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Operational Risk Deviation ORD and ​Deviations Management Procedure​

Prepared By:
Hazhar Ramzi Reviewed By
Prod. Supervisor Siyar Ameen
30 Jan 2023 Training Coordinator
 Section - 1
​Operational Risk Deviation ORD ​
Operational Risk Deviation ORD
What is ORD:
When you intended to operate critical equipment or plant outside its normal operating envelope, or with protective devices,
controls, monitoring devices, or other safeguards that are not functioning as originally designed. This includes any impact on
organisational capability and or critical documentation that may compromise the operation of the facilities.

The ORD process provides the means to decide whether it is acceptable to operate equipment or plant with a known
abnormality, to identify what additional controls may be required to manage the risk and/or to identify how and when the
abnormality needs to be rectified.

Purpose:
Covers the relevant steps to assess, manage, control and report on adverse changes in critical assets, systems or other
abnormal situations that may increase levels of major risk.
It is intended to ensure that where DNO Kurdistan chooses to continue to operate with such abnormalities that it has
documented clearly the basis of why it is safe to continue to operate and when the issue will be resolved. In addition, it is
intended to ensure ORDs are well managed and visible.
ORD is primarily to conclude whether it is acceptable to continue to operate plant or equipment with a known abnormality

Roles and Responsibilities
The effective management of major accident hazards (MAH) is an
integral feature of responsible operations. Operational Risk
Assessment (ORD) is a mechanism to assess and manage these
risks.
Role Responsibilities
Plant Manager  Assembling a Risk Assessment Team that possess the necessary knowledge
and experience to identify the hazards and controls.
 Can appoint an ORD Team Leader and team in performance of hazard
identification and Risk Assessment, and in the identification of appropriate
risk management measures and/or controls.
 For ensuring quality standards are satisfied.
 Informing all necessary personnel of the nature of the ORD.
 Ensuring personnel with responsibility for delivering a control measure are
aware of this fact.
Closure of an ORD

Review and audit of the ORD process.

Ensuring that ORDs are considered as part of the Permit to Work process.

 Conducting monthly review of the ORD register and forms

Initiate Lead Participate Review Approve Operations Manager  Approval of ‘Red’ Residual Risk ORDs, providing there are sufficient
Plant Manager ● ● ● ● ● measures, controls and/or assurances that deem the situation to be above
Discipline ALARP and these are in place and maintained.
Specialists ● ● ●
Risk Assessment Discipline Specialist  Providing the relevant technical discipline input as necessary.
● ●
Team Establishing suitable performance criteria (in conjunction with the Process
● Engineers SME 
Ops Manager ● Safety Function).
(Escalation) Verifying that cumulative risk has been considered, as appropriate.

 Assuring that the risk profile is acceptable with the control/mitigation
measures in place
 Agreeing a Technical Expiry date for the ORD which aligns with the remedial
plan

Head of Ops Support  Updating and maintaining the ORD Register.

Risk Assessment Team  Actively participate in the ORD process.

 Help identify hazards, assess risks and identify control measures in order to
reduce the likelihood and consequences of an incident/accident from
occurring.
 Ensuring agreement is reached with regards to the overall ORD content.
 Countersign the finalised ORD on completion.
When ORD is required
An ORD is required whenever it is intended to operate critical equipment or plant outside its normal operating envelope, or with protective devices,
controls, monitoring devices, or other safeguards that are not functioning as originally designed. This includes any impact on organisational
capability and or critical documentation that may compromise the operation of the facilities.
The ORD process provides the means to decide whether it is acceptable to operate equipment or plant with a known abnormality, to identify what
additional controls may be required to manage the risk and/or to identify how and when the abnormality needs to be rectified.

The need to conduct an ORD would be driven by any of the following:

 An abnormal situation that may potentially increase levels of major accident risk.

 The loss or degradation of critical component.

 An unplanned fault or failure of existing equipment that is not covered by the approved design (hardware, protective systems, monitoring
devices, documents) that creates a hazard.

 An unplanned event or failure to meet safety related performance criteria.

 Long-term (>7 days) override or inhibit of an instrumented protective function.

The ORD process is intended to manage short term abnormalities only, with each ORD limited to a maximum period of 90 days only. Longer term or
planned changes should be managed as part of the Management of Change process.
 Identification:
Most commonly the identification of the need for an ORD is:
 Through observations during routine plant operations and maintenance activities
The Need for an ORD  Whilst conducting assurance routines
 During testing
 As a result of an unplanned event
The first stage in the ORD process is to clarify what constitutes the abnormality.
 By understanding the design intent and performance standard associated with the barrier that has
been compromised.
 By measuring the actual degree of impairment, degradation or failure.
 Quantifying the gap in performance.

Note: ORDs shall not be used as a convenient way of operating unsafe critical equipment or to endorse poor or unsafe operating practices; ORDs are very much a last resort,
and the use thereof must be fully justifiable. ORDs shall only be applied where there are sufficient and appropriate controls and/or mitigating measures in place to reduce
residual risks to an acceptable level. Furthermore, a clear plan must also be in place for resolution of the underlying problem within an appropriate timescale.

An overview of the context of an ORD and when and where there may be cause for use is shown in the schematic below:
PLANNED CHANGES PLANNED ABNORMAL CONDITIONS ABNORMAL CONDITIONS
MOC OVERRIDE MAINT DEFFERAL PROCESS ORD

A structured and systematic process for dealing An Intentional and approved short-term (<7 days) Deferment of overdue critical A formal response to an abnormal event; a process that aims to validate whether it is
with temporary and permanent planned inhibit of an instrumented protective device from maintenance at month end. acceptable to operate for a defined period, items of plant or equipment outside their normal
engineering, procedural or organisational change. performing its designed safe action function. operating (design) envelope, or with protective or monitoring devices, controls or other
safeguards that are not functioning as designed.

Risks are proactively assessed before the event occurs Risks are reactively assessed
 Initial Actions / Decisions
The observance of an abnormality will require an immediate decision to be made - to continue to operate if it is deemed acceptable
to do so or remove from service. If the initial decision is to continue to operate then this should be documented formally within
twenty-four (24) hours of the abnormality being identified.

The Plant Manager must review the initial decision where it is deemed safe to continue to operate, followed by a formal review and
approval on this decision from the where the residual risk is deemed ‘Red’ Operations Manager. For abnormalities which have
resulted in the loss of, or reduced functionality of critical equipment such that it is no longer possible for it to be considered an MAH
barrier (in such cases the relevant discipline specialist should also be consulted), then the initial decision shall constitute an interim
assessment of the ability to remain acceptable to operate until a detailed ORD can be completed (which shall be no more than 24
hours from the identification of the need for an ORD).

• The 24-hour interim timeline was devised as this shall allow for the following:

 Review of the abnormality and an assessment to determine whether it is an impaired Critical Function.

 Generation of remediation plan for the abnormality to be repaired / replaced.

 Full generation of a reviewed and robust Risk Assessment, including identified mitigations.

 Completed ORD approved by relevant technical, operational and management personnel.

• Included with the initial decision are the initial interim risk mitigations / controls that are to be implemented immediately.

The detailed ORD should be completed at the earliest opportunity. The conclusions, mitigations and controls of the detailed ORD
will take priority over the initial decision.

Note: The detailed ORD should be completed by a competent team of at least three people with
the relevant skills and experience given the nature of the abnormality or fault and should include
technical and engineering expertise from inception.
Steps to process and generate ORD
ORD HEADER
Installation:
Location:
Plant
Location / Equipment
ORD:
Location
(NINTEX Generated)
Location / Equipment Description
Revision:
Impairment Source: Compliance / Deferment
Management of ORD
Description: of SC Work / Process
Safety / Operational /
Human Factors
Operational Risk Deviation shall be
Date Raised: Finish Date: Return to normal Safety Critical: Yes / No Priority: High
Operations proactively managed throughout; this
Description: Provide a meaningful description involves five key steps, which are
Purpose: Provide details of the abnormal condition and include any interim control measures applied
summarised in the following sections of the
procedure.
ORD STATUS
Name Role Status Initial/Sign Date
ORD Team Lead
Discipline SME
Verified
SME Reviewed
Identification
Discipline SME SME Reviewed
ORD Team Lead Review Verified
Higher Authority
Facility Manager
Approved
Approved
Initial Actions / Decisions
ORD Team Leader Request Closure
Discipline SME Agree to Closure
Facility Manager Closed
ORD REFERENCE DOCUMENTATION
ORD Generation
Document
Document Number Document Description
Type
Operational Risk Assessment
ORD PEOPLE
ROLE NAME SIGNED DATE
Team Leader
Team Member
Name of the ORD Team Leader
Name of an ORD Team member (minimum of 3 persons team)
ORD People
Team Member
ORD TEAM
Tech Review SME:
SME:
Name of a Discipline SME related to the issue ORD Risk Assessment
Higher Authority Approver SNR Management where the ORD Risk is higher than approved thresh
hold, Acceptance of Risk on behalf of the Company
Facility Manager Approver Plant Manager
 ORD
Generation
ORD People

The main task of the ORD Team is to identify the Hazards and their Initial Risk,
and then identify Mitigation Controls that reduce the Initial Risk down to an
acceptable Residual Risk (i.e., once the Mitigation Controls have been Risk Values Description
implemented).

The members of the team who will create the ORD to manage the abnormal Initial Risk (IR) Identifies the likelihood of the Hazard
condition are entered on the ORD People section of the ORD. The composition of
this team is;
occurring and the severity of the impact of
that occurrence.
 ORD Team Leader

 ORD Team Member (must be 2 or more) Residual Risk The risk remaining once the Controls have
 Technical Reviewers / Subject Matter Experts (we will refer to this as SMEs)
(RR) been applied. It is calculated as the
maximum risk of all the Controls defined.
The SMEs are selected once the ORD risk assessment has been produced as
they are based on the SECEs identified in the risk assessment. The team that will
develop the ORD risk assessment is specified first as described below.
Operational Risk The Risk Assessment Team are required to quantify the
risk level associated with the following:
Assessment

Normal Operating Risk

Abnormal Risk

Mitigated Risk
Operational Risk The quantification of the risk level shall be in accordance
with the DNO Kurdistan Risk matrix (see Appendix B).
Assessment
Establishing Hazard Controls
ORD Controls
 Enter the description of the Control
Prerequisite
 Enter the Control Type ref to Table 5 Types of ORD Controls
 Where the control is Primary the Equipment reference must be added
and is optional and optional for other types of Control.
 The Residual Risk, as a result of applying the control, is selected from
the ORD Risk Matrix. While the Residual Risk is constrained to have the
same Severity as the Initial Risk identified on the Hazard, the
mitigation control can reduce the Likelihood of this occurring.
Primary
 Enter the Trade that will be tasked with completing the Action related
to the Control.
 The Expected Result is the result expected when performing the
verification that the Control remains effective throughout the Hazard
life cycle. For example, the status for a valve. This information is used
by when reviewing the Hazard Control Action to determine if the
review results are satisfactory or not.
Secondary
 Enter the Review Scheme identifies the frequency by which the
generated Hazard Control Action must be reviewed. The set of Review
Schemes available will vary depending on the client configuration. The
Review Scheme determines both Review frequency (e.g., x hourly,
daily, weekly etc.), and the threshold before reviews are deemed to be
critically overdue.
Description
Generally, a Control that has been initially applied to reduce the initial Hazard or extended to prevent escalation,
e.g., system isolation, area barriered off to prevent uncontrolled access, currently design controls being taken credit
for.
When defined as a Control, the Control must be in place before the ORD can be approved.
The Residual Risk for a Prerequisite Control is often higher than that of any associated Secondary or Primary
controls, increasing the residual risk of the Hazard until such time that the Prerequisite Action is in place.
Note: When closing the ORD or Hazard the Prerequisite Control must be removed or reinstated prior to closing
Hazard or ORD.
A Control which makes use of equipment to manage the risk on the Hazard. This is usually an automated control
measure that will initiate and reduce of escalating of the hazard materialising i.e., trip function, relief, isolation etc.
A Primary Control must identify the equipment that will be used.
Note: there is no requirement for a control action for a Primary Control as in the expected result, Trade, and Review
Scheme required. This is due to the expected automated response of the control.
These Controls are manual actions for monitoring the status of a piece of equipment or process. Examples include
monitoring conditions, verifying the status of pre-requisite or primary controls, such as calibration and proving
ongoing availability. They can also relate to maintaining awareness and communication.
As these require manual actions, the tracking of the performance through the generation of Actions for each
Secondary Control is required and are based on the Trade, Expected Results and Review Scheme frequency. The
Hazard Control Action must refer to the associated ORD.
The ORD Secondary Actions should be completed (including all outstanding Reviews) before the ORD is closed.
Note: When closing the ORD or Hazard the Secondary Control Action must be closed or prior to closing Hazard or
ORD.
ORD Approval and Communication of ORD
ORD Approvals

• Pant Manager: The Plant Manager shall approve ORDs with either ‘Green’ or ‘Amber’ mitigated risk status.

• ORDs with ‘Red’ mitigated risk status are deemed to be intolerable and shall be deemed as a company risk. ORDs with Red mitigated risk status will be
Referred to senior management by the Higher Authority e.g., Operations Manager Approval and if Required to be passed to next level up for further
Approval.

Communication and Visibility of ORDs

• The following outlines the philosophy for ensuring ORDs and their associated controls are communicated effectively and remain visible to the key plant
personnel who need to know of their existence and the specific requirements pertaining to each.

 The ORD register and supporting ORD forms and documents must be available for review by all personnel and will be held by DNO Kurdistan share folder.
A folder structure will be maintained and kept up to date. Approved forms must be scanned and placed in the online portal with hard copies kept in the
control room.

 Any new ORDs that are raised within the immediate term should be discussed at shift handover meetings. Emphasis should be given to the major
accident potential, defeated barriers and mitigation controls.

 For key personnel who are working on rotation, all live ORDs shall be discussed with the incoming personnel as soon as reasonably practicable; emphasis
should be given to the major accident potential, defeated barriers and mitigation controls.

 The number and status of live ORDs should be tracked on a monthly basis and reported to senior management as part of an integrated asset integrity
scorecard; this will allow overall trends in ORDs to be monitored and support the evaluation of cumulative risk.

 Once an ORD is closed, the ORD, with associated documentation, will be stored by the Head of Operations Support for audit purposes with the ORD
register and online portal updated.
 Section - 2
​Deviations Management Procedure​
Situation Require formal Deviations Management procedure
 Planning identifies not being able to comply with requirements provided by Governmental bodies, Company Standards and/or contracts

 Reviews, inspections or similar activities identifies that work is performed resulting in lack of compliance with requirements. Corrective actions are not possible and/or not the preferred course of
action.

Steps to Proceed:

1. All deviations and requests shall be reported to line manager and/or project manager as soon as possible

2. A risk assessment shall be performed for the identified deviation according to DNO methodology. The HSE function should participate in the risk assessment. Mitigating measures shall be
identified to control risks within the ALARP area. The identified risks shall be documented in the appropriate risk register.

3. Contractors performing work for DNO shall report deviations requests to DNO when:

a. Identifying deviations with regulatory requirements

b. Identifying deviation from Contract requirements, including DNO controlling documents referenced in the Contract

c. Identifying deviations which could affect safety critical elements and barriers

4. The deviation may be of such a character that the deviation is required to be controlled under Management of Change

5. Permission to Deviate from DNO controlling documents, Contract and/or regulatory requirements is required to continue operations not in compliance with requirements. Approvals shall be
documented in Synergi.

6. Permission to Deviate shall define whether the permission is permanent or temporary. Temporary permissions shall define the specific timeframe.

7. In cases where Permission to Deviate are given under conditions, the related actions shall be documented and managed systematically

8. In cases where Permission to Deviate is not granted all related consequences and actions shall be documented

9. All deviations shall be assessed in order to ensure proper organizational learning to avoid recurrence
​Deviations Management Procedure​

Mandatory requirements to ensure systematic reporting, management and documentation of all identified deviations
from DNO Corporate Standards and Procedures, BU Procedures and Plant Operating Envelopes. The Management
and approval of Plant Overrides shall be in conformance to this procedure.

• References:
• CORP-STD-HSE-015 Permit To Work (PTW) Standard
• CORP-STD-PRD-001 Production Management Standard
• CORP-STD-HSE-002 HSE Risk Management Standard
• CORP-STD-HSE-006 HSSE Asset Integrity Management Standard
• CORP-STD-HSE-013 Life Saving Rules
• OMAN-STD-OPS-008 Management of Overrides
 DNO Technical Authorities Framework Technical Authority Level

Responsibilities

Technical (Projects/Engineering/Drilling) Standards

Low/Medium Risk Production Plans and Deviations

Low/Medium Technical Risk Plans and Deviations

Low/Medium Risk HSSE Plans and Deviations

Engineering Designs Procedures and Plans

Statement of Fitness new/existing Facility

High Risk Plans and Deviations

Drilling Designs, Procedures and Plans

Production Plans and Procedures

HSSE Standards and Procedures

Overrides/Inhibits Management
Projects Procedures and Plans
Corporate Standards

SCE Maintenance Deviations

HSSE Plans and Procedures

Production Standards
Non-Conformances and
Deviations management for
technical (incl HSSE) standards
is performed through the A=Approve, I= Issue

Technical Authorities Framework.

Title Name A+I A+I A A+I A A+I A+I A+I A+I A+I A A+I A+I A+I A+I A+I

Chief Operating Officer Jeroen Regtien ❶❶

Technical Director Trond Myrseth ❶❶
Projects Manager Karl Defty ❶
Engineering Manager Kurt Bosse ❶
Drilling Manager Charles Pratten ` ❶
Head of HSE John Slater ❶❶❶
Production Excellence Manager Anton Keizer ❶❶
Production/Asset Manager (for respective BU) Eric Aillaud ❶ ❶ ❶ ❶
Production/Asset Manager (for respective BU) Scott North ❶ ❶ ❶ ❶
Production/Asset Manager (for respective BU) David Thorpe ❶ ❶ ❶ ❶
Production/Asset Manager (for respective BU) Jeff Thompson ❶ ❶ ❶ ❶
Request for approval for Deviation - Operating Risk Assessment
 Definition

Term (Abbreviation) Definition

Deviation Lack of compliance with:
DNO Controlling documents and/or contract affecting Safety Critical Elements
Contractor’s controlling documents
Regulatory Requirements

High Risk Deviation · Lack of compliance resulting in a High Risk (DNO RAM matrix)
Low/Medium Risk Deviation · Lack of compliance resulting in a Low/Medium Risk (DNO RAM matrix)
Deviation Request Specific format used to request permission to deviate from a requirement and/or to document deviations from a
requirement
Permission to Deviate An approved course of action documenting the management of risks related to deviation from requirements and
standards. (Example Management of Change form, Operational Risk Assessment).
Controlling document Any approved policy, requirement, standard and/or procedure included in DNO Business Management System.
Thank you