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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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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.