SMS :
Management of Change (MOC) General Changes to equipment, personnel, operating conditions, procedures, introduction of third party contractors or a new vessel can increase the risk of an incident. Therefore it is important to evaluate potential impacts of the change and take appropriate actions to avoid unacceptable risks. The management of change process require, but is not limited to the following; - That persons/ranks Responsible, Accountable, Consulted and Informed of the change are identified and execute their given tasks. - That the reason for the change is identified and documented. - That the change is done the decided way, which shall be the best way considering the available options and factors taken into account. - That the persons in charge of the change, at different levels, must be competent within the area of the change. - That Health, Safety and Environment protection must always be adhered to and risks minimized. - That all changes must comply with regulations, industry standards and specifications of applicable original equipment or system remaining. - That appropriate procedures are in place for staff handover and familiarization, both onboard and ashore. - That risk assessments/evaluations of the change is carried out, both of the change itself and the applicable works to be done. - That applicable work permits are in place before any work is carried out to equipment or systems. - That any potential consequences of the change are identified and necessary mitigation measures taken. - That related persons and organisations are kept informed of the decided change. - That changes are carried out within the decided timescale. If not, the change shall be reviewed and revalidated again. - That any training needs arising from the change are identified and taken care of. - That appropriate drawings, manuals, procedures and other documents are updated after any change or modification. - That closeout, feedback and review of changes is made. Examples of MOC; - Equipment changes such as rebuilding a fuel system or replacing a loading instrument. Adding a new ship is also a change in equipment. - Operational changes such as a new trade area, new cargoes carried implementation of new procedures or deviation from operational procedures and safe work practices. - Organizational changes such as changing the PIC for the ship, taking a new ship in service, increasing or decreasing the number of key staff onboard the vessel or in the office, new employed or moved / promoted personnel.
Emerging requirements for the concerned changes may be legislative (rules and regulations) or industry recommended best practices (VIQ, safety criteria’s etcetera), both permanent and temporary required changes. This cover areas such as; - Safety - Environmental and energy saving - Security - Health - Operational, including navigation, engineering, maintenance, cargo and mooring. Sources that will provide this information are; - Frequent newsletters by class, flag states, industry organizations etcetera. - Participation in industry forums like ship owner’s organisations and their associated groups/meetings/conferences for HR, safety, technology etcetera. - Close relations with suppliers and participating in their conferences etcetera. - Close relations with customers and participating in their conferences, working groups and frequent operational follow up meetings. - External inspections and audits onboard by oil major’s representatives, class and PSC. The responsibility for monitoring these emerging requirements rests with the staff within the organization that work with the concerned topics. New requirements are shared and discussed at the office meetings and informally with concerned responsible managers. The Management of Change process is initiated when someone (anyone within the company) identifies the need for change, or recognises that a change situation is developing. At this stage it shall be decided if the change is needed and if it does require a MoC process? A change can be permanent, temporary or an emergency change. Some changes do not require a MoC process, such as; replacement with identical part, domestic activities and changes already controlled by other management processes. In order qualify the change and determine the appropriate next step a list of “pre-screen” questions can be used. If the answer to any question below is “NO”, than the change is to be controlled by the MoC system in the appendix. Change in ship/facility mode - Is the new mode of operation equivalent to a previous mode of operation that was managed successfully? - Is the present crew familiar with this type of operation? - Have all shore and shore-interface modifications for the new mode of operation been carried out before? - Does mode change require modification to procedures and manuals?
New equipment or software - Does the new equipment have same performance, functional, material, maintenance, control systems and dimensional specifications as old equipment? - Are the existing procedures applicable to the new equipment? New hazardous cargoes/hydrocarbon/chemical - Does new cargo/hydrocarbon/chemical have similar properties to previous in terms of; o Fire & explosion o Toxicity o Corrosiveness o Reactivity o Spill response o Physical properties (boiling and freezing points, thermal expansion, decomposition, vapor pressure) o Chemical compabilities with other cargoes/materials handled? Handling new cargoes/material - Are existing equipment and crew skills adequate for safe handling, loading or unloading of the new cargo/material? - Are procedures for handling new cargoes/materials available? Personnel - Does the new candidate meet the competencies, training, education and experience requirements for the position? - For organizational changes ashore (eliminating positions, restructuring etc.) do reporting relationships, job responsibilities, work load etc., remain unchanged? Contractors - Changes to contractors working in areas or activities so designated by company or regulation, should be subject to MoCs, unless the contractor change is a “replacement-in-kind”. A positive answer to all the questions below is a good indication of replacement-in-kind. o Have contractors worked with company before? o Are contractors familiar with company regulations and personnel? o Have contractors worked with this type of ship/facility before? o Have contractors worked with this type of equipment before? o Have contractors been qualified (competency, financial, insurance, billing) by the company before? o Will there be company resources to properly monitor and supervise the quality of the work and the safety of the contracted personnel? Corrective action requests/hazard analysis recommendations - Changes initiated as a result of a non-conformance, corrective action, incident investigation, hazard analysis etc. can have the potential to affect onboard and shore operations and as such should be evaluated via the MoC system. o Is the change a replacement in kind? o Is the type of change exempt from the company’s MoC program? New regulations, procedures, standards, registry - The preliminary impact analysis may take the form of a gap analysis to identify the new requirements proposed and how the new requirements change the current ways. This type of change almost always requires an MoC to comprehensively identify potential impacts and develop an implementation plan.
Authorization of changes For any change it shall be established who is/shall be: Responsible, Accountable, Consulted and Informed. As an example, the level of authority to approve different changes is divided as follows depending on the area of change; Personnel changes are normally authorized by HR & Crewing Manager but changes in the manning level of key positions or to promote / employ a Master or C/E must be approved by the Managing Director. Technical changes of smaller nature are normally authorized by the Technical Superintendent responsible for the ship but major changes must be approved by the Technical Manager. Procedure changes in HSE Management System and other controlled documents are normally authorized by the HSE Manager but major changes like new HSE Management System must be approved by the Managing Director. Common for all affected changes is that they shall be risk assessed, approved and documented. Changes controlled by be office shall be shared with the “onboard leader team” for consultation and information. Minor changes onboard can be authorized by the Master or Chief Engineer. The definition of minor changes is then something that do not require approval by office as per the established routines for purchasing, document changes or crew changes. Examples of such minor changes are; - Changes in documents not controlled by the office. - Changes in onboard routines that are not controlled by the HSE MS or other controlled document. - Changes in important set points like safety valves release pressure. If there should be any doubts of what level of authority that is required to approve a change it is always the higher rank that is authorized. Also for minor changes done without office approval is still needed risk assessed, approval and documentation. A checklist for ensuring the management of change process onboard is available in the appendix.
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