ALKYL AMINES CHEMICALS LTD.

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PROCEDURE FOR MANAGEMENT OF CHANGE Procedure No. IMSP/TC/H/07

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1. Objective To establish a procedure for "Management of Change”

with proper approvals and documentation.
2. Scope Applicable to all departments at location of Alkyl.
This procedure is applicable to carry out formal Quality,
Environment, Health & Safety (QEHS) impact prior to
implementation of any
• Change / modification in existing unit
• Installation
• Introduction of new product.
• Change of critical raw material Source
• Substantial modification to a facility ( addition or removal
of hardware )
• Substantial modification to operating parameters outside
a define range.
• Modification to critical parameters and safety thresholds
with a potential impact on persons, product quality, assets
and the environment.
• EHS review must be considered for all modifications.
• This procedure is applied for Permanent or Temporary
modification also.
• Safety review of any significant modification and before
start-up of new facility.
• Quality parameters change
• Change or Addition of key person to the system
• Preventive Maintenance Schedule
• Legal, statutory requirements.
• All Capex Jobs
Essentially, there needs to be:
1. A rigid procedure to ensure that all modifications are
authorized by competent persons.
2. A standardized method of safety assessment to help
identify all the consequences of a modification, specify
safeguards and maintain compliance with operating
licenses.
A system to ensure that completed modifications are
accepted by competent persons, to ensure that the work is
complete as specified, tested the QEHS assessment is
complied with, process personnel trained, and records
updated; and everyone concerned including all process
and maintenance personnel must be made aware of the
modification control system and its purpose.
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PROCEDURE FOR MANAGEMENT OF CHANGE Procedure No. IMSP/TC/H/07

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3. Reference Clause No.8.1,8.1.3 & 8.2, of ISO 9001:2015, ISO

14001:2015, ISO 45001:2018 and ISO 50001:2018, Alkyl
IMS Manual.
4. Responsibility & Initiator ( FH):
Authority ● Dept. which requires change / modification to fill Change
/ Modification form before execution for initiation.
● To Carry Out HIRA and Aspect Impact.
● To coordinate for completing the MOC.
● To conduct review before execution of project with EHS
Dept.
● Closure of Management of Change Form
● To co-ordinate for completing the review points
FH-EHS
● To consider statutory requirement during review.
● To work for review and safety study Other Concern
( FH):
● Assessment of QEHS impact in their affected area.
FH(TC):
● Periodic review, implementation & monitoring of MOC
system at site/s
● Preparation of proposed drawings / P&ID.
● Maintain the records of all completed MOCs.
OTHER/Concern FH:- Assessment of impact of change.
GM (Works):
●Responsible & Authorize for final approval of
Management of Change
5. Glossary & TC : Technology Center
Abbreviations: MOC : Management of Change
QEHS : Quality, Environment Health and Safety
P&A : Personnel and administration dept
SIC : Shift In charge
PID : Piping & Instrumentation Diagram
CQC : Central Quality control laboratory
PPE : Personal protective equipments
HIRA : Hazard Identification& Risk Assessment.

Plant Modification : "Plant Modification" means any of

the following
- Addition of equipment.
- Replacement of equipment with size change or change
in material of construction.
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- Addition of piping/valves/fittings. - Addition of

instrumentation/interlock.
- Replacement of piping/valves/fittings with size change or
change in material of construction.
- Any other changes, which would call for, change in P & I
diagram but no major change in operating procedure.

Process Modification
Any change to the process described in the operating
instructions manual or to the normally accepted operating
procedure, temporary or permanent. Including process
materials, services, experimental program, and products
purchased for resale and ancillary items such as cleaning
materials.
Written operating instructions covering the change must
accompany the modification certificate.
Change or Addition of person to the system to be
considered.
Natural Calamities for change (i.e. Flood, Earthquake etc)
to be considered.
Software Modification
I. Multiple changes to software or any additions/deletions
to program instructions.
II. Upgrading software releases.
III. Changes to plant trip settings.
IV. Operating instrumentation manually by forcing drives
etc. to assist with plant operations or maintenance if a
hazardous situation may occur. Changes which affect the
plant operating instructions or process.
Major (Significant change): Which can adversely impact
on QEHS & Energy performance
Minor (In-significant change): Which cannot be
adversely impact on QEHS & Energy performance
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6. Procedure
Action Activity Details Reference
Step
MOC Numbering System : MOC No should be in the following format FORM/H/T
Location(P/K/D/H)/Plant/Initiator Dept. /Financial Year/Number C/70
1.0
e.g : K/S16/CQC/2019-20/01
P/S1/CQC/2019-20/01
2.0 Following nomenclature to be used for Kurkumbh plant
S1 Production 1 - DEHA Plant
S2 Production 1 - Hydrogen Plant
S3 Production 1 - Methyl Amines Solution & Anh storage. .
S4 Production 1 - Utilities
S5 Production 1 - Effluent Treatment Plant
S6 Production 2 - Ethyl Amines Plant
S7 Production 2 - Utilities
S8 Production 1 - AMINEHCL
S9 Production 1 - MPP-I
S10 Production 1 - MPP-III
S11 Production 3 - AmineHCl Powder Plant-1
S12 Production 2 – Boiler (Bagasse/FO/Coal)
S13 Production 1 – Pilot Plant
S14 Production 2 – Acetonitrile Plant
S15 Production 3 - AmineHCl Powder Plant-2
S16 Production 3 - AmineHCl Powder Plant-3
S17 Production 3 - AmineHCl Powder Plant-4 & 5
S18 Production 1 – DIPEA PLANT
S19 GENERAL Area
S20 HYDROGEN PLANT (NEW)
S21 ETHYL PLANT (NEW)
S22 BOILER (NEW)
S23 ETP (NEW)
S24 DEK PLANT
S25 TAA PLANT
S26 TEMPOL PLANT
S27 R-5001 (NEW D-6/2)
Following nomenclature to be used for Patalganga plant
S1 - Plant 1 (MPP)
S2 - Plant 2 (Methyl Amine/Ethyl Amine/Absolute Alcohol/Aldega)
S3 - Dispatch and SMPV
S4 - Utilities
S5 - Effluent Treatment Plant
S6 - Boiler (A-7)
S7 - Boiler (A-25)
S8 - Electrical
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Action Activity Details Reference

Step
S9 - Other General Area
Following nomenclature to be used for Dahej plant
S1 – Methyl Amine Plant
S2 – Process Plant
S3 - Dispatch and SMPV
S4 - Utilities
2.0 S5 - Effluent Treatment Plant
S6 - Boiler
S7 – Electrical/ MCC
S8 – Acetonitrile Plant
S9- GENERAL
S10- RO & MEE Plant
Following codes to be used for plant
Technology Centre Department : TCD
Production : PROD
Production 1 : PROD1
Production 2 : PROD2
Production 3 : PROD3
Quality Control : C.Q.C
Instrumentation : INST
Electrical : ELECT
Mechanical Engineering : MECH
3.0
Process Engineering : PE
Personnel & Administration : P&A
Commercial : COMM
Computer and Networking System : SYS
Account : ACCT
Safety, Health and Environment : EHS
TS : Technology services.
Project : Proj
R&D : RND
Boiler : Boiler
Once a need for a modification in a particular section emerges, the
FORM/H/
4.0 Functional Head and/or his delegates shall fill Management of Change
TC/70
Form
Every change in process rout, specification of product, building, site
change, key person, and equipment modifications must routed through
5.0
MOC procedure. Documentary changes shall be done as per procedure
defined in IMS.
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Action Activity Details Reference

Step
Initiator will arrange meeting with Multidisciplinary teams representing
all the functions. This Multidisciplinary team representing all the function
which is affected by new modifications will analyze the MOC request.
And if required they will take necessary advice from Process Safety
Expert. Field round shall be planned immediately for required changes
WI/H/TC/04
6.0 if any based on requirement of team members. In this meeting,
requirements shall be finalized.
MOM of MOC initiation meeting should be recorded with Responsibility
and Target Date.
MOC Initiator will hand over the form along with filled MOM to the
Functional Head Technology Center or his delegates
Then Functional Head Technology Center or his delegates will hand
7.0
over the form along with schematic diagram if applicable to initiator.
Initiator will take comments from respective FH or his delegates based
8.0
on scheme provided.
EHS in charge must be take safety review of any modification and he FORM/H/
8.1
should put his remark on MOC form TC/70

QEHS impact review should be performed at the movement of request FORM/H/

8.2
of modification, before commissioning of facility. TC/70
Initiator with consultation of concern HOD/impacted department shall
FORM/H/
8.3 identify the type of change i.e. Major/Minor & appropriately record it in
TC/70
change control proposal format.
Quality impact shall be done by TC,PE ,Production & QC dept. where
8.4 applicable

9.0 A formal Identification of affected operating procedures , PID , Training ,

PPE requirement emergency procedures or many others to be updated
as a part of MOC procedure, if required.
Disposal/Recycle of removed equipment or instrument to be decided
based on the condition of particular Equipment.
Concern FH i.e. FH (ES) for Mechanical Equipment and FH (Electrical
and Instrumentation) for Electrical Equipment or Instrument will certify
the fitness of that equipment.
If it is fit for use, it will be transferred to Reuse Yard and informed to
FH(TC) with details. FH(TC) will check possibility of using the same as
per requirement. If any equipment or Instrument in yard is lying for 3 or
more than 3 years, it has to be transferred to Scrap Yard after approval
from VP(Mfg) / VP(Technical). The same will be disposed as per Scrap
Disposal Procedure
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Action Activity Details Reference

Step
If removed Equipment or instrument is not fit for use, it will be
transferred to scrap yard and later will disposed as per Scrap Disposal
Procedure after approval from VP(Mfg) / VP (Technical).
The Spares related to above equipments/instruments lying in stores to
be maintained till disposal of that equipment. If spares of disposed
equipment or instruments are not usable for other services or it is in the
category of non-moving i.e. lying for more than 5 year, it is to be
disposed off.
Follow up must be done for above affected aspects to insure
10.0
compliance of all requirement before modification
Respective FH shall update required standards and applicable “AACL
11.0
Guidelines” whenever applicable.
After complete review it is to be send to GM-Works for approval and
12.0 comments, if any.GM-works will decide the schedule for revisiting and
reviewing, if required.
13.0 After getting final approval from GM- Works, modification shall be done.
Change of Management" form shall assess & signed by :
Functional Head Electrical
Functional Head Instrumentation.
Functional Head Mechanical Engineering.
Functional Head Production.
Functional Head Functional Head Fire and Safety.
Functional Head Functional Project.
Functional Head Quality Control. FORM/H/
14.0
Factory Medical Officer; FH P&A. TC/70
Functional Head Technology Center Dept.
Functional Head Functional Commercial.
Document coordinator (IMS)
The proposal shall be approved for implementation by GM-Works.
In case the above designated persons are unavailable for signatures
and the execution of the modification becomes urgent, the respective
delegates of the Functional Head can approve the MOC.
Based on comments, if required schematic diagram will be revised by
functional Head Technology Center or his delegate.
The revised scheme to be signed by respective FH as per format FORM/H/
15.0
and maintained as separate revision. TC/70
After approval of MOC from GM-Works initiator will give one copy
(Soft/hard) to functional Head Technology Center or his delegate.
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Action Activity Details Reference

Step
The HAZOP/ASPECT, IMPACT/HIRA recommendations to be
considered, if any before finalizing the modification scheme. The
Equipment layout to be finalized by FH (Mechanical Engineering)/FH FORM/H/
16.0
(Project). Based on the approved schematic diagram and HAZOP TC/04
recommendations, Functional Head Technology Center or his delegate
will make the modification proposal if required.
Any significant /quality impacted changes i.e. change in manufacturing
location, manufacturing process, Route of synthesis, Critical Raw
material, Equipments, specification change will be informed to FORM/H/
customer and if required approval will be taken. TC/70
17.0
After assessment of such major change executer department will Communicati
communicate the change to customer through marketing/ export. Also If on-by mail.
required, EHS impacted changes shall be communicated to relevant
stake holders.

If the modification budget is exceed to Rs 3 Lacs, MOC initiator will

make the PEAR with help of FH (TC) for Approval. PEAR Approval will
18.0 be taken by MOC initiator. For budget less than Rs 3 Lacs, FH (TC) can
provide job no based on requirement. After receiving the Job No,
FH(TC) will issue the Modification Proposal for the given MOC. if req.

19.0 If required legal compliance must be obtained from regulatory authority.

MOC Initiator (FH) will close the MOC. Original MOC will be maintained
FORM/H/
20.0 by Initiator dept and copy will be provided to TC. Review of MOC will be
TC/70
done by initiator dept and TC, if mentioned in MOC

For Temporary modification removal date to be mentioned on MOC

form. And after due date it is to be cancel or removed from the list. The FORM/H/
21.0
extension or change of date for cancel or removal of modification shall TC/70
be approved from GM(Works).

FH(TC) or his delegate shall be responsible for reviewing of all MOCs

22.0
fortnightly.

For modification in existing system, FH(TC) or his delegate is

responsible to issue pre-scheme on the basis of initial discussion after
23.0 MOC raised by initiator and after comment from all the concern
department, FH(TC) or his delegate shall provide final scheme to
executor along with modification proposal
For new project/infrastructure , FH(TC) or his delegate is responsible to FORM/H/
24.0
issue basic engineering package along with P&ID’s of plant to executor TC/104
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7. Revision History
Issue Revision Change details
Number Number.
03 00 Procedure reviewed & new issue number -03 is given.

03 01 As per comment after internal audit and Departmental review

03 02 Updated for addition of plant no. S27-R-5001