The audit activity was part of the processing of the application for an Acknowledgement of Compliance (AoC) for the COSLRival living quarters facility.
The audit was conducted through a review of governing documentation at the company’s offices in Stavanger.
COSL Drilling Europe AS (CDE) has applied to the PSA for an AoC for the COSLRival. The facility is currently operated by OSM Offshore AS, which has operating responsibility for the COSLRival until 31 May 2010. CDE is a new player on the Norwegian shelf, and the audit of the company’s management system was part of the processing of the application for AoC.
The goal of the audit activity was to verify that COSL Drilling Europe AS’ management systems are established in accordance with regulatory requirements, including requirements for working environment follow-up, systems for identifying and following up non-conformities, systems for following up and investigating incidents, systems and plans for performing internal audits and systems for safeguarding competence and training.
The activity showed that CDE was in the final phase of implementing the necessary management systems for operating the COSLRival. Plans with deadlines had been made to ensure that the COSLRival crew has the required familiarity with CDE’s management system. It is our impression that CDE is in control of what needs to be done before CDE takes over operating responsibility for the facility. Within the areas covered by the audit, the PSA received a good impression of CDE’s management systems. Three non-conformities and seven improvement items were identified.
The PSA’s observations generally fall into one of two categories:
• Non-conformity: Related to those observations where we believe there is a breach of regulations.
• Improvement item: Related to observations where we see deficiencies, but do not have enough information to prove a breach of regulations.
Unclear working environment requirements:
It was not clear from the company’s governing documents which specific working environment requirements were in force in relation to emergency lighting, air capacity in various manned rooms and area noise for the COSLRival.
- COSL lacked governing documents clearly describing which specific working environment requirements were used as a basis for mapping and verifying conditions relating to:
- Emergency lighting. We found no reference to the EN 1838 standard, cf. guidelines to Section 37 of the Facilities Regulations relating to emergency lighting. This standard sets requirements for an assessment of the need for emergency lighting, dependent upon which functions are to be performed during a dangerous and/or accident situation. The standard provides a good supplement to the specific requirements for emergency lighting following from the Norwegian Maritime Directorate’s regulations. Requirements for emergency lighting with the appurtenant verified measured values were not evident from the facility’s working environment area chart (WEAC).
- Air capacity, air exchanges in manned areas.
- Area noise. It was unclear which requirements were used as a basis for measuring compliance with the applicable regulatory requirements for area noise. The regulations allow for older parts of the COSLRival to use the Norwegian Shipowners’ Association’s “Standard for physical –chemical working environment on mobile facilities built prior to 1 August 1995 and operating on the Norwegian shelf”. There is a short reference to this standard in Chapter 2 of CDE’s Health & Working Environment Manual without any clarification as to which parts of the facility will be covered by these noise requirements. We only find a reference to the area noise requirements in NORSOK S-002 in the application for AoC.
Requirements for working environment competence:
a) Adequate minimum requirements for working environment competence could not be verified for personnel with special responsibility for following up working environment conditions in connection with CDE’s mobile facilities and the COSLRival in particular. This is especially important for the Medical Officer, Safety Officer and HSE& Q-Coordinator positions.
b) It was not evident from the governing documents which working environment competence CDE itself would safeguard within its own organisation and which working environment competence would be supplemented externally through the associated company medical service (BHT) or other contracted working environment specialists.
c) The division of responsibility with regard to possessing competence in different working environment factors within CDE was not clarified with respect to the positions Medical Officer, Safety Officer and HSE & Q - Coordinator.
- Job descriptions could not be presented with information about who within the CDE’s organisation had the professional responsibility to follow up or provide technical guidance on various specific working environment conditions. It is expected that there are personnel in the CDE organisation with working environment skills that go beyond the basic working environment skills required of safety delegates, members of the working environment committee and supervisors, cf. requirements for basic 40-hour working environment course.
- It could not be determined which working environment skills, as a minimum, should be held by the HSE & Q Coordinator, Medical Officer or Safety Officer. These job functions shall, in accordance with the received information, provide guidance and technical advice related to general health and working environment follow-up on CDE's facilities.
- It was not clear which working environment skills the Medical Officer position supplemented by COPSAS should have. The competence requirements (described in the SAP job description) applicable to this position were not very specific or binding.
- It was not clear which working environment skills CDE itself should safeguard through its own organisation, and which competence should be handled externally through BHT or other contracted working environment consultants.
- CDE’s course matrix did not reflect the requirement for a basic 40-hour working environment training for the HSE&Q-Coordinator position.
- It is natural to expect the positions of Medical Officer, Safety Officer and HSE & Q-Coordinator to possess additional training in working environment conditions beyond the basic working environment course.
Organisation of working environment committee:
We could not verify the establishment of a joint local working environment committee FSAMU for the COSLRival in accordance with regulatory requirements.
- The CDE procedure “Working Environment Committee” does not describe the organisation of a joint local working environment committee (FSAMU) for a flotel (e.g. COSLRival), and how the corresponding FSAMU for a drilling facility would be composed.
- It is not evident from CDE’s working environment committee procedure that the company medical service (former safety and health personnel) shall be permanent members of the committee.
- It is not evident if the operator is represented in the FSAMU for COSLRival and, if so, what status is given to the operator (voting rights or observer status).
- The minutes from the FSAMU meeting on 5 August 2009 do not include who is representing the main activity area catering (ESS) from the employer’s side.
- Furthermore, it is unclear how the representatives for tenants (flotel guests) are ensured access/representation in the FSAMU for COSLRival.
- The governing documents are also unclear as to which tasks are covered by CDE’s “Company WEC” and which tasks are assigned to the FSAMU for the individual mobile facility (JLWEC). Any interfaces and connections between these WECs are not clearly represented. Furthermore, it is unclear if the Company WEC should only cover factors related to CDE’s land personnel (under the Norwegian Labour Inspection Authority’s sphere of authority) or should function as a coordinating WEC when CDE receives operating responsibility for additional mobile facilities.
Outstanding verification of physical working environment conditions on the COSLRival:
Documentation could not be provided to verify compliance with applicable requirements for working environment for the following conditions:
a) Work was outstanding on verifying noise in some areas of the facility. (To be performed by Sinus in the first week of May)
b) Work was outstanding on verifying emergency lighting in some areas of the facility
c) Work was outstanding on verifying that the air capacity provided to manned rooms/areas was adequate to ensure acceptable indoor environment conditions, cf. also CDE non-conformity Synergi no. 149.
Need for update of the working environment area chart (WEAC) for the COSLRival:
Working environment status in individual areas of the COSLRival is not particularly evident in the facility’s WEAC.
- According to CDE’s Health & Working Environment Manual Chapter 4.4, the area requirements (WEALs) for the individual area shall be evident from the WEAC. The WEAC shall further be kept up-to-date to illustrate the working environment status for the individual area.
- The provided WEAC form for the COSLRival did not adequately reflect the facility’s working environment status.
- It was not clear from the provided WEAC document which specific conditions belonged to which field/column on the WEAC form. For example, it was not evident which conditions belonged to the columns arrangement, ergonomics, Human Factors etc. Whether a circumstance such as safety signage has been assessed is also unclear.
- The WEAC form was not adequately updated, with several fields (columns) left blank. The WEAC form provided was poorly suited to document the applicable working environment requirements.
- As regards the purely empirical requirements, the requirement for the number of air exchanges per hour was not filled in. No data was attached for measured air volumes either.
- Requirements for emergency lighting were neither reflected on the form nor in measured values.
- The lower part of the WEAC form did not provide any verifiable information on several critical working environment factors.
- In spite of the identified deficiencies above, we wish to emphasise that we believe the working environment conditions aboard the COSLRival comply with regulatory requirements, cf. reports following several performed working environment mappings. The challenge facing CDE, however, is in documenting and presenting the working environment status of the individual areas, based on the results of these surveys, in a simple and straightforward manner. The use of WEAC is a useful tool in this connection.
Need for update of some governing documents:
Beyond the need for updating governing documents relating to the above-mentioned factors, we also wish to call attention to the following circumstances:
a) The company’s procedure for reporting and handling possible work-related illnesses was deficient. This was especially true for the term work-related illness, the description of the responsibility for reporting such illnesses, and the reference to the applicable regulatory requirements.
b) The document “Health & Working Environment Manual” should be updated to better safeguard the following uncovered deficiencies:
- The procedure did not describe who is responsible for implementing the mappings and following up the results. A reference to the AMU could be beneficial.
- The procedure also did not describe which requirements or criteria which shall form the basis for assessing the need to implement a working environment mapping, especially the type “Continuous Working Environment mapping”.
- A requirement for the mapping report to include information on which improvement measures should be prioritised, based on technical assessments, is lacking.
- Deficient requirements for and reference to recognised standards for indoor environment, e.g. references to the Norwegian Labour Inspection Authority’s publication 444 and The National Institute of Public Health’s recommended technical standards for indoor environment, cf. Section 13 of the Facilities Regulations.
c) The procedure connected with meeting structure and Inspection Procedure was somewhat deficient, as the Medical Officer does not participate in weekly HSE area inspections. It is considered important that the nurse acquires a good familiarity with work operations and the physical HSE conditions in the different areas on the facility. Furthermore, third-party personnel should be secured access to HSE meetings.
HSE management system
Procedures in general: Not all procedures were drawn up. A decision had not been made as to which procedures would be translated into Norwegian.
- CDE’s status of total complete procedures was 84 per cent. For HSEQ, the completion percentage was about 90 per cent and the plan was for all relevant procedures for the COSL Rival to be complete by 15 May 2010.
- The management system was structured to facilitate work on foreign shelves without substantial changes. Requirements were so far not provided for how the AoC would be followed up if the facility were to operate for a time on the British shelf.
- All procedures were composed in English. However, we were informed that plans were underway for translating some procedures and work processes into Norwegian. The plan for this had yet to be drawn up.
- Gatherings were planned for the second half of May, where everyone on board would be provided with an introduction to CDE’s management system. The web-based solution to be used was not complete at the time of the audit.
Competence and training:
Gap analyses for mapping deficient competence had not been performed throughout the organisation.
- An OCS system was used for following up that the competence requirements for each position are met. Work was underway to register the competence of each person in the organisation and gap analyses were to be performed to uncover any need for further training. The gap analyses had, at the time of the audit, not yet been performed for everyone on board.
- “HSE talks” are defined in the AoC application as a management tool to direct attention toward risk factors and risk understanding. Managers on land were not provided adequate training in the use of this tool.
- We refer to the paragraph above relating to working environment competence.
Some improvement items were identified in the non-conformance procedures.
- The flowchart for non-conformance procedures, ref. L3-HSE-604, was not updated in accordance with the latest procedure revision.
- It was not evident from the procedures whether the safety delegates are involved when the effect of performed corrective measures is to be evaluated.
- It was not evident whether the company performs a review of all non-conformities together e.g. to assess if multiple non-conformities within an area can increase the risk of an incident occurring or developing.
- Processing time for non-conformities is generally stated as 30 days. Critical non-conformities are handled immediately. The company will, however, reassess if a processing time of 30 days is acceptable for non-conformities rated criticality 2.
Follow-up of incidents – investigation:
The description of the company’s system for investigating incidents does not meet all requirements in this area.
- It was not evident from the mandate in the procedure for investigating incidents that the underlying causes of the incident shall be assessed.
- In connection with investigations, it was not stated that similar incidents should be considered, either as a part of the mandate or in any other manner.
- The HSEQ Director shall produce an investigation mandate on behalf of line managers. It could also be beneficial for the HSEQ Director to be the investigation leader, or be included in the investigation team. This situation is not described.
- Criteria were not defined for when and how representatives from equipment suppliers, contractors or the operator should participate in the investigation group.
- Responsibilities during completion of investigations and approval of the investigation report were not clear.
During the audit, it was unclear how the employees had been involved in the process of drawing up the AoC application. Following the audit, the PSA has received confirmation from the safety delegate service of their involvement in the AoC process.