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AoC: Floating on trust

The PSA has manoeuvred the acknowledgement of compliance (AoC) onto the NCS with a firm hand. This scheme is now securely anchored as an important tool for monitoring mobile units.


This article was published in the publication "Safety - status and signals 2010-2011".

A very ambitious approach was taken by the PSA in the late 1990s when it launched a trial with a process for advance approval of mobile units, better known today as the AoC.

But the question was whether it would be possible to create a scheme which could clarify responsibility and make the consent process more efficient.

At the same time, the PSA wanted the AoC to reduce bureaucracy, make roles clear and establish greater predictability.

Discussed
A system of this kind had been discussed in various contexts, and the decision to establish it on a trial basis was accordingly welcomed. That applied particularly to the rig contractors, who had long been pressing for a more predictable system.

Companies and unions played an active role in shaping and establishing the AoC.

“Broad agreement prevails across the industry today that the aims have been met and that experience with the AoC is positive,” says special adviser Kjell-Gunnar Dørum at the PSA.

He is more familiar than most with the scheme, having been present when the idea was launched, the trial period initiated and the AoC made mandatory.

Over the 11 years that the system has been in place, he has also been involved with the bulk of AoC applications received by the PSA.

The West Navigator drilling rig, then owned by Norway’s Smedvig, had the honour of being the AoC’s first guinea pig in 2000.

Since then, applications for such recognition have flowed in at a steady pace, and a total of 42 units were covered by an AoC at 1 January 2011.

It should be noted that the AoC does not represent an approval.

Range
The scheme was aimed at achieving a range of improvements, which included helping to describe the rig contractor’s responsibilities and their interface with the operator’s duties.

An AoC was also intended to contribute to making contractors more responsible, and encouraging more direct contact between them and the PSA.

In addition, it would boost efficiency for contractors, operators and government by underpinning both applications for and consideration of consents concerning units with AoCs.

The system was furthermore intended to provide greater predictability for the contractors with regard to regulatory requirements and their own management.

And it would facilitate the movement of mobile units between fields and operators on the NCS, and ultimately between countries in north-western Europe.

Participation
The introduction of the AoC has contributed to greater participation by as well as better knowledge of the regulations among employees.

At the same time, rig contractors have gained increased expertise about the units they own and their technical condition – which has also seen a general improvement.

Responsibility
The rig contractors are responsible for ensuring that their organisation and management system as well as the technical condition of their units accord with the rules at all times.

They also have a duty to measure compliance, and must be able to document that the regulatory requirements have been met. This is checked by the authorities, in part through audits.

“Trust is the key word here,” says PSA supervision coordinator Ingvill Hagesæther Foss.

“When we’ve awarded an AoC, it means we rely on the contractor to live up to their responsibilities.”

Long time
Everyone who has applied so far has eventually received an AoC, but the process has taken a long time in some cases. Normal consideration lasts three months, assuming that:

Longer consideration could mean the application is poorly based, the unit’s condition is unacceptable, or the operating organisation and management systems are deficient.

“We’ve seen a number of examples in recent years where people have failed to understand the work involved in building up a company and introducing a new unit to the NCS,” says Ms Foss.

Time-consuming processes mean increased use of resources for the PSA, and also impose additional costs on the AoC applicant.

Changes
The player picture on the NCS has changed signifi cantly since the system was introduced, with more than 50 companies entering.

Whether the AoC process might have helped a number of them to accept the demanding job of serving as an operator is a question that remains to be answered.

Ms Foss merely notes that both operators and rig contractors are positive.

“Contractors have both received and accepted more responsibility. They’ve had to roll up their sleeves. And we must suppose that this has led to safer operation.”

Figures from the PSA’s RNNP process are positive. Results for mobile units have clearly improved in several areas during recent years, including major accidents, personal injuries and noise.

“We hope this trend will continue,” Ms Foss comments.

This article was published in the publication "Safety - status and signals 2010-2011".