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AoC - Maintaining a new urgency

The acknowledgement of compliance (AoC), which celebrates its 10th anniversary this year, has contributed to a marked improvement in safety on mobile units. But maintenance lags behind – something the PSA now expects the industry to take serious action on.

West Navigator was the first rig to be awarded an AoC in 2000, after the scheme had initially been established as a voluntary option.

It became obligatory with an expanded scope in 2004, and a total of 41 mobile units had received an AoC by 31 December last year.

The 10th anniversary represents a milestone which invites reflection on the question of whether the arrangement has been a success.

“It’s definitely contributed to a substantial improvement in the industry, and thereby to a significant enhancement in safety,” says PSA special advisor and AoC veteran Kjell-Gunnar Dørum.

“This arrangement clarified roles and the division of responsibilities between operator and drilling contractor, and meant we could communicate directly with several key players.

“Giving contractors responsibility greatly enhanced their grasp of the regulations, leading to a marked improvement in the technical condition of units and in company management systems and organisation.”

Employee participation on these rigs has not least become much better as a result of the AoC process, adds Mr Dørum, who has been involved in dealing with every request made under the scheme.

In addition to the safety boost, the arrangement has also yielded a clear efficiency gain for the PSA’s consideration of consent applications.

“It’s meant we get to know the unit,” Mr Dørum explains. “That’s contributed to greater predictability in dealing with consents, both for us and for the industry.”

But the AoC’s history to date does contain one sorry mess, which goes under the name “maintenance”.

“Many serious incidents with a major accident potential on the NCS can be traced back to inadequate maintenance,” says Mr Dørum. “It’s a big problem that conditions in this area are so poor.”

Maintenance has often been the most difficult issue when dealing with an AoC application.

Disparities been regulatory requirements and the applicant’s maintenance management and systems are a recurring problem.

“Subsequent audits have exposed a number of shortcomings in this area, both on the individual unit and at owner level,” Mr Dørum explains.

“In practice, some AoC holders fail to follow up the obligations they’ve taken on. That’s quite simply unacceptable, and should be a source of shame to the industry.”

An extensive catalogue of sins includes failing to label  and classify equipment, deficient maintenance systems and programmes, and not least the postponement or neglect of planned work.

The consequences are reduced management and control, which in turn affect the safety culture.

Mr Dørum believes that Norway has one of the world’s most modern regulatory regimes for maintenance. Its management requirements permit great flexibility in developing programmes tailored to the level of activity and condition of each rig.

“As the regulator, we’re naturally concerned with good maintenance because it’s important for safety,” he says.  “But it also has a clear financial upside.”

“That’s because a well-maintained unit has more uptime since undesirable incidents decline in number, so maintenance spending also yields greater revenues for owner, operator and Norway Ltd.”

The PSA has challenged the industry over maintenance for a number of years, through active involvement in conferences and seminars, meeting with the companies and courses on the regulations.

It has also conducted a number of audits of owners and units. Reports from these inspections are posted to the web in full (Norwegian only) to promote learning and experience transfer.

After years of finger-wagging and a long list of post-audit orders, the PSA now hopes that the contractors will change course and step up their maintenance commitment.

“We’ll be assessing new measures during 2010 which could contribute to an improvement,” Mr Dørum adds.

An early bird
A number of contractors without previous experience from petroleum operations in Norway have built mobile units in recent years with the intention of working on the NCS.

The PSA has seen the challenges posed because both the AoC applicant and the construction yard are ignorant about Norway’s regulatory regime.

“We’ve accordingly established an early-phase project to advise applicants in this part of the process,” reports Kjell-Gunnar Dørum.

“They can thereby avoid timeconsuming and expensive extra rounds. We’ve received very positive feedback from the industry and the fabricators over this practice.”