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Notification of order following audit of Transocean

During the period from 19 January – 1 March 2012, the Petroleum Safety Authority Norway (PSA) conducted an audit of Transocean Offshore Ltd (Transocean) and the company’s maintenance management system. The audit identified serious breaches of the regulations. The PSA has now issued a notification of order to the company.

The audit targeted selected parts of Transocean’s maintenance management system, and how it is used and followed up in the organisation onshore and offshore.

The background for the audit activity is the issuance of an Acknowledgement of Compliance (AoC) to Transocean for the facility and Statoil’s consent for use of the Transocean Arctic on the Tyrihans field.

The consent is issued in part on the basis of documentation associated with the AoC for the facility, with the preconditions and obligations which the AoC represents for the drilling contractor.

Transocean has seven facilities engaged in operations on the Norwegian shelf. These facilities are operated by dedicated operations organisations in Norway, with shared support functions from the office in Stavanger.

The objective of the activity included verifying the order issued in 2007 requiring the company to draw up a binding plan and schedule for ensuring that all facilities under Transocean’s sphere of responsibility in Norway carry out necessary maintenance pursuant to the regulations. According to the company’s reply, the order was to have been carried out by 15 July 2009.

In addition, we verified whether Transocean had implemented the new maintenance management system, RMS, to the necessary extent, and whether this satisfies the regulatory requirements.

The company began using RMS during the period 1 January 2009 to 1 July 2009, after previously using Empac. Leading up to the summer of 2011, Transocean carried out a number of different projects aimed at improving and further developing the system.

The audit activity revealed that Transocean’s maintenance management system still did not satisfy the regulatory requirements. The activity was carried out in the form of spot checks on a random selection of equipment and documentation.

Examples of important factors include:

  • It emerged during interviews that the new maintenance management system was not very user-friendly.
  • Maintenance programs for a number of equipment units and components were missing.
  • It was difficult to identify and track randomly selected equipment in RMS.
  • It was unclear which method and criteria were used to assess criticality and to determine which equipment/barriers were safety-critical.
  • The facility structure (the hierarchy) does not encompass all equipment in such a way that it can easily be identified in the facility, on drawings and in the PM program.
  • Deficiencies in the maintenance history system 
  • Performance requirements for important barrier elements were not always verified through testing and inspection activities in the maintenance system.

In addition to this, the activity revealed deficiencies in the company’s own follow-up, internal audits and completion of modification and maintenance activities.

Based on the findings made during the audit, the PSA has now notified Transocean of the following order:

Pursuant to Section 69 of the Framework Regulations relating to administrative decisions, cf. Section 6 of the Management Regulations relating to management of health, safety and environment, Section 8 relating to internal requirements and Section 21 relating to follow-up, Transocean Offshore ltd NUF is ordered to initiate the following measures:

  • Review the management system and implement measures so that the company’s follow-up systems safeguard the intended needs in all parts of the organisation. This work shall include an investigation of why important deficiencies in the maintenance system were not identified and followed up in connection with the process of implementing a new system (RMS).
  • Draw up a binding plan and schedule for how this work will be carried out and followed up. This plan must be sent to the PSA by 26 April 2012, together with a response to the audit report,

cf. Sections 5.1.1, 5.1.2, 5.1.3, 5.1.4 and 5.1.5 of the report.

The deadline for complying with the first part of the order is set at 1 September 2012. The PSA must be notified when the order has been carried out.

Any comments regarding the notification must reach us by 10 April 2012.

Order and notification of order
An order is a administrative decision made pursuant to the regulations.

Before the PSA makes an order, it usually issues a notification of order to the companies concerned.

A notification of order is neither a measure nor a warning of sanctions, but part of the PSA’s administrative process as specified in its established procedural rules.

The notification is merely a first step before an administrative decision is made.