Chapter 11 / MANAGEMENT OF CHANGE AND DOCUMENT CONTROL
Chapter 11
MANAGEMENT OF CHANGE
AND DOCUMENT CONTROL
CONTENTS
11.1. Purpose 3
11.2. Responsibilities 3
11.3. Procedure 4
11.3.1. Identification of changes 5
11.3.1.1. Regulatory Changes 5
11.3.1.2. Commercial Changes 5
11.3.1.3. Technical Changes 6
11.3.1.4. Operational Changes 6
11.3.1.5. Changes to personnel 6
11.3.1.6. New Experience 7
11.3.2. Change process 7
11.3.2.1. Handling of Change Request form 7
11.3.2.2. Risk identification and Risk Assessment (RA) 7
11.3.2.3. Development, implementation and monitoring 8
11.3.3. Introduction of newly acquired vessel into the SMS 8
11.3.4. Vessels leaving management 9
11.3.5. Change of vessel’s name or Flag 9
11.3.6. Changes which do not impact on Operations Integrity 9
11.4. Control of Documents 9
11.4.1. Controlled documents and Data Maintained in Electronic Form 10
11.4.2. Identification, issuance, changes and distribution of the SMS documentation 10
11.4.2.1. Identification and issuance of SMS documentation 10
11.4.2.2. Changes to the SMS documentation 12
11.4.2.3. Document distribution 12
11.4.3. Record keeping 13
11.4.3.1. Purpose 13
11.4.3.2. Responsibilities 13
11.4.3.3. Storage & Protection 13
11.4.4. Minimum Retention times 14
11.4.5. Disposition 14
11.5. Relevant forms 14
11.1. Purpose
Even minor changes can affect safety, if they are not properly carried out and therefore require systematic review. Changes can result from new procedures, personnel or operating conditions, from introduction of third-party contractors or a new vessel, from installation of new equipment or components, new instrument settings (outside of normal operating limits), new regulations, etc.
Management of Change is a structured process which will ensure that proposed/forthcoming changes are fully evaluated and managed to ensure that arising safety, quality, health, security and environmental risks remain at an acceptable level. The purpose of this procedure is to ensure that:
- All changes affecting Company’s activities are properly identified and assessed.
- The potential consequences of a change and any required mitigation measures are identified.
- Actions to prevent problems due to changes are determined and implemented.
- All changes are evaluated and implemented in controlled and authorized circumstances.
- Assistance is given to staff in identifying hazards due to changes in order to reduce risks.
- Risks arising from any change remain at an acceptable level.
This procedure applies:
- Whenever we identify any change to the conditions which affect our activities.
- When our control mechanisms indicate the necessity to re-consider previous decisions.
This procedure is also applied to document control process.
11.2. Responsibilities
The DPA authorizes the approval of all permanent changes.
The Marine/Ship Managers are responsible for the approval of any temporary changes which also are reviewed by the DPA. Care shall be taken to identify all those positions that may be affected by the change, and they are responsible to ensure that those identified are made aware of the details surrounding the impact of the change.
As regards the document control process, the DPA is responsible for issuing and maintaining the SMS documentation and for retrieval of one series of them when obsolete. He is also responsible for maintaining master copies of all SMS documentation and together with other key staff, is responsible for identifying the needs for new procedures.
All Department Heads are responsible for the evaluation and implementation of all changes relevant to their department. They are also responsible for the management of their department’s controlled documents and the handling of all relevant correspondence.
The Master is responsible for the evaluation and implementation of onboard changes. Care shall be taken to identify all those positions that may be affected by the change, and the Master is responsible to ensure that those identified are made aware of the details surrounding the impact of the change. He is also responsible for the management of controlled documents onboard and the handling of all ship’s correspondence.
The C/E is responsible for the evaluation and implementation of all changes relevant to his department. He is also responsible for the management of his department’s controlled documents and the handling of all relevant correspondence. Authority for changes to critical systems/ equipment should lie with the C/E or the General Manager, dependent on the time frame of the change.
11.3. Procedure
Changes in operations, procedures, personnel, etc. must be evaluated and managed to ensure that arising risks remain at an acceptable level. This procedure may be utilised when the control and monitoring mechanisms (audits, inspections, reviews, etc.) indicate that the Company needs to re-evaluate its approach to certain matters. The Management of Change procedure intends to:
- Include steps that lead to a clear understanding of the safety, quality, health, security and environmental implications of a change.
- Ensure that all changes comply with regulations, industry standards and original equipment design specifications.
- Ensure that there is an appropriate procedure in place for staff handover and familiarisation on changes both ashore and onboard vessels.
- Identify and document any training needs arising from any changes and ensure that all appropriate personnel receive the required training within a specified period.
- Ensure that all changes are developed in consultation with those who will have to implement them, in order to be better suited to their purpose and more readily accepted.
Temporary changes, such as hose connections between process–utility systems, which could have a significant effect on safety, quality, health, security or the environment shall be documented (form D 003). The duration of the change shall be noted. To reverse the temporary change back to the original, a Change Request form (D 003) is also to be completed. Temporary changes shall not exceed the initial authorisation for scope or time without review and re-approval.
Emergency changes shall be also recorded in the form D 003. For an emergency change, verbal authority may be given by the General Manager, the DPA, the department heads or the Master, provided that it is supported by a Change Request Form (D 003) at the first available opportunity.
All temporary, emergency and permanent changes shall be evaluated and properly managed in order to ensure that Company’s standards are not compromised. Techniques such as risk assessment shall be used for significant changes, to fully understand their impacts and to prioritise the most effective risk reduction measures.
All changes and the review process that led to their approval shall be documented and records shall be properly maintained. Care shall be taken to identify all those positions that may be affected by the change. The Company shall ensure that those identified understand the extent and likely impact of any planned change and that the evaluation results are communicated to affected persons. Any improvements shall be recorded and appropriate action shall be taken that would include a close out process.
The form D 003 “Change Request” must be completed for all proposed changes. Where doubt exists, this form shall be used. The originator completes Part A of the form and forwards to his Master/department head, as appropriate. The Master or the department head review the proposed change, and regardless of whether he supports it or not, he forwards it to the DPA. The DPA ultimately approves the proposed change. The approval is then communicated to the Department Heads and to the responsible Master/department head in order to arrange the further actions.
The DPA or the relevant department head shall inform the originator on the approval or on reasons of rejection.
11.3.1. Identification of changes
Change is defined as “any new condition which might affect Company’s activities” which justifies a structured analysis in order to determine any further actions needed, as well as "any modification other than replacement in kind". In other words, Change is any new aspect which, if not handled systematically, may have adverse effects on safety, health, security, environment protection or customer satisfaction. The experience and understanding of the Company’s staff is the main criterion for identifying which changes will be handled by this procedure. Such changes could be:
- Regulatory changes.
- Commercial changes.
- Technical changes.
- Operational changes.
- Changes in the human resource profile/changes to personnel.
- Changes necessitated from gathered/new experience, etc.
11.3.1.1. Regulatory Changes
All department heads are responsible for tracking, identifying and accessing applicable forthcoming rules and regulations of the IMO, Flag Administrations, Class Societies and industry organizations and evaluating their potential impact on Company’s operations. In this respect several techniques are employed, which information from the vessels’ Class Societies and industry organizations associations and direct communication with Flag Administrations regulatory agencies.
The tracking of forthcoming regulations is an ongoing process. Each department head shall inform the DPA who shall maintain a list of applicable forthcoming regulations, indicating the means/ persons by which these regulations can be accessed. The DPA, in cooperation with the department heads, correlates these regulations to the Company’s activities and the safety, quality, health and environmental aspects associated with them and address them in the Shore Safety or the Management Review Committee, to ensure that these requirements will be complied with in due time (see Appendix III: a variety of sources of information on applicable regulations).
11.3.1.2. Commercial Changes
Such changes may be:
- Changes in the market conditions which may necessitate a change in policy or change in the vessel type operated.
- Changes in the contractual agreements with customers e.g. a different Charter Party.
- Changes in the political environment (e.g. war) that affects Company’s business plans, etc.
11.3.1.3. Technical Changes
Such changes may be:
- Non routine maintenance tasks.
- Change of equipment/system type or changes outside the design (specification) of the installed equipment/system.
- New system or equipment which may be installed on vessels (e.g. a new incinerator).
- A new vessel entering fleet.
- New technological solutions available in the market.
- New rules and regulations affecting the technical condition of the managed vessels, etc.
The General Manager ensures that all applicable drawings, procedures and other technical documents are updated following any change or modification.
11.3.1.4. Operational Changes
New types of operations may be:
- Navigating in areas with special conditions (e.g. in rivers or in ice).
- Committing to carry a cargo with extra-ordinary characteristics.
- Vessels’ types within the fleet.
- Fleet size.
- Flag or Class Society’ changes affecting operations.
- Planning an un-usual cargo operation (e.g. to unload in barges), etc.
11.3.1.5. Changes to personnel
Changes to personnel and changes in the human resource profile of the Company/fleet may be:
- Major changes to shore organisation (i.e. replacement of a department head).
- New Manning agent.
- New crew nationality.
- Changes to the minimum safe manning of a vessel.
- New requirements related to crew composition and competence, etc.
Necessary levels of individual and collective experience and knowledge shall be carefully considered when personnel changes are made. The number, experience and skills of personnel shall be sufficient under different operational conditions. For major changes to the shore Organisation such as changes in reporting relationships, elimination of positions, restructuring, etc. the change process shall be reviewed for the impact to both the Organisation and the SMS. The department heads, responsible for supervising or managing the functions undergoing change, shall convene a Shore Safety or a Management Review Committee meeting in order to reassign the responsibilities and to review the impact of all changes to the Company’s roles and responsibilities.
11.3.1.6. New Experience
Experience gathered from the day-to-day operation, which indicates the existence of risk shall be identified and handled in accordance with this procedure. Such new experience may be:
- Incidents, near misses, non conformities, defects, etc.
- Outputs from the Shore Safety/Management Review Committee meetings, etc.
11.3.2. Change process
11.3.2.1. Handling of Change Request form
The DPA, on receipt of a Change Request form D 003,dix 1 ?? allocates its particulars on the “Change Request Register” (form D 004). Depending on the importance of the change request, he circulates the form to the responsible department head(s) or he organises a Shore Safety or a Management Review Committee meeting in order for the Management to authorise or not the change.
Each change effected is subject to a review and, where new risks are identified, the adequacy of risk reduction measures shall be authorised by the General Manager. The reason for the change, a clear understanding of the safety, quality, health, security and environmental implications and the appropriate level of approval shall be documented on the form D 003. A time frame shall be also set for the completion of any proposed change.
As a general rule, persons directly involved in the change shall not be involved in its approval.
Initiation of any change on board is the responsibility of the Master and/or the C/E, with the consultation of the DPA or the other key shore staff. Once the process has been completed and signed off, a copy of the completed form D 003 is to be forwarded to the originator.
11.3.2.2. Risk identification and Risk Assessment (RA)
Every change identified is analysed in order to determine risks which may contain a danger to life, safety, quality, health, security, environment or property or may adversely affect Company’s Customers. The DPA and the relevant department head/Master shall ensure that the potential consequences of the change are identified, together with any required risk-reduction (control) measures. This process helps the Company to identify and prioritise the most effective risk-reduction measures. It will also identify residual risks that require management attention.
- If aspects of the change containing risk are identified, a RA should be carried out for each of the identified risks and the need for further action should be evaluated.
- If no risk is identified, no further actions are required.
The risk assessment may result in:
- Identification of resource needs.
- Identification of training needs.
- Revision of procedures.
- Updating of PMS/spares requirements/drawings and/or technical documents, etc.
This process is recorded in the Risk Assessment forms (see also the “Risk Assessment and Risk Management Manual”).