Managing Change at BASF

1. Introduction

BASF, which operates production facilities at more than 350 locations worldwide and employs more than 115,000 people, has its roots in Mannheim, Germany. Friedrich Engelhorn, a jeweler and entrepreneur, founded the joint-stock company "Badische Anilin-&Sodafabrik" (BASF) in 1865 to produce dyes, raw materials required by the market, auxiliary substances, precursor materials and intermediate products. Today, with a 153-year history, BASF entered the Turkish market in 1880 with dye product sales and began production operations in Turkey in 1970 as 'BASF Sümerbank Türk Kimya Sanayi A.Ş.' When examining the history of the chemical sector, it is possible to encounter many disasters. When the findings obtained from each disaster experienced today are evaluated, it appears that actually more than 90 percent of these disasters could be prevented by simple and disciplined methods. In the sector, change management practices, accepted as one of the most important of these methods, are naturally a process for BASF in which application and system compliance are maintained at the highest level. For BASF, the priority is to maintain high standards in health, safety and environmental protection at its facilities worldwide. BASF adopts a strong health, safety and environment strategy to achieve this goal. Achieving these high standards within the normal production cycle is possible through an effective change management system. The change management system covers BASF's production facilities, warehouses, research and development units and offices. This system covers all permanent and temporary changes affecting facility operations, whether technical or organizational, during the facility's lifetime from the start of production to its closure. At BASF, the definitions of change management, its scope, how it is addressed and how it is evaluated are described in detail in the continuation of our article.

2. Definitions

Change: Covers all mechanical, technical or organizational changes that are planned and carried out consciously. Changes to be considered are listed in detail in section 4.2. If a change is carried out on a regular basis, it is supported by an operating procedure, a risk analysis is performed, and this work is no longer considered a change. Temporary Change: Changes that are planned for a specific period and the system reverts to its original state after the planned period ends. (For example, facility trials.) Emergency Change: Urgent actions taken to prevent serious adverse situations.

3. Responsibilities

The Facility Manager, responsible for facility management, is responsible for establishing a comprehensive change management system that complies with local and regional regulations. In addition, this person responsible for facility management is also responsible for monitoring the effectiveness of the system and compliance with the system.

4. Change Management System Requirements

Each facility must have an effective change management system within its structure. The detail of the change management system should be proportional to the hazard and complexity level of the facilities. The change management system should address the following matters;

4.1 General Requirements for the Change Management System;

• What constitutes a change must be clearly defined. • Roles and responsibilities must be clearly defined. • There must be a written procedure describing each step and element of the change management system. • All personnel involved in the change management system must be trained regularly on the implementation of the system. • Changes must be documented and these documents must be retained for at least five years or for the longest period specified if local regulations require a longer period.

4.2 Changes Within the Scope of the Change Management System;

The following changes must be addressed within the framework of the change management system,

• Chemical/Technological;

- Changes that go beyond previously defined and documented safe operating limits. Revisions of alarm or lock limits. - Computer software revisions. - New chemical use. - Change of chemical used. - Changes in operation steps.

• Equipment;

- New piping or equipment. - Revision of piping. - Revision of equipment.

• Procedural;

- Standard operating procedures. - Emergency procedures. - Safe work procedures. - Maintenance/inspection procedures. - New procedures created for new equipment installations. - Personnel competency specified for a task and number of personnel.

• Personnel/Organizational;

- Changes in personnel numbers. - Administrative matters. - Maintenance support. - Subcontractors.

• Facility;

- Changes to buildings. - Construction of new buildings.

• Production Operations;

- Redesigning production processes to manufacture a new product.

4.3 Change Management System Elements;

The following elements are typical parts of an effective change management system and all of these elements must be clearly described in procedures. Decision tools, forms and best practice examples provide ease in the implementation of effective change management practices.

4.3.1 Technical Changes,

Technical changes cover chemical, technological, equipment, facility and production changes. Typical elements of the change management system are as follows, • Initiation and proposal, i. Definition of who can request a change. • Proposal review and technical evaluation, i. Definition of who will review and classify the change proposal. ii. Classification of the proposal according to the type of change. iii. Evaluation of the necessity of the change. iv. Evaluation of technical suitability. v. Determination by risk level classification of what level of risk analysis and approval process is required. vi. Verification that documents required to complete the evaluation are complete and current. vii. Identification of all documents, procedures and personnel that will be affected by the change. viii. Determination of expected periods in case of temporary changes.

• Risk assessment,

i. Determination of the risk assessment method required to ensure that the change does not have a negative health, safety and environmental impact. ii. Definition of the qualification and expertise of the personnel who will perform the risk assessment. (The composition of the risk assessment team may vary depending on the risk level of the proposed change.)

• Information and training of relevant personnel,

i. All personnel affected by the change must be informed. ii. All personnel whose work will be affected after the change are given the necessary training.

• Update of relevant technical documents and procedures,

i. Equipment information is updated. ii. P&IDs are updated. iii. Safety documents are updated (for example, explosion protection document). iv. Test and inspection procedures are updated. v. Emergency plans are updated.

• Implementation preparations,

i. Facility-specific work permits required are obtained.

• Pre-implementation review,

i. Verification that all required final acceptance tests have been completed and documented. ii. Review of organizational measures taken for safe operation. (Operating procedures, training, etc.) iii. Verification that actions from risk analyses have been closed.

• Closure of open items,

i. Definition of who is responsible for tracking open actions. ii. Closed action items are documented.

• Change closure,

i. After all open actions are closed, clear definition of who has the authority to complete and close the change. ii. Documentation and archiving of closed changes is ensured.

4.3.2 Organizational Changes,

Organizational changes cover changes in procedures, personnel or organization. Typical elements of the change management system are as follows,

• Initiation and proposal,

i. Definition of who can request a change.

• Proposal review and technical evaluation,

i. Definition of who will review and classify the change proposal. ii. Classification of the proposal according to the type of change. iii. Evaluation of the necessity of the change. iv. Determination by risk level classification of what level of risk analysis and approval process is required. v. Identification of all documents, procedures and personnel that will be affected by the change. vi. Determination of expected periods in case of temporary changes.

• Risk assessment,

i. Determination of the risk assessment method required to ensure that the change does not have a negative health, safety and environmental impact. ii. Definition of the qualification and expertise of the personnel who will perform the risk assessment. The composition of the risk assessment team may vary depending on the risk level of the proposed change.

• Information and training of relevant personnel,

i. All personnel affected by the change must be informed. ii. All personnel whose work will be affected after the change are given the necessary training.

• Update of relevant technical documents and procedures,

i. Operating and maintenance procedures are updated. ii. Test and inspection procedures are updated. iii. Emergency plans are updated.

• Change closure,

i. After all open actions are closed, clear definition of who has the authority to complete and close the change. ii. Documentation and archiving of closed changes is ensured.

5. Documentation

Change management documentation should include the following elements, • Clear definition of the change, • Reason for the change, • Technical background, • Risk assessment, • Approvals, • Communication and training of affected personnel, • Review of documents and procedures, • Change closure

6. Risk Assessment Work at Change Approval Level

BASF has developed a tiered approach to determine the level of risk analysis to be performed and the approval authority according to the complexity and hazard level of the change. In this four-tiered approach, evaluation is performed using a question list. The risk assessment level and approval mechanism level are clarified by the answers to the questions in the question list and concluded with a decision flow chart.

6.1 Question lists; List 1;

Questions related to local regulations such as laws and regulations (For example, Regulation on Prevention of Major Industrial Accidents and Mitigation of Their Effects (SEVESO II), Regulation on Protection of Employees from Dangers of Explosive Atmospheres). • Is it a case of exceeding the threshold quantity for a critical substance for the first time? • Is there a change in the official safety report prepared for the facility?

List 2;

Questions related to the potential of the proposed change to increase facility risk. • Is there a change, addition or removal of a protective device (For example, safety valve, explosion flap, safety equipment (Z quality locking))? • Does the change have the potential to affect the design scenario of a protective device (For example, surge scenario)? • Is there a case of formation of a high exothermic reaction? • Is there an addition of unstable substances with high exothermic decomposition potential? List 3; Questions related to minor changes. • Will only errors in documents be corrected?  

6.2 Decision Flow Chart

 

6.3 Risk Analysis Tiering

Tier 1; Risk analysis is not necessary. Tier 2; Risk analysis is performed by production/operations teams using a checklist. Tier 3; Risk analysis is performed by a team consisting of production/operations teams, HSE teams, facility manager and process safety specialist. Tier 4; Risk analysis complying with all local regulations according to legal requirements (in case the safety report is affected, including this change) is performed by a team consisting of production/operations teams, HSE teams, facility manager and process safety specialist. Ömür Vural Taşdemir Process Safety Specialist Turkey, Azerbaijan and Middle East Region BASF Türk Kimya San. ve Tic. Ltd. Şti.