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You should definitely not be opening up any test/production system in order to update the organizational units in your workflow. What is normal practice is to put in the org units into your workflow (as you have been doing) and then transport the org units through to test/production along with your workflow. You can use transaction RE_RHMOVE30 to attach your org objects to a transport and send them through.
Your situation is a little different, as your users are the ones who are creating/changing the org units in production. If this can be avoided, then I would do so, but if this is an absolute requirement then you should change your workflows to call a responsibility rule in order to determine your agents. Then, once this is done, log into your production (or test) system and go to transaction OOCU_RESP. This will allow you to assign the org units to the responsibility for your workflow.
You should ensure that this does not in any way constitute a SOX compliance infringement.
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