Basis Changes possible with prod client set to "no changes"

Hi SAP Basis Experts
I am busy with an internal security review of a client's SAP Environment and I experienced a query from the client side regarding a finding on SAP Basis Changes - an area I'm not too well versed in. The Client's Change procedures require all changes to be requested by logging it in a notification screen and the classification of the SAP changes according to it being either, small, normal, emergency or basis changes.
Should the change be classified as basis changes, it bypasses their security procedures  and no authorisation is required for the implementation thereof, it seems, straight into the production environment.
The Client has the following settings
Their Global Security Setting (SE06) is set to "Modifiable"
Cross Client Obj Changes for the Production Client (SCC4) is set to "No changes to repository and cross client customising objs"
The person performing the basis changes has a development key in the production client (DEVACCESS) along with two others.
Other than a myriad of security shortcomings my question is this:
The Basis Administrator argues that he can not make changes to the production environment due to the the "No changes..." setting even if he does have a Developer key.
1) Is this correct?
2) What further reports can I ask to validate that this administrator can not make changes without due authorisation?
3) Is there a report that details which users can make changes to the Client Settings (SCC4)
Thank you for the assistance!
Jacques du Plessis

Hi,
The Following things needs to be take care in this Activity
1) No Need to create Another TS for SAP R/3, this will not allow you to create another one.
2) Just Add the Business system for the Existing TS with Client 216 and also take care abt the Logical System Name here.
3) Refresh SLD Data Cache in IDEnvironment-
4) Now Use this New Business System for Communication which is having the New Client and Corresponding LS Name
REgards
Seshagiri

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