HSE Procedures

SUEZ OIL COMPANY Cairo-HSE-P-14

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Deviation Control Procedure

CairoHSEP14
1 Scope

This procedure covers the requirements to manage and approve deviations from SUCO's
"controlled" standards and procedures in order to maintain asset integrity.

This procedure is generic and is to be used in both Operations and Engineering departments.

2 Background

Integrity of the Companys operations is maintained through the rigorous application of standards
and procedures. These standards and procedures are embodied in the Companys Controlled
Documents.

Occasionally, it will be necessary to respond to circumstances which demand a modification to

and/or relaxation of standards and procedures either on a temporary or permanent basis. Therefore,
in order to maintain the integrity of an asset and/or group of assets, this procedure provides an
auditable means for controlling these Deviations.

3 Objective of the Procedure

To provide an auditable procedure for approving Deviations to Company standards and procedures
as defined in Controlled Documents.

4 Definitions

A Controlled Document is defined as any Company document which is controlled by means of a

formal issue and revision procedure. A list of Controlled Standards will be periodically published by
the Engineering and Operations document custodians.

A Deviation is defined as any change to the intent of a Controlled Document which may impact on
HSE and / or asset integrity.

An example of a Deviation is the request for a waiver to carry out an integrity hydro test of a newly
welded section on gas lift line piping. In order to avoid the ingress of water into the gas lift system a
deviation is submitted to Engineering, requesting a waiver to the SUCO Standard (reference to ANSI
B 31.3). An alternative, such as Radiography or UT inspection, must be proposed to ensure the
integrity of the weld.

Notes:

1) Deviations which do not impact on HSE and or asset integrity are to be processed and
approved by the Asset Manager.

2) Physical changes to existing plant which impact on HSE and / or asset integrity are
governed by the Plant Modification Certificate (PMC) Procedure.

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A Temporary Deviation is defined as a Deviation which is valid for up to a maximum of one year
from implementation. This is acceptable in cases when it is necessary, for Operational reasons, to
adopt temporary measures where HSE and or asset integrity is not compromised over the period for
which the Deviation is approved.

An example of a Temporary Deviation would be a waiver to defer a vessel inspection and therefore
postpone a shutdown to minimize oil deferment. Approval would be based on previously known
material conditions and expected corrosion rates.

5 Approval Procedure

Deviation Request Form - Part A Initiation

The Originator should complete Part A of the Deviation Request Form (Appendix 1) giving all
details necessary for the Deviation to be reviewed. The Originator shall signify the category of the
deviation (Safety, Operability etc.) and whether it is Permanent or Temporary.

a) A Temporary Deviation shall include the required validity period.

b) The Deviation Request shall be issued to the Asset Holder and Asset Manager for approval.

c) Asset Holders and Managers are nominated as follows:

ASSET ASSET HOLDER ASSET MANAGER

Zeit Bay O-71 O-70

Ras Budran O-61 O-60
Ras Fanar O-81 O-80
Engineering Projects P-1
Engineering Construction P-1

Deviation Request Form - Part B Technical Review and Approval

A Deviation Request is forwarded to the appropriate Focal Point. Focal points are nominated as
follows :

DOCUMENT FOCAL POINT

Company HSE Standards & Procedures HSE

Engineering and Technical Safety Controlled Documents
(Schedules, Procedures, Guidelines, Philosophies, P-1
Engineering Contracts)
Operations Controlled Documents O-50

The Focal Point will forward the Deviation Request to the Custodian of the relevant Controlled
Document.

The Custodian will review the Deviation Request and will determine whether or not the Deviation
Request is technically supported.

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If the Deviation Request is technically supported, then the Custodian will arrange for the approval
authority of the Controlled Document to approve the Deviation Request. Approval of a Temporary
Deviation shall be given for a stated duration. If the Deviation Request is not supported, the
Custodian shall clearly state reasons for rejection of the request.

The Custodian shall return the Deviation Request to the Focal Point who will review the
recommendation and confirm approval has been given by the appropriate authority and return the
Deviation Request to the Originator (Asset Holder).

The Custodian shall file a copy of the approved Deviation Request.

Deviation Request Form - Part D Execution and Close Out

The Asset Holder shall arrange for the Deviation to be implemented and both the Asset Holder and
Asset Manager shall sign to confirm that the Deviation request has been executed correctly.

6 Registration and Management of Deviations

The Asset Holder is responsible for maintaining an Asset Deviation Register (Appendix 2). The
Register shall record the progress of a Deviation Request and provide an auditable record of all
approved and executed Deviations. The Register shall also contain all completed original Deviation
Request Forms and shall be the primary record for the purpose of an audit trail.

Temporary Deviations require strict control after execution to monitor the expiry date. The Asset
Holder shall highlight all Temporary Deviations in the Asset Deviation Register which shall be
reviewed on a regular basis with the Asset Manager. One month prior to the expiry date the Asset
Holder shall take the necessary measures to carry out the requirements of the Controlled Document
or approve / reissue the Temporary Deviation for a further validation period.

Deviations which are continually arising should be highlighted by the Asset Holder in order to prompt
a review of the relevant Controlled Document by the Custodian.

Reference Documents :

Appendix 1. Deviation Request Form

Appendix 2. Asset Deviation Register

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(Appendix 1)

DEVIATION CONTROL PROCEDURE

Deviation Request Form

Part A - Initiation
Deviation Title:

Deviation Number: Area:

Asset Name: Location:

Temporary Deviation (See Definitions section 4): Yes / No

Required Validity (Temporary Deviation only): months from Execution Date

Controlled Document Focal Point:

[To whom Deviation Request should be sent (Ref. Section 5.2) ]

Safety * Operability Maintenance Inspection Test Other :

Initiation Date:

Applicable Controlled Document: (Reference sections, paragraphs etc.)

Deviation Details: All information required for Document custodian to review and assess requested
Deviation. For example: 1. Existing Situation, 2. Reason for Deviation, 3. Proposed Deviation (Attach
supporting documents/drawings).

DEVIATION REQUEST APPROVAL:

Originator Asset Holder Asset Manager

Name: Name: Name:

Ref. Ind.: Ref. Ind.: Ref. Ind.:

Sign: Sign: Sign:

Date: Date: Date:

* () tick those which apply

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Deviation Request Form

Part B - Technical Review & Approval

CUSTODIAN APPROVAL EXPIRY DATE:
APPROVED: Yes / No
REVIEW
Temporary Deviation only

Custodian Comments:

Name: Ref. Ind.: Date: Signature

OPERATIONS APPROVAL (Signature / Date): * To be defined by Custodian.

* * *
* * *
* * *

ENGINEERING APPROVAL (Signature / Date): * To be defined by Custodian.

* * *

* * *
* * *

Part C - Execution and Close Out

EXECUTION COMPLETION DATE:

APPROVAL EXPIRY DATE:

Originator Asset Holder Asset Manager

Name: Name: Name:

Ref. Ind.: Ref. Ind.: Ref. Ind.:

Sign: Sign: Sign:

Date: Date: Date:

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(Appendix 2
Deviation Control Procedure)

ASSET DEVIATION REGISTER

Register Custodian (Asset Holder): Asset Name / Location:

INITIATION APPROVED EXECUTION EXPIRY

Deviation By (Ref. Ind.) Controlled Description By (Ref. Ind.) By (Ref. Ind.) Date
Reg. No: Document
Date
Number Date Date

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