HSE-SAF-PRO-00-0013

SAFETY
Rev. 4
06-Sep-2015
SAFETY VARIANCE PROCEDURE
Page 1 of 5

TABLE OF CONTENTS

1. INTRODUCTION .......................................................................................................... 2

2. SCOPE & PURPOSE ................................................................................................... 2

3. DEFINITIONS ............................................................................................................... 2

4. PROCEDURE ............................................................................................................... 2

5. RESPONSIBILTIES ..................................................................................................... 4

6. REFERENCES ............................................................................................................. 5

7. ATTACHMENTS .......................................................................................................... 5

8. APPENDICES .............................................................................................................. 5

9. REVISION HISTORY.................................................................................................... 5

Rev. Issue Date Amendment Description Prepared By Reviewed By Approved By

Refer to Section 9 - Revision History
4 06-Sep-15 Haresh Patel Refer sec.9 Refer sec. 9
Change category: Type-1
Next Scheduled Periodic Review: September/2018

HSE-SAF-PRO-00-0013 Page 1 of 5
 HSE-SAF-PRO-00-0013
SAFETY
Rev. 4
06-Sep-2015
SAFETY VARIANCE PROCEDURE
Page 2 of 5

1. INTRODUCTION

It is recognized that all situations cannot be addressed in any one procedure, program or
standard. Therefore, this procedure shall be used for situations where it is required to vary
from the established Q-Chem safe work practices.

2. SCOPE & PURPOSE

The purpose of this procedure is not to circumvent established safe work procedures,
programs or standards but to address case-by-case situations where following the written
procedure is not possible or an equally safe alternative that make more sense for a task.
This procedure applies to all intended safety deviations in the Company to the written
requirements of the Q-Chem Safety department (it includes policies, programs, plans,
procedures, guidelines, manuals and standards).

3. DEFINITIONS

 FSC: Fire and Safety Coordinator

 Originator: The person initiating the Safety Variance Permit. He/she shall be of
supervisor level or above.
 Safety Variance Permit: The permit that identifies necessary safeguards and
compensating measures and authorizes work that deviates from the established safe work
practices.

4. PROCEDURE

4.1. Safety Variance Permit

i. Section A, B and C of the Safety Variance Permit (HSE-SAF-SFM-00-0022) shall be

initiated and completely filled out by the Originator.
ii. A Hazard Analysis shall be conducted for all Safety Variance Permit requests. The
minimum required personnel for conducting the hazard analysis are as follows:
a) Originator
b) Affected Area Engineer or Supervisor
c) Safety Section Representative
d) Technical /Maintenance Representative (if work involves either department)

NOTE
Safety Section representative can be Safety Specialist, Safety &
Emergency Response Specialist, Process Safety & Compliance
Coordinator, Industrial Hygienist or FSC.

iii. The Hazard Analysis team shall conduct a hazards assessment using Hazard Analysis for
Safety Variance Permit (HSE-SAF-SFM-00-0120) and attach it to the Safety Variance
Permit.
iv. The team shall document the necessary safe guards and/or compensating measures on
the Safety Variance Permit.

HSE-SAF-PRO-00-0013 Page 2 of 5
 HSE-SAF-PRO-00-0013
SAFETY
Rev. 4
06-Sep-2015
SAFETY VARIANCE PROCEDURE
Page 3 of 5

v. The Originator, seeking approval, shall prepare a completed variance package with all
applicable documents for review.
The package shall include the following documents as minimum:
a) Safety Variance Permit
b) Hazard Analysis for Safety Variance
vi. Based on the type of variance the following additional document(s) may be considered as
attachment. e.g.:
a) Job Safety Analysis
b) Marked Up P&ID
c) Rescue Plan
d) Pre Plan (for fire Prevention/Control)
e) Copy of previous Safety Variance Permit for the same task done in past
f) Operational Isolation/Action Plan
vii. The Originator shall present the Safety Variance Permit along with all applicable
documents to the Managers/Superintendents and obtain final approval from the following:
a) Originator Area Superintendent
b) Originator Department Manager
c) Affected Area Manager (if the variance is required for an area outside of Originator
Department Area other than Technical/Maintenance Manager/Superintendent
(RLOC)
d) Technical Manager/Superintendent (RLOC)
e) Maintenance Manager/Superintendent (RLOC)
f) Safety Manager/HSE Superintendent (RLOC)
g) Operations Manager/Plant Manager (RLOC)
viii. Extension of Safety Variance Permit: Plan the task in such a way to complete the task
during validity of Safety Variance Permit. In extreme case, Safety Variance Permit validity
may be extended. To extend the validity of the Safety Variance Permit, the Originator shall
obtain the original Safety Variance Permit from the HSE Administrative Assistant, fill the
date and time in Section H of the Safety Variance Permit and get the approval for
extension from following:
a) Originator Area/Department Manager/Superintendent (RLOC)
b) Safety Manager/HSE Superintendent (RLOC)
The Originator shall make copies of the extended approved Safety Variance Permit and
deliver the original documents to the HSE Administrative Assistant.

4.2. Prior to Starting the Job

i. All parties involved in executing the work covered by the Safety Variance Permit shall be
briefed on the details of the variance and agreed safeguards, Hazard Analysis for Safety
Variance and other applicable documents.

HSE-SAF-PRO-00-0013 Page 3 of 5
 HSE-SAF-PRO-00-0013
SAFETY
Rev. 4
06-Sep-2015
SAFETY VARIANCE PROCEDURE
Page 4 of 5

4.3. Records and Documentation

i. The Originator shall make copies of the approved Safety Variance Permit along with all
applicable documents and deliver the original documents to the HSE Administrative
Assistant.
ii. HSE Administrative Assistant shall provide the number to the Safety Variance Permit and
upload a scanned copy of Safety Variance Permit along with all applicable documents on
Safety Web Page.
iii. Approved Safety Variance Permits shall be maintained for the life of the Plant.

4.4. Follow up

i. Follow up is required if Section G of the Safety Variance Permit (HSE-SAF-SFM-00-0022)

indicates any comment or suggestion for improvement.
ii. Follow up from Safety department is required to consider change in the Safety Document
or any other respective department to prepare action plan to avoid further Safety Variance
Permit for the same task in future.
iii. If the Safety Variance Permit (Section G) prompts a change to the safety documents, HSE
Administrative Assistant shall add this into Safety Manual Feedback for further follow up.

5. RESPONSIBILTIES

5.1. Safety Section

i. Maintain all approved Safety Variance Permits for the life of the Plant.
ii. Provide number to all the Approved Safety Variance and upload onto Safety Web Page.
iii. If the Safety Variance Permit (Section G) prompts a change to the safety documents,
same to be added into Safety Manual Feedback for further follow up.
iv. Review/update this procedure as per the ‘Document Revision, Update and Tracking
procedure’ (QC-IMT-PRO-00-0001) or whenever a revision/change is recommended.

5.2. Originator Department

i. Identify the requirement of Safety Variance Permit.

ii. Facilitate the Hazard Analysis for Safety Variance Permit.
iii. Attach all applicable documents with Safety Variance Permit as mentioned in this
procedure.
iv. Get approval from respective personnel indicated in this procedure.
v. Make copy of Safety Variance Permit along with all applicable documents and send only
Original Safety Variance Permit and other associated documents to HSE Administrative
Assistant.
vi. Communicate to affected personnel as identified in Section F of the Safety Variance
Procedure.
vii. Ensure that the task is executed as per Safety Variance Permit requirements.

HSE-SAF-PRO-00-0013 Page 4 of 5
 HSE-SAF-PRO-00-0013
SAFETY
Rev. 4
06-Sep-2015
SAFETY VARIANCE PROCEDURE
Page 5 of 5

6. REFERENCES

None

7. ATTACHMENTS

7.1. Safety Variance Permit - HSE-SAF-SFM-00-0022

7.2. Hazard Analysis for Safety Variance Permit - HSE-SAF-SFM-00-0120

8. APPENDICES

None

9. REVISION HISTORY

Rev Issue Date Amendment Description Prepared By Reviewed By Approved By

 Change Category: Type-1

 Included clarification on documents to be
attached with Safety Variance Permit
and record retention as per PSM Audit
action item (4.1.(v) & (vi)). Carl Benson Carl Poldrack
Abdul W Shaikh Kevin C Kabell
 Review frequency included (5.1.(iv)) Syed Rafiullah Saleh Abdulla
Venkata Chandra Gary L Piana
4 06-Sep-15  If the Safety Variance Permit (Section F) Haresh Patel Nitin Saraf Chad A Jennings
prompts a change to the safety Gopalakrishnan Ali Al-Marri
documents, same to be added into Pedrito Fugen Roehl Bartolome
Safety Manual Feedback for further Christopher de Abdulla S Al-
follow up (4.4.(iii) & 5.1. (iii)). Chavez Khulaifi
 Added Section H in the Safety Variance
Permit. A requirement for Extension of
Safety Variance Permit included (4.1.
(viii))
This revision includes period review as well
as change in Safety Variance Permit,
addition of approval authority, additional
3.0 30-Jun-13 document to be attached with Permits (i.e. Haresh Patel Review Team Carl Poldrack
Hazard Assessment ,JSA, Method of
communication ,Pre-plan, Mark UP P& ID
etc. ,along with Safety Variance Permit)
Minor Change: Incorporated changes in
2.1 02-Apr-08 Management positions and RLOC Imran Malik
positions.
This revision includes a revised Safety
2 01-Jan-06 Variance Permit and the inclusion of the Jarvis Olsen
Sr. Safety Engineer approval.

HSE-SAF-PRO-00-0013 Page 5 of 5