, permits, training manuals, signage, etc., may need to be
updated to reflect an approved change. A well thought out checklist should be in place to help
identify all the management processes that can be impacted by the change. The documentation of
such an impacted management process should also be updated if needed (procurement,
maintenance, training, emergency response, etc.). It is covered under the section of V.
Documentation and Training in the Management of Change Form (MOC-511-01).
5.5.2
Before the change is implemented, all affected personnel should be aware of the change that will
take place. The change owner should emphasize consequences of concern and special precautions
to be taken as a result of the change.
Change should be communicated to all personnel who may be affected by the change. This
notification should occur before the change is implemented. The manner and breadth of
communications/ training should be reflective of the complexity of change (examples are e-mail,
announcement in meetings, tool box talks, etc.). Relying on passive notifications such as entries
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in log books or documentation in procedures should not be the sole way of communicating to
personnel since they could easily be overlooked by personnel that need to be aware of the change.
For further details of communication procedure, refer to Communication (QSP-415-01).
Changes involving significant revisions to current practices will require training of relevant
personnel. An awareness training, or in some cases, detailed training of the new practice should
be provided. It is covered under the section of V Documentation and Training and Identify Any
Training Needs in the Management of Change Form (MOC-511-01).
In addition to notifying the people immediately affected by the change, there should be
consideration of the need to inform other departments (procurement, maintenance, training, etc.).
Any modifications to documentation, updates to risk assessments and reviews, should also be
communicated to demonstrate transparency of the MOC process.
5.5.3
Execution
Before executing the change, the change owner should confirm that all risk control measures
from the risk assessment are on target with the implementation plan and that the affected
personnel are trained and informed of the change, then and only then should the change be put in
place.
5.6
Once any change is implemented, it is good practice to revisit it in the short-term to assess
effectiveness. It is covered under the section of VI Verification and Closeout in the Management
of Change Form (MOC-511-01).
Companies may find it difficult to finish the update to documentation before the needed change is
executed. This verification step will check that the follow-on work was performed prior to closing
out the MOC.
Temporary changes should be monitored to confirm that before expiring they are either converted
to a permanent change by completing the MOC process or reverted to their original state.
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Therefore, some of the questions to be answered during this verification step are as follows:
Are the actions from the implementation plan being complied with and meeting the
intended function?
Have the temporary changes expired? If so, can the system revert to its original state? If
the answer is no, proceed to convert a permanent change, restarting the MOC review
process.
5.6.1
Closeout
All changes that have gone through the MOC review process, even if they were eventually
rejected by management, should be signed-off and retained for audit and inspection. This is an
essential step to be able to audit the MOC program and monitor the program for continual
improvement.
A summary of the typical evaluations carried out in each step of the MOC process is presented in
Figure 2 (Appendix B).
5.7
MOC Notification
PT BORNEO MANDIRI INVESTMENT shall notify relevant personnel, including the customer
when required by contract, of the change and residual or new risk due to changes that have either
been initiated by PT BORNEO MANDIRI INVESTMENT or requested by the customer.
6
Reference
a) Quality Management System (QSM-01 Rev.2)
Appendix
Appendix A
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Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
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