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NOTE

OIL INDUSTRY SAFETY DIRECTORATE (OISD) publications are prepared

for use in the Petroleum and Natural Gas industry under Ministry of Petroleum & Natural
Gas. These are the property of Ministry of Petroleum & Natural Gas, and shall not be
reproduced or copied and loaned or exhibited to others without written consent from
OISD.

Though every effort has been made to assure the accuracy and reliability of the
information contained in these documents, OISD hereby expressly disclaims any liability
or responsibility for loss or damage resulting from their use.

These documents are intended only to supplement and not to replace the
prevailing statutory requirements.

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 FOREWORD

The oil industry in India is over 100 years old. Variety of practices have been in
vogue because of collaboration / association with different foreign companies and
governments. Standardisation in design philosophies and operating and maintenance
practices at a national level was hardly in existence. This coupled with feedback from
some serious accidents that occurred in the recent past in India and abroad, emphasised
the need for the industry to review the existing state of art in designing, operating and
maintaining oil and gas installations.

With this in view, Oil Industry Safety Directorate (OISD) was established in 1986
staffed from within the industry for formulating and implementing a series of self
regulatory measures aimed at removing obsolescence, standardising and upgrading the
existing standards to ensure safer operations. OISD constituted a number of committees
comprising of experts nominated from the industry to draw up standards and guidelines
on various areas of concern.

The present document on ‘Guidelines on Management of Change’ for Petroleum

Refineries & Oil/Gas processing plants is prepared by the Committee on ‘Management of
Change’. This document is based on the accumulated knowledge and experience of
industry members and various national and international codes and practices. It is hoped
that the provision of this document, if implemented objectively will go a long way in
improving the safety in the hydrocarbon processing industry.

This guidelines in no way supersedes the statutory regulations and requirements

of various statutory bodies, which shall be followed as applicable.

This document will be reviewed periodically for improvements based on the new
experiences and better understanding. Suggestions from users/industry members may be
addressed to:

The Co-ordinator
Committee on ‘Management of Change’
OIL INDUSTRY SAFETY DIRECTORATE
7TH FLOOR, NEW DELHI HOUSE
27, BARAKHAMBA ROAD
NEW DELHI - 110 001.

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 COMMITTEE
ON
MANAGEMENT OF CHANGE

------------------------------------------------------------------------------------------------------------
Members Representing
------------------------------------------------------------------------------------------------------------

S/Shri

1. G. C. Mitra Indian Oil Corporation Limited Leader

2. R. D. Goyal Gas Authority of India Limited Member

3. V. Narayanan Madras Refineries Limited Member

4. K. Madhusudan Cochin Refineries Limited Member

5. M. S. Rathod Hindustan Petroleum Corporation Ltd. Member

6. N.D. Raut Bharat Petroleum Corporation Limited Member

7. N. Rengaswamy Enginers India Limited Member

8. S. K. Sinha Oil &Natural Gas Corporation Ltd. Member

9. A. Ghatak Oil Industry Safety Directorate (Member Co-ordinator)

In addition to the above, several other experts from industry contributed in the
preparation, review and finalisation of the document.

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 GUIDELINES ON MANAGEMENT OF CHANGE
CONTENTS

SECTION PAGE NO.

1.0 Introduction 1
2.0 Scope 1
3.0 Definitions 1
4.0 Types of Changes 2
5.0 Procedure to implement Changes 3
5.1 Changes due to Modification of Plant/Facilities 3
5.2 Additional checks for changes in Normal Operating
Procedure,Start-up,Shutdown and Emergency 8
Procedures.

5.3 Additional Checks for introduction of new Catalyst, 9

Additive,Corrosion Control Agents etc.

5.4 Additional checks for changes in Solvents in the 10

Extraction Process.

5.5 Additional checks for Carrying out changes of Logic 10

of Interlocks, Set Point, and Process Conditions

5.6 Additional checks for carrying out Changes of Software 11

5.7 Changes of Personnel 11

5.8 Additional checks for any Other Changes requiring 12

Orginal Design Review including Service Change.

6.0 References 12

7.0 Annexure – I 13

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1.0 INTRODUCTION

A process industry is subjected to continuous modifications to achieve higher

efficiency, improve operability and safety, improve reliability, improvement of
the plant machineries and equipment and to accommodate technical change. Any
changes in the processing units/ facilities may have the potential to destabilise
existing safety and to introduce new hazards. The hazards connected with any
change are to be identified and controlled efficiently through an appropriate
hazard management system. These guidelines lay down procedures covering
various aspects of change and addresses the following :

- Minimise the mishaps caused due to non-compliance of procedures.

- Improve optimisation and utilisation of facilities.
- Decrease downtime.
- Increase favourable public opinion.
- Increase knowledge of plants and process activities.

2.0 SCOPE

These guidelines describes the procedures to be adopted for systemic

management of

- change of process / technologies,

- change of hardware excluding replacements (of same specification and

kind),

- change of software,

- changes of personnel,

- change of chemicals and

- change of catalysts,

- change of operating procedures,

- change in working environment.

3.0 DEFINITIONS

3.1 Petroleum Refinery

‘Petroleum Refinery’ is a plant where crude oil is received and processed to

produce various intermediates and finished products.

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3.2 Oil/Gas Processing Plant

‘Oil/Gas Processing Plant’ is a plant where crude oil/natural gas is collected and
processed in order to separate oil and gas and to remove impurities like water,
sulphur etc. before sending them to refinery or to obtain end products.

3.3 Facility

Facility means the buildings, containers or equipment including pipeline operation

which contain a process.

3.4 Process

Process means any activity involving a hazardous chemical and utilities including
use, storage, manufacturing, handling and the on-site movement of such
chemicals and utilities or combination of these activities. (These include pipeline
operation also).

3.5 Process Hazard Analysis (PHA)

It is the application of one or more analytical techniques that aid in identifying

and evaluating a process hazard.

4.0 TYPES OF CHANGES IN WORKING ENVIRONMENT

The need for change arises out of various reasons like operational flexibility,
energy conservation, capacity augmentation, improvement of product
specification, yield improvement, compliance with statutory rules and regulations.
The various types of changes that take place in a process unit and related facilities
are detailed below.

i) Equipment changes like addition, alteration or removal of an equipment

or a part of it from the plant.

ii) Modifications in piping system and process equipment, replacement of

equipment or machinery that differs from the original equipment.

iii) Change in metallurgy.

iv) Change in normal operating procedure, start-up, shut down and emergency
handling procedures.

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 v) Introduction of new catalysts, additives, corrosion agents, solvents in
extraction processes etc.

vi) Change in instrument which may include pressure, temperatures, flow, set
points, alarm points, speed, logic and control parameters.

vii) Mechanical process or instrument system changes made to increase

production rates.

viii) Change of software in a computerised environment.

ix) Introduction of operation or maintenance personnel who are new in

respect of the process.

x) Any other change requiring original design review including service

change and changing pipeline scrapper station / delivery station to
pumping or pumping and storage tank station.

5.0 PROCEDURES TO IMPLEMENT CHANGES

5.1 CHANGES DUE TO MODIFICATION OF PLANT/FACILITIES

The procedure for implementing modification shall be flexible to include both

major or minor modifications.

There should be a formal procedure which requires all modifications to be

authorised by competent persons and a standard method of making the safety
assessment. There should also be a system of inspection of modifications by a
competent person to make sure the work has been done as intended and is
complete. The competent persons shall be nominated and notified by the
management of respective organisations / units. Implementation of any
modification / change shall not be done without the formal approval of the said
competent persons. There should be a system of documentation to record the
change and there should be adequate training so that all personnel concerned
understood the system of control.

In general, any modification shall cover the following as minimum :

i) Origination of modification proposal.

ii) Design philosophy.
iii) Scrutiny and approval procedure / safety assessment.
iv) Execution of the modification job.
v) Training of the operating / maintenance personnel on proposed
modification.

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 vi) Commissioning.

vii) Updating of documents in line with the modification.

viii) Approved handing over / taking over procedure.
ix) Post commissioning review.
x) As built record.

i) Origination of Modification Proposal

Process plants and facilities requires continuous updation to increase

efficiency, improve operability and safety. It is appropriate that the
proposed modification is considered critically. The following three
queries shall always be answered before finalising any proposal :

- Is it necessary ?
- Is it economic ?
There is a possibility of introduction of new hazards as the safeguard’s
built in original design are changed. The modification proposal should
therefore achieve primary objective in a safe manner. Therefore, the
following questions are to be considered :

- How will the change impact the people and the work environment ?
- Will people be able to construct / implement and operate "the change" and work
with "the change" within an acceptable level of risk ?
- How will "the change" impact inspection & maintenance activities ?
- Is "the change" going to adversely affect excess / ingress for operation,
inspection, maintenance, emergencies etc.

Is there a better alternative?

This necessitates the following to be checked before finalising any such

modification proposal :

a) The technical basis for the proposed change.

b)
Impact of change on safety, health and working environment.
c) Modification to operating procedures.

d) Authorisation requirements by the competent persons nominated

and notified by the management for the proposed change.

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ii) Design Philosophy

The design philosophy shall include both process design information and
mechanical design information.

The process design information should include a block flow diagram or a

simplified process flow diagram, the process chemistry with relief system
and where process design material and energy balances are available, this
should also be included. The process design information should also take

into consideration environmental requirements like safety, health and

environment review to ensure compliance with respect to safety, health
and environment.

The mechanical design information should include materials of

construction, piping and instrumentation diagram (P&ID), area
classification, design codes and standards employed and equipment and
piping specifications.

The mechanical design shall be consistent with the applicable consensus

codes and standards in effect at the time the design is prepared, or in the
absence of such codes and standards, recognised and generally accepted
standard engineering practices. Where the original mechanical design
information no longer exists, information may be developed from
available equipment and inspection records.

The provision of design and engineering practice manual and applicable

codes and standards shall be followed while carrying out any
modification. Applicable statutory requirement shall also be considered
while firming up the design philosophy. Ergonomics to be well taken care
of during the design stage of modification / change.

iii) Scrutiny/Approval Procedure

Design shall be completed in two stages. In the first stage, Basic design
shall be completed and in the second stage detail engineering shall be
completed. Second stage shall be taken up only after verification of first
stage design.

Design shall be verified after completion of the first stage to confirm the
following.

- Basic design meets the requirement of the proposal,

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 - Design is safe for expected conditions of use, environment and
also unintended uses and misuses.

- The above shall be confirmed with detailed process hazard

analysis.

- Compliance of the standards with regulatory requirements, national

and international standards , and corporate practices.

- Review made by internal and external agency on the problems

faced from similar nature of design.

Verification after second stage shall confirm the following:

- Detail engineering has been carried out as per the requirement of

the modification.
- It meets the requirement of reliability, serviceability,
maintainability and safety as per national and international
standards.

- There will be least problem in fabrication, installation, erection,

assembly and availability of spare parts and consumable items.

- Design shall be checked for fail safe characteristic

- Ensure modified system / changed system shall not exceed design

limitations of the existing relief system.

- Aesthetic specification shall also to be met.

- Standard materials comparable with existing plant materials are

only specified to the extent possible.

The system of approval by competent persons at various stages to be fixed

by the individual organisations. However, the names of the competent
persons shall be nominated and notified by the management of each
organisation / unit.

iv) Execution of the Modification Job Procedures

Modification shall be taken up for implementation only after availabilityof

“Approved for Construction” documents and materials as per the bill of
materials and approval of statutory authority for the modification
wherever applicable.

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v) Training of the Operating/ Maintenance Personnel on Proposed
Modification

The operating and maintenance personnel who are responsible for

operating and maintaining the plant/facility shall be trained on the possible
impact of the modification. This training should include safe practices to
be adopted after the proposed modification. Contract employees whose job
tasks will be affected by the change in the process shall be informed of
and trained in proposed changes prior to the start-up of the process.

The plant manager or his authorised person to brief and train the
contractor personnel who will be associated with this change.

vi) Commissioning

Plants/facilities shall be commissioned after the job carried out is cleared

by multidisciplinary group approved by management and completion
certificate is available. Licence from statutory authority, wherever
applicable, is obtained.

vii) Updating of Documents in line with Modifications

Design basis, assumptions and important points of design, bill of materials

shall be provided in the design document. The operating and maintenance
manuals are required to be reviewed in line with the modifications.
Changes if any need to be incorporated prior to the commissioning of the
plant/facility. The Layouts, P&IDs, utility drawings, loop / one line
drawings, emergency response plan and PFDs are also to be updated to
incorporate changes arising out of the modification. Necessary updation
of disaster management plan to be carried out for the proposed
modification

viii) Handing Over and Taking Over procedure

There should be a transparent handing over procedure by the executing

departments/agencies to the operating department/agencies. This should
include transfer of Facilities, Hardware, Manuals, Drawings etc. Similarly
department/agencies taking over the facilities should also have a
procedure for the same.

ix) Post Commissioning Review:

After commissioning of the new/modified facility, safety check-list to be

prepared in view of modification / change before conducting any test run
for evaluating the modified facility. Subsequently, a test run shall be

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 conducted to evaluate whether the modification have achieved its desired
objective or not. The results of such test run shall be recorded.

x) As-built Records

All modification records generated from the proposal stage to

commissioning stage including design review, construction documents
statutory approval shall be preserved in approved and accepted locations
for quick references. As-built documents shall be prepared incorporating
all the approved site changes.

5.2 ADDITIONAL CHECKS FOR CHANGE IN NORMAL OPERATING

PROCEDURE, START-UP, SHUTDOWN AND EMERGENCY
HANDLING PROCEDURE

The design of the plant specifies the conditions at which it is to operate. Any
change, major or minor in technology, facilities, plant modification etc. has the
potential for disruption. Change in normal operating procedure, start-up, shut-
down and emergency handling procedure resulting from any modification /change
as mentioned above needs careful consideration to identify incorrect assumptions,
to resolve differences and to eliminate inconsistencies. The ultimate responsibility
for the operating procedures rest with the plant manager. (The modifications made
during the original design process really fall outside the discussions which is
mainly concerned with the stages of commissioning and operation).

To support operator’s performance a written operating procedure shall be

provided for safe operation of the plant. The operating procedure shall include the
changes/ modifications that plant has undergone and specify sets of conditions
within which the plant shall operate and sets of variations which are allowed and
in certain cases the variations beyond a limit are not allowed/permitted. At any
given time, the operational envelope should be clearly defined and strictly
enforced . The plant manager shall develop and implement written operating
procedure that provide clear instructions for safely conducting activities involved
in each process consistent with the process safety information and shall address at
least the following.

a) Steps for each Operating Phase

i) Initial Start-up
ii) Normal Operation
iii) Need based Operation
iv) Emergency Operations including Emergency Shutdown and
Start-up

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 v) Normal Shutdown
vi) Start-up following a turnaround
vii) Start-up after prolonged outage
viii) Process Flow Schemes.

b) Operating Limits

i) The consequence of deviations

ii) Steps required to correct or avoid deviation
iii) Safety systems and their functions/Fail safe position

c) Clear instruction for safe operation of each facility that consistent with the
process safety information.

d) The occupational safety, health and environment considerations including

the following:

i) The properties and hazards presented by the materials needed in

the process.

ii) The special precautions required to prevent exposure including

engineering controls, administrative controls and personal
protective equipment.

iii) The control measures to be taken if physical contact or air borne

exposure occurs.

5.3 ADDITIONAL CHECKS FOR INTRODUCTION OF NEW CATALYST,

ADDITIVE, CORROSION CONTROL AGENTS ETC.

· Change in catalyst /additives, corrosion control agents is normally done in

case of change in process or mechanical design is altered or to
accommodate technical innovation, increase in efficiency & cost benefits.

· A written procedure shall be provided with clear instruction for safety

handling of each items and shall address at least the following:

i) Handling procedure of catalysts, additives, corrosion control agent.

ii) Effect of use of these catalysts, additives, corrosion control agents

on process safety, if any.

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 iii) Specifications & inventories critical to process safety.

iv) Quality control procedure to ensure the use of catalyst, additives,

corrosion control agents meet the specification for use.

v) Material safety data sheets.

vi) Procedure for Catalyst regeneration and disposal of spent catalysts

5.4 ADDITIONAL CHECKS FOR CHANGE IN SOLVENTS IN

EXTRACTION PROCESSES.

Change of solvents in extraction process is normally done during upgradation of

process technology, reduce toxicity, statutory / mandatory requirement, pollution
control, cost control, new innovations or for any other reason best suited for a
particular process.

A written procedure shall be provided for safe handling of the changed new
solvent and the procedure shall also address at least the following items:

· Safe Handling and Storage Procedure

· Process Safety Information

· Toxicity of the solvent used in IDLH ( Concentration at which irreversible

affects on health could be expected.

· Material safety data sheets.

5.5 ADDITIONAL CHECKS FOR CARRYING OUT CHANGES OF LOGIC

OF INTERLOCKS SET POINT AND PROCESS CONDITIONS

A number of modification/addition/alteration are made in existing facilities in the

refinery in the logic of interlocks, set points and process conditions. The
following procedure in addition to earlier stated standard procedure 5.1 shall be
adopted whenever modification/alteration/addition is proposed in existing logic.

a) Instrumentation & Process Engineering shall check the existing ladder

diagram whether the intended change can be incorporated.

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 b) A group of engineers from Process Engineering, Operation, Maintenance
Instrumentation & Safety Department shall conduct HAZOP study of the
scheme prepared for the changes.

c) For incorporating the modification in logic, the group must study whether
it can be incorporated in running plant or the plant has to be shutdown. If
shutdown of the plant is necessary the downtime loss and pay back period
after modification shall be studied .

d) To change the set point of the alarm & trips the group must take into
consideration of the existing process variable whether it can

e) accommodate the change or not, like if the set point of tripping of high
discharge pressure of a compressor is changed to higher one , the
discharge of the PSV must be taken into consideration.

f) After taking into consideration the HAZOP study recommendation, the

scheme shall be approved by the competent person. Based on the approved
scheme, detailed engineering drawing shall be prepared. The drawing shall
then be approved by the competent authority.

g) The changes shall be incorporated in the ladder diagram, operating manual

once the jobs are executed. The updated records shall be preserved for
reference in approved and accepted locations.

5.6 ADDITIONAL CHECKS FOR CARRYING OUT CHANGES OF

SOFTWARE

a) The compatibility of new software with the existing computer

environment shall be checked and approved.

b) The software shall be checked offline to ensure that it does not introduce
any new bugs.

c) After it has been found to function satisfactorily as certified by all

concerned department then only it shall be loaded for normal use.

d) Training of all concerned personnel who will be operating the software

shall be completed before introducing the new software.

5.7 CHANGE OF PERSONNEL

Introduction of personnel who is new to the process may introduce new hazards.
Therefore each employee before being involved in operating newly assigned

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 process shall be trained in an overview of the process and in the operating
procedures. The training shall include emphasis on the specific safety and health
hazards, emergency operations including shutdown, safe work practices
applicable to employees job task.

The employer shall ascertain that each employee involved in operating a process
has received and understood the required training. A record shall be prepared
containing the identity of the employee, date of training and the means used to
verify that the employee understood the training.

5.8 ADDITIONAL CHECKS FOR ANY OTHER CHANGES REQUIRING

ORIGINAL DESIGN REVIEW INCLUDING SERVICE CHANGE

a) Importance of maintaining the integrity of the plant and of avoiding

degradation due to process modifications can not be overlooked. Process
modifications may be in the form of change in the process parameters of a
hydrocarbon producing well due to exploration from previously non-tested
horizon, increase in throughput , change in specification of finished
products, changes in instrument system involving major measurement
signals and/or de-rating of the equipment to allow pressure warranted due
to health deterioration etc.

The existing system can be put at risk by the operation of the process
outside the domain of operating conditions for which the system was
originally designed. These changes will call for consideration of the
relevant codes of practice and specifications. It may affect any existing
trip or alarm system and may require additional trip and alarm protection.
Further these process changes will be capable of effecting originally
designed /existing operating and maintenance procedure, equipment
inspection frequency or may require altogether a new procedure even the
composition of effluent and its disposal has to be looked into. One thing
which may not go any major changes will be the hardware available
within the system as the design review has to be carried out to check the
suitability of originally designed and constructed system for the changed
process requirement.

b) Changes in Services of Equipment

The service of process equipment sometimes require change for example

class B petroleum product tank changes to class A petroleum service. In
such cases changed service requirement shall be studied with respect to

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 earlier condition. Change of facility and Change in Procedure if needed
shall be persued as detailed in para 5.1 and 5.2.

6.0 REFERENCES

i) Loss prevention in process Industries, By F. P. Lees.

ii) Process Safety Management of Highly Hazardous Chemicals; Explosives
and Blasting Agents; Final Rule OSHA, USA

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