GUIDELINES REGARDING THE ACTIVITIES REGULATIONS
(Last updated 25 January 2019)
Petroleum Safety Authority Norway
Norwegian Environment Agency
Norwegian Directorate of Health
Norwegian Food Safety Authority
Norwegian Radiation and Nuclear Safety Authority
Guidelines regarding the activities regulations
The scope of the regulations is limited in comparison with the scope of the , so that they only apply to offshore petroleum activities.
The provision in the second subsection makes individual requirements in these regulations applicable also for facilities and equipment for conduct of manned underwater operations from vessels. For practical reasons, a choice has been made to have a general section on this, rather than repeating it in the individual provisions.
The purpose of joint working environment committees is to ensure coordination of the individual enterprises’ safety and environment work and to give all employees a genuine opportunity of taking part in and influencing the safety and environment work at their own workplace, regardless of their employment relationship. Reference is made to Section 7-2 of the and provisions on safety delegates in . These regulations also apply directly to the petroleum activities, with the specifications and limitations given in the regulations.
The duty to establish joint working environment committees does not reduce the duty of the individual employer to establish a working environment committee at its own enterprise, cf. . The joint working environment committee will be superior to the working environment committees of the individual enterprises in matters related to the jurisdiction of the joint working environment committee.
The term "field" is continued in the new regulations, inter alia to ensure delimitation of the areas that naturally form an entity for such co-ordination.
Coordinating working environment committees for fields as mentioned in the first subsection, should be limited organisationally to ensure representation of all main activity areas, familiarity with the local conditions at the workplace and proximity to the work of the committee. If agreement cannot be reached among the operator, the contractors in the various main activity areas and the safety delegates as to establishing a coordinating working environment committee that comprises more than one field, cf. the requirement regarding general agreement as mentioned in the first subsection, one of the parties can submit the issue to the Petroleum Safety Authority Norway; which, after having considered all aspects of the matter, can decide if such a working environment committee is to be established.
The coordinating working environment committee should set up subcommittees for the individual facilities when the committee encompasses several facilities, cf. . These regulations also apply directly to the petroleum activities, with the specifications and limitations given in the regulations.
The main activity areas mentioned in the second section, include drilling, well service, catering, construction, maintenance and production. What is to be considered as main activity areas, will depend on the actual activity on the various facilities.
In order to fulfil the requirement for participation as mentioned in the second subsection, the representatives should come from the principal undertaking and from the largest contractors in the various main activity areas. The employees' representatives should be elected by and among the safety delegates and main safety delegates for the various main activity areas. Two or more trade unions that together organise the majority of the employees in a main activity area can agree that the election will take place as a proportionate representation election or that these trade unions will appoint the employees' representatives for the area, cf. . These regulations also apply directly to the petroleum activities, with the specifications and limitations given in the regulations. The coordinating working environment committee for the field should have at least one employee representative from each manned facility on the field. The operator's representative on a mobile facility can have status either as an observer or as a representative with voting rights. On the joint, local working environment committee on mobile facilities, a representative of the operator can represent the employer side for contractors that have been hired by the operator.
Coordination as mentioned in the last subsection, means coordination of safety and environment-related matters that are of significance for both mobile and permanently placed facilities on the field.
Reference is made to Section 3-3 of the as regards occupational health services. The new does not have the same requirements related to safety personnel as earlier versions. However, there remains a need for safety personnel in the offshore petroleum activities, and these are defined as part of the occupational health service. The occupational health service shall be approved by the Norwegian Labour Inspection Authority and shall have a free and independent position in working environment matters, cf. Section 3-3, first and third subsections of the .
As far as the employers use of occupational health service is concerned, reference is, inter alia, also made to provisions on occupational health service in and . These regulations also apply directly to the petroleum activities, with the specifications and limitations given in the regulations.
In order to fulfil the requirement for cooperation as mentioned in the second subsection, the operator or the party responsible for the operation of a facility, shall enter into agreements with the principal undertaking and the employers of the contractor employees regarding distribution of the working environment tasks carried out by the occupational health service on the facility.
Long-term effects of working environment factors as mentioned in the first subsection, include long-term effects of hazardous noise.
For requirements related to health examinations as mentioned in the third subsection, reference is made to Section 3-1, second subsection, litera g and Section 10-11, seventh subsection of the .
Health-hazardous exposure as mentioned in the fourth subsection, includes exposure to
a) hazardous noise,
b) isocyanates or air containing lead,
c) heightened ambient pressure,
d) asbestos dust,
e) carcinogenic substances.
In order to fulfil the requirement for medical examination, the Norwegian Board of Health Supervision's guidelines regarding physicians in connection with examination of professional divers should be used for participants in manned underwater operations.
Working hours as mentioned in the first subsection, mean the actual time worked, including both normal working hours and any overtime.
To follow up working hours as mentioned in the first subsection, entails that the employer has a responsibility for own employees not working more than permitted, cf. .
The working time registers shall be available to the employee representatives, cf. Section 10-7 of the .
The health service means the organisation, the personnel and the resources that are necessary in order to attend to the health-related matters in the petroleum activities as mentioned in .
When health personnel carry out tasks as mentioned in , the responsibility, authority and prioritisation of work tasks shall be clearly defined as mentioned in .
In order to ensure satisfactory services, the rule stating that a physician shall have a special professional responsibility for the health service on the continental shelf, shall be continued. Physicians that participate in the health service, should have general medical experience and insight. The responsible physician shall have Norwegian authorisation or licence according to Sections 48 or 49 of the . The same applies to nurses.
In those cases where a nurse leaves the facility to accompany a patient to land, the requirement in the third subsection implies that compensating measures shall be implemented, and that the nurse returns to the facility as soon as possible.
In order to fulfil the requirement for adequate health services as mentioned in the first subsection, Chapter 5.1 of the standard should be used for manned underwater operations.
When performing the duties described in , the provisions relating to the health personnel's duty of secrecy, duty to report and to keep journals as stipulated in or pursuant to the , will apply. When a mobile facility that is registered in a national ships' register is laid up, the journals should be stored by the shipping company's onshore health service.
The health emergency preparedness as mentioned in litera c, should include
a) counselling and professional guidance for the health personnel on a facility or vessel,
b) communication with other health services,
c) prioritisation of transport for injured or ill personnel to land.
The requirement relating to arriving at the facility on the shortest possible notice, implies that systems shall be set up to enable rapid and efficient organisation of helicopter transport.
The physician should cooperate with personnel in the municipal health service with regard to following up actions in accordance with the legislation relating to dealing with communicable diseases.
Production, packing, storage, transport and presentation of food products shall be in accordance with the Food Act and appurtenant regulations, cf. .
The Ministry of Health and Care Services laid down for implementation of the Drinking Water Directive 98/83/EC, incorporated into the EEA Agreement on 25 January 2001. These regulations entered into force on 1 January 2001 and also apply to the petroleum activities.
In accordance with the and pursuant to delegation from the Norwegian Food Safety Authority, the County Governor of Rogaland supervises that the provisions regarding food, water supply and drinking water are complied with in the petroleum activities.
According to the , the duty of the water supply system's owner in the petroleum activities rests with the operator and other participants in the petroleum activities, cf. .
When a water supply system delivers water to another water supply system, it is important to identify what is included in the individual water supply system owner's responsibility.
In connection with planning and execution of cleaning activities, the NS-INSTA 800 standard should be used, with the following additions:
a) it is assumed that a decision regarding the level of quality is made as mentioned in ,
b) when planning the cleaning, the load in the various areas should, inter alia, be used as a basis.
In addition, the health service should take part in the planning. Cf. also .
Cleaning is of great importance in preventing e.g. respiratory disorders. The relationship between dust and health problems in sensitive individuals and individuals with asthma and allergies is well documented. The purpose of cleaning is to reduce the occurrence of dust particles, allergens and infective agents. Another purpose of cleaning is to create general welfare and well-being.
Main cleaning of indoor areas should be carried out at least once per year.
The following standards should be used in connection with preliminary surveys:
a) the NS-EN ISO 19901 Part 1 standard for surveying natural conditions,
b) Section 3 of the standard should be used for route surveys,
c) Chapter 7.9.1 of the standard for geotechnical surveys, with the following addition: a quaternary geological description should be prepared if in a new area,
d) Chapter 5.7.2 of the standard in the event of shallow gas surveys,
e) subsidence is calculated with the aid of geological models. As such models are associated with significant uncertainty, an upper 90 percentile should be used for the subsidence estimate. Consideration can be given to the stabilising effects of injection of gas or liquids.
If the surveys show that the likelihood of placing foundations above formations that contain gas is greater than one per cent, another location should be chosen.
In addition to preliminary surveys, baseline surveys shall be carried out as mentioned in to map the environmental status.
In order to fulfil the requirement for installation as mentioned in the first subsection,
a) Section 10.1 through 10.9 of the standard should be used for steel pipeline systems,
b) Chapter 9 of the API RP 17B guidelines should be used for flexible pipeline systems.
Commissioning as mentioned in the second subsection entails e.g. that safety systems shall be function tested and verified. To satisfy the requirement, the standard should be used, with the following additions:
a) Section 10.10 through 10.13 of the standard should be used for steel pipeline systems,
b) Chapter 9.5.3 of the API RP 17B guidelines should be used for flexible pipeline systems,
c) Appendix H to the standard should be used for lifting equipment,
d) Chapters 5.5 and 6.45 of the standard should be used for drilling facilities,
e) the result of function test are compared with performance requirements and relevant calculations,
f) is used where electrical, electronic and programmable electronic systems are used in the construction of the functions.
In order to fulfil the requirement for technical condition as mentioned in the third subsection, the standard should be used for preservation.
For the design of cabins, refer to .
A physical barrier means a function that can prevent or limit harm in the event of an unwanted incident. Other acute situations may, inter alia, constitute hazard and accident situations that have occurred, weather conditions that reduce the possibility of transporting personnel from the facility etc.
A turnaround/revision stop is a pre-planned period in which the operations on the facility have been shut down in order to carry out an accumulated portfolio of extensive and necessary maintenance, modifications, improvements, inspections etc.
Hook-up and start-up is the period from a new facility is placed on the field to hydro carbons are contained in the processing systems, and production has started. In this period, the facility will be commissioned; all systems hooked up, tested and started.
Cabin sharing is contingent upon compensation being given to those affected by it directly. It is an established practice between the parties to come up with solutions as far as compensation is concerned, and reference can be made, for that matter, to existing arrangements in this respect.
The operational organisation as mentioned in the second subsection litera a, also means the emergency preparedness organisation.
Governing documents as mentioned in the second subsection, litera b, also mean the guidelines, procedures, plans and programmes that are prepared according to these regulations and the .
In order to fulfil the requirement for technical operations documents as mentioned in the second subsection litera b, Chapter 4 and Appendices A, C and D of the standard should be used. For drilling and well technical equipment, Chapter 5 and Annexes A, B and C of the standard should also be used.
There are also requirements to qualifications and training in the field of working environment in . They relate to
a) work with chemicals, cf. those regulations chapter 3, except for sections 3-23, 3-24 and 3-27,
b) work with asbestos, cf. those regulations chapter 4, except for section 4-4,
c) work involving risk of being exposed to biological factors, cf. those regulations chapter 6,
d) work with work equipment that requires additional carefulness, cf. RCW chapter 10, with the exception of sections 10-1, 10-2 and 10-3,
e) maintenance of work equipment, cf. those regulations chapter 12,
f) work involving risk of being exposed to health detrimental noise or mechanical vibrations, cf. those regulations chapter 14, except for sections 14-1 – 14-7 included, and section 14-10,
g) work involving risk of being exposed to artificial optic radiation, cf. those regulations chapter 16,
h) safety signs and signalling, cf. those regulations chapter 22,
i) work imposing ergonomic strain, cf. those regulations chapter 23.
The requirement relating to ensuring competence implies, inter alia, that requirements are set for the necessary competence, that the competence is verified, and that it is maintained through practice, exercises, training and education.
In order to fulfil the requirement for competence in the area of health, safety and working environment,
a) Chapter 6 of the standard should be used for manned underwater operations,
b) Chapter 8 of the ISO 15544 standard should be used for emergency preparedness and safety, with the following addition: the should be used for safety and emergency preparedness training for personnel on facilities and vessels,
c) Chapter 4.9 of the standard and should be used for general competence within drilling and well activities, with the exception of Chapter 2.1.1 litera a and b on the requirements for examination. For posts as operators, training and examination in accordance with public curriculum VG2 well techniques should be undertaken. In cases of underbalanced drilling and completion, Chapter 13.7.2 of the standard should also be used,
d) the following regulations and guidelines should be used for work on electrical installations:
a) for personnel on permanently placed facilities, Sections 6, 7, 8, 9, 25 plus Appendix I or Sections 37, 44 and 45, or
b) for personnel on mobile facilities registered in a national ships' register, the Sections 37, 44 and 45, or
c) for the designated person responsible for the electrical installations as mentioned in the , Sections 7 and 25
e) Appendix 3 to the should be used for weather observers who carry out routine weather observations (METAR),
f) Appendix B to the standard should be used for lifting operations,
g) the Norwegian Maritime Authority’s should be used for maritime operations,
a) the party responsible for operating the maritime systems on permanently placed, mobile facilities, should fulfil the qualification requirements for comparable positions in the regulations mentioned in litera g of these guidelines. Control room operators who operate maritime systems on such permanently placed, mobile facilities, should fulfil the requirements related to certificates for control room operators in the same regulations. The party responsible for stability on board, should have maritime competence equivalent to the offshore installation manager in the same regulations,
b) in the event of operations with dynamic positioning Equipment Classes 2 and 3, those operating the equipment, should have competence in accordance with the regulations as mentioned in litera g of these guidelines, cf. . For operations in Equipment Class 1, one competent person is sufficient,
c) for facilities registered in a national ships' register, it is also assumed that maritime competence is documented in accordance with the requirements stipulated by the respective flag state authorities. The requirement in first subsection second sentence implies that jack-up facilities are staffed with personnel competent at and trained in operating the jacking systems in an emergency,
h) in connection with the use of communication equipment, it should be ensured that the person responsible for communication, cf. , second subsection, has sufficient experience as communications operator and valid GMDSS radio operator certificate (GOC or ROC depending on radio transmitting equipment on board), as well as necessary competence in areas such as emergency preparedness management, helicopter communication, meteorological observation and monitoring of the safety zones and maritime zones surrounding the facility.
i) should be used for qualifications for and training of helideck personnel,
j) the standard NS 9700 should be used for work with and on scaffolding, except for Part 2: Requirements for certification of scaffolders,
k) the standard NS 9600 should be used for rope access, except for requirements for certification of businesses and personnel.
As regards radio operators who operate maritime radio equipment, the competence requirements are specified in the licence terms set by the Ministry of Transport and Communications.
As regards certificates as mentioned in the second subsection, diving certificates issued by authorities in other countries are accepted if they document that the level of education corresponds with that which is recognised by Norwegian authorities. The reference used by the Petroleum Safety Authority Norway, is the ”Diving Industry Personnel Competence Standards” 2003, issued by the European Diving Technology Committee (EDTC) in cooperation with the International Marine Contractors Association (IMCA).
Re Section 22
Safety and working environment training pursuant to the Working Environment Act
As regards training as mentioned in the first subsection, reference is made to relevant provisions on safety delegates and working environment committees in Regulations relating to organisation, management and participation (in Norwegian only). These regulations also apply, with the limitations given directly in the regulations, to the petroleum activities. In addition, reference is made to the of the Norwegian Labour Inspection Authority, in which the requirement of the regulations that are being repealed upon entering into force of the new regulations in pursuance of the Working Environment Act, are included.
The training as mentioned in the second subsection should include aspects that are of significance to the overall workload of the individual, cf. .
In order to fulfil the requirement for radiation protection training as mentioned in the third subsection, the Norwegian Radiation and Nuclear Safety Authority’s training requirements should be used. Radioactive sources are substances that emit alpha, beta and gamma radiation
As regards requirements for training of safety delegates and members of working environment committees, reference is made to relevant provisions in Regulations relating to organisation, management and participation (in Norwegian only). These regulations also apply, with the limitations given directly in the regulations, to the petroleum activities. In addition, reference is made to the of the Norwegian Labour Inspection Authority, in which the requirement of the regulations that are being repealed upon entering into force of the new regulations in pursuance of the Working Environment Act, are included.
In order to fulfil the requirements for training and drills
a) simulator training should be used for monitoring and control functions,
b) personnel who have emergency preparedness functions, should practice their emergency preparedness tasks at least once during each period of stay. Everyone who takes part in emergency preparedness management and collaboration on emergency preparedness against acute pollution, should practice their emergency preparedness functions at least once each year.
An emergency preparedness drill covering all personnel on the facility should be carried out at least once during a period of stay. Mustering and evacuation routines should be included in the drill. At least one annual drill should be carried out for the emergency preparedness management and for personnel attending to collaboration on emergency preparedness against acute pollution. Drills related to collaboration on emergency preparedness against acute pollution should include skill training in the individual emergency preparedness functions and co-training between the operator and any agreement parties. The result of the drill should be evaluated.
When hired facilities or vessels are used, a drill should be conducted at an early point in time in accordance with a coordinated emergency preparedness plan for the contractor and the operator. If the same facility is used for a lengthy consecutive period, a major annual drill should be held involving both unit and area resources, relevant external resources, the operator's and the contractor's onshore emergency preparedness organisations, as well as the supervisory authorities,
a) Chapter 9.2 of the standard should be used for manned underwater operations,
b) Chapters 4.2.6, 4.2.7, 4.9.1, 4.9.2, 5.5.2, 6.5.2, 7.5.2, 9.3.5, 10.5.2, 11.5.2, 188.8.131.52.5.2, 13.7.2 and 14.5.2 of the standard should be used for drilling and well activities, with the following addition: regular drills should be carried out in well control, and the results should be evaluated.
The verification shall be performed in accordance with .
Procedure as mentioned in the first subsection, means a specified way of conducting an activity or a process, cf. Chapter 3.4.5 of NS-EN ISO 9000.
The formulation of procedures as mentioned in the second subsection, should be unambiguous, user-friendly and adapted to the users' competence.
The users of the procedures should take part in the formulation and revision of such procedures. The procedures should be tested before use to check design and contents with regard to the intended functions.
In order to fulfil the requirement for procedures as mentioned in the second subsection, Chapter 8.2 of the standard should be used for manned underwater operations.
Limitations for use as mentioned in the first subsection, can ensue from the loads that the facility and its individual parts shall be able to withstand, cf. . The loads can include chemical loads, environmental loads such as waves, wind and temperature and functional loads such as pressure, weight, temperature and vibration.
When conducting drilling and well activities with mobile facilities, the vertical movements of the facility and movements brought about by resonance between the wave frequency and the frequency of the facility itself should also be taken into account, as well as movements in the event of loss of position due to anchor line breakage or drift, or because of dynamic positioning failure. Cf. .
Facilities and parts thereof as mentioned in the first subsection, also include less complex facilities as mentioned in and temporary equipment.
In order to fulfil the requirement for use as mentioned in the first subsection, the standard should be used for temporary equipment.
Status as mentioned in the second subsection, means, inter alia, the backlog of preventive maintenance and the outstanding corrective maintenance.
When using facilities, systems and equipment beyond the original intended period, the party responsible should systematically review the effects of degradation and changes that have occurred, and expected degradation and changes over extended periods. In order to fulfil requirements for the conditions for use for an extended period, updated knowledge, data and information should be taken into account. The assessments should be based on . For structures and marine systems, the standard should also be used. For classified facilities, , Appendix A, Special Considerations for Ageing Offshore Units and , Chapter 2, Section 1, point 5 should be taken into account.
A safety system means technical barrier elements realised in a common system, cf. the and the .
The requirement in the first subsection entails that the measures and limitations shall result in a risk reduction which is relevant, and which is proportionate to the barrier functions that are affected; examples of which are limitation in the level of activities, full shut down or other risk reducing measures.
The status of active safety systems, cf. the second subsection, shall be available in the central control room, cf. the .
To fulfil the requirements for measures and limitations as mentioned in the first subsection, Chapter 7.7 of the IEC 61508-1 standard and Chapter 7.6 of the IEC 61508-2 standard , and Chapters 10 and 11 of should be used for electrical, electronic and programmable electronic safety systems.
Critical activities can be
a) work on pressurised, electrified or hydrocarbon-bearing systems,
b) hot work,
c) work with explosives or substances that self-ignite,
d) work on radioactive sources,
e) work that entails risk of acute pollution,
f) work that entails disconnection of safety systems,
g) lifting operations, cf. .
When identifying important contributors to risk, one should, inter alia, use the results from the risk analyses performed and experience from hazard and accident situations.
The limitations can be requirements for implementing compensatory measures in connection with executing an activity, or duration or frequency limitations for executing a special type of activity.
In order to fulfil the requirement for critical activities, Chapters 4.4, 4.5 and 4.6 of the standard should be used for drilling and well activities.
Activities as mentioned in the first subsection, can be production activities, drilling and well activities, and maintenance and modification activities, including activities as mentioned in .
Measures as mentioned in the second subsection, can be limitations or prohibitions that are to be implemented in connection with certain types of simultaneous activities during start-up, operation and shutdown.
In connection with executing activities as mentioned in the second subsection, the effect of mutual dependence between different activities should, inter alia, be taken into account.
In order to fulfil the requirement for simultaneous activities, Chapters 4.4, 4.5 and 4.6 of the standard should be used for drilling and well activities.
The requirement for planning as mentioned in the first subsection entails, inter alia, ensuring that the activities are executed within the limitations mentioned in .
Re Section 29a
Storage, handling and use of explosives
In order to ensure that explosives do not go off unintentionally as mentioned in the second subsection, electrically triggered perforating equipment for use in drilling and well activities should be protected against the effects of radio waves and other electrical fields, cf. the requirements for electrical compatibility in .
In addition, explosives should be protected against falling loads and fires during storage.
In order to fulfil the safety clearance requirement, a work permit system should be used.
When activities are cleared in accordance with this section, a safe job analysis should be conducted when sub-activities are not covered by procedures, the procedures can conflict with each other, or the activities are new to the personnel involved.
As regards conducting safe job analyses, Appendix B.4 to the ISO 17776 standard should be used in the area of health, safety and working environment. With regard to conducting a job safety analysis, see the last paragraph in the above-mentioned Appendix B.4, the party responsible for carrying out the work and the workers who actually carry it out, should participate, possibly also the persons responsible for the system and area.
To fulfil the requirements for measures, the should be used for this type of activities. In respect of measures relating to discharge of drainage water, refer to Chapter 7.8 Discharges from Facilities.
To fulfil the requirements for measures, Chapters 4.10.3, 8.2, 8.3, 8.4, 8.6 and 8.7 of the standard and should be used for drilling and well activities in the event of handover of wells between units, with the following addition: the wells' barrier status should be tested and verified.
In respect of tandem transfer of hydrocarbons from an FPSO or FSU to a shuttle tanker, it should be assessed whether to reduce other shipping activities to or from the FPSO or the FSU.
Handover of wells between units means handover between production, well service, operation, maintenance, etc.
Conditions as mentioned in the first subsection, can be conditions and parameters as mentioned in and , status for other safety systems, ongoing activities and implemented compensatory measures.
The requirement relating to continuous monitoring as mentioned in the first subsection, entails that the personnel shall not be assigned tasks that can impair their handling of the control and monitoring functions, cf. also and .
For monitoring and control as mentioned in the first subsection, there should be at least two persons to handle the monitoring and control functions as mentioned in the third subsection,
a) in the central control room on permanently manned facilities,
b) for operation of equipment for dynamic positioning, Classes 2 and 3,
c) for drilling and well activities.
To fulfil the requirement relating to monitoring and control, the standard, Chapters 8.3 and 8.5.1, should be used for manned underwater operations.
For monitoring and control of the external environment, see .
Shift and crew change means daily shift changes and replacement of personnel at the end of the period of stay on the facility, both for operator and contractor employees.
The organisation as mentioned in the first subsection, should, inter alia, take into account the need for individual adaptation, including work capacity and age. Cf. also and .
Hazardous exposure and unfortunate loads as mentioned in first subsection, mean exposure and loads that result from ergonomic conditions, chemical influences, radiation, noise, vibrations, climatic conditions and psychosocial conditions. Factors that can influence the psychosocial working environment, can be the interaction between requirements relating to work performance, the employee's perception of control over own work and social support in the working environment.
To avoid exposure that is hazardous to health as mentioned in the first subsection, measures or solutions should be selected at the highest of these levels:
a) elimination of the causes of the exposure,
b) technical measures that reduce the likelihood of exposure,
c) technical measures that reduce exposure,
d) operational measures that reduce exposure.
Organisation as mentioned in the first and second subsections, should be a continuous process where both employers and the employees strive to improve the working environment, cf. also .
Organisation of work should be based on accessible knowledge of the characteristics and needs of humans, so that the interaction between people, technology and organisation is optimised, cf. . The ISO 6385 standard should be used in such organisation.
The requirement relating to carrying out as much as possible of the work in the daytime as mentioned in the fourth subsection, entails that night work shall be limited to tasks and functions necessary to maintain prudent operations.
The requirement relating to necessary rest and restitution as mentioned in fourth subsection, entails that all personnel can sleep undisturbed and normally alone, cf. also , and that necessary transport in offshore periods, including helicopter transport, takes place during working hours.
For work above ground, Chapter 17 in the should be used.
For work in tanks, reference is made to relevant provisions in regulations under , stipulated 6 December 2011.
The purpose of the provision is to prevent unfortunate developments whereby the employee is not assured of sufficient restitution and rest, which could have safety-related consequences.
Regulations laid down by the Ministry of Labour and Social Affairs 6 December 2011, pursuant to the Working Environment Act, and entering into force 1 January 2013, contain, inter alia, further provisions on ergonomic aspects, including heavy and monotonous work and work at computer screens. Clarification of the scope as far as the petroleum activities are concerned, is directly evident from the individual regulations. In addition, reference is made to the of the Norwegian Labour Inspection Authority, in which the requirement of the regulations that are being repealed upon entering into force of the new regulations in pursuance of the Working Environment Act, are included.
In connection with the organisation as mentioned in the first subsection, the should be used. standard, Chapters 6.2, 6.3.2, 6.3.3, 7.8, and 7.9
For work at computer screens as mentioned in the third subsection, the Labour Inspection's Guidelines for work at computer screens should be used.
For information, see also .
Aspects as mentioned in the first sentence, can include
a) requirements relating to efficiency and workload in relation to the resources available for conducting the work tasks,
b) the work's complexity in relation to competence and resources,
c) opportunities for variation and stimulation in the job,
d) opportunities for independence and influence on important decisions,
e) opportunities for career development and utilisation of own competence,
f) climate of co-operation, handling of disagreements, conflicts and harassment,
g) work management, including feedback and follow-up in the daily work,
h) night work and working alone.
In order to avoid exposure as mentioned in the first subsection, the Regulations relating to conduct of work should be used.
As regards CO and CO2 as mentioned in second subsection, the standard, Chapters 184.108.40.206 and 220.127.116.11, should be used. In addition, special consideration should be given to potential release of, from materials under high pressure, chemical substances that are detrimental to health.
For information, see also .
Radiation means ionising and non-ionising radiation.
Handling also means handling during hazard and accident situations.
apply to the petroleum activities also.
To fulfil the requirement relating to avoiding exposure, the Norwegian Radiation and Nuclear Safety Authority’s
a) Guideline 1 relating to industrial radiography,
b) Guideline 9 relating to industrial control sources in fixed installations as well as use of radiation for research purposes, and
c) Guideline 13 relating to radioactive pollution and radioactive waste from the petroleum activities should be used in addition.
For information, see also .
Exposure action value as mentioned in this section, does not replace, but shall be seen in the context of, requirements related to risk reduction, cf. .
The risk assessment as mentioned in the third subsection, shall in particular take into account
a) exposure level, type and duration and exposure to impulse noise such as impacts and bangs,
b) effect on health and safety of employees who are especially exposed to risk,
c) any effect on the employees’ health and safety due to interaction of noise and chemical substances and between noise and vibrations in the work, to the extent possible,
d) indirect effects on the employees’ health and safety due to the noise's effect on the ability to register warning signals or other sounds that shall be audible to reduce the risk of accidents,
e) the manufacturer's information on the noise level of the working equipment,
f) whether alternative working equipment exists which gives lower noise exposure,
g) exposure to noise beyond regular working hours which falls under the employer's responsibility,
h) relevant information from health surveys, and other published information, to the extent possible, and
i) availability of hearing protection with sufficient sound reduction.
Information and training for the employees as mentioned in the fifth subsection, should especially include
a) the risk assessment made, and the measures implemented,
b) limit values and action values,
c) measurement results,
d) when there is a need for hearing protection and training in correct use, risk related to noise and how signs of hearing injuries can be discovered and how they shall be reported,
e) under which terms they are entitled to medical examination and the purpose of the examination,
f) ensure working methods that limit noise exposure to the extent possible, and
g) the risk of health injury potentially caused by the use of working equipment.
Regulations laid down by the Ministry of Labour and Social Affairs 6 December 2011, pursuant to the Working Environment Act, and entering into force 1 January 2013, contain, inter alia, further provisions on protection against mechanical vibrations. Clarification of the scope as far as the petroleum activities are concerned, is directly evident from the individual regulations. In addition, reference is made to the of the Norwegian Labour Inspection Authority, in which the requirement of the regulations that are being repealed upon entering into force of the new regulations in pursuance of the Working Environment Act, are included.
For information, see also .
In order to set criteria for choosing protective measures for outdoor work, the standard chapter 7.9 and A.8 in Annex A should be used.
For information, see also .
(This section has been repealed. The guidelines have been removed.)
(This section has been repealed. The guidelines have been removed.)
(This section has been repealed. The guidelines have been removed.)
Maintenance means the combination of all technical, administrative and managerial actions during the life cycle of an item intended to retain it in, or restore it to, a state in which it can perform the required function, cf. definition 2.1 (with associated terminology) in the NS-EN 13306 standard.
Maintenance includes activities such as monitoring, inspection, testing, trial and repair, and keeping things tidy.
Functions also mean safety functions, cf. . For these functions, the requirement relating to maintenance entails that performance shall be ensured at all times, cf. .
Facilities or parts of facilities also mean temporary equipment.
All phases also mean periods in which the facility or parts of the facility are temporarily or permanently shut down.
To fulfil the classification requirement, the standard should be used in the area of health, working environment and safety.
Fault (cf. functional fault), failure mode, failure cause and failure mechanism as mentioned in this section, are defined in the NS-EN 13306 standard.
The maintenance programme can consist of sub-programmes for inspection, testing, preventive maintenance, etc., cf. .
The requirement relating to prevention as mentioned in the first subsection, entails also that the programmes shall be available at start-up, cf. , second subsection, litera b. When preparing the maintenance programme as mentioned in the first subsection, the standard, the NS-EN ISO 20815:2008 standard Appendix I and the NEK IEC 60300-3-11 standard can be used in the area of health, working environment and safety.
For activities as mentioned in the second and third subsections, the following should be used in the area of health, working environment and safety:
a) the standards ISO 13702, Appendix C5, and IEC 61508, and is used for safety systems,
b) the emergency shut-down system is verified in accordance with the safety integrity levels set on the basis of the IEC 61508 standard and . For plants that are not covered by this standard and this guideline, the operability should be verified through a full-scale function test at least once each year. The test should cover all parts of the safety function, including closing of valves. The test should also include measurement of interior leakage through closed valves. Recording of the plant's or equipment's functionality in situations where the function is triggered or put to use, may replace testing of the plant or the equipment,
c) the standard should be used to monitor the condition of structures and maritime systems. See also ,
d) the standard should be used for preservation,
e) condition monitoring should be carried out at least once each year of risers with support and other particularly vulnerable parts of the pipeline system. Where there are multiple pipeline systems with identical properties for use, this monitoring can be performed on a representative selection,
f) the standard, Appendices G and H should be used for maintenance of lifting appliances and lifting gear,
g) the standards , Chapters 4.2.3 and 4.2.4 and table 15.9, ISO 10417 and ISO 10423, Chapter 9 should be used for well control and well intervention equipment, subsurface safety valves and christmas trees, with the following addition: the requirement in the second subsection of the regulations also includes the condition of barrier elements and pressure integrity in wells.
h) the IEC 61892 standard should be used for electrical installations with associated equipment.
The guidelines may be used to establish the inspection programme for process plants and auxiliary systems.
In order to fulfil the requirement relating to time limits as mentioned in the second subsection, the time limits should be calculated from the time when a failure mode is identified as having occurred or is under development.
Maintenance effectiveness as mentioned in the first subsection, means the ratio between the requirements stipulated for performance and technical condition and the actual results.
The standards NS-EN ISO 14224 and NS-EN ISO 20815, Appendix E, should be used when registering data as mentioned in the first subsection, including failure data and maintenance data.
Floating facilities which shall be inspected and maintained at sea without regular dry-docking, should use , Chapter 2, Section 1, Part 12.
For information about the second subsection, see .
The examinations as mentioned in the fourth subsection, should particularly be carried out with a view towards projected new facilities and use of facilities beyond their original planned lifetime in mind.
Failure modes as mentioned in the fifth subsection, mean both external and internal failure modes.
To fulfil the requirement relating to testing, complete overhaul and recertification so that the equipment can fulfil its required functions, the standard, Chapter 6.35.3, cf. , and the standard, Chapters 18.104.22.168 and 22.214.171.124 as well as tables 15.4, 15.14, 15.19, 15.21, 15.32, 15.37, 15.38, 15.47, 15.53, 15.57, 15.58 and 15.59 and Appendix A, Table 39, as well as should be used. See as regards this type of equipment in well interventions and overhaul of subsea wells.
Complete overhaul and recertification as mentioned in the second subsection, may be carried out continuously and in a manner which ensures that single components and the whole unit will be overhauled in a rolling five year period. The complete overhaul does not necessarily imply a full dismantling of all the parts, cf. design, operation and maintenance history, lifetime and associated risk assessments (classification) etc., but must be carried out in a way that will be eligible for recertification.
Chapter X contains supplementary provisions on how to monitor the external environment. The term operator is defined in the : Anyone executing on behalf of the licensee the day to day management of the petroleum activities.
Environmental monitoring of the Norwegian continental shelf includes both monitoring of benthic habitats (sediments, soft and hard benthic fauna) and monitoring of the water column. The purpose of the environmental monitoring offshore is to achieve:
a) an overview and control of pollution and impacts on the external environmental from the petroleum activities
b) an overview of the general condition and development around the individual facilities and in the regions (trends).
The results from the monitoring shall provide factual data based information that can be used as a basis for necessary actions to be taken on the continental shelf. The results from the monitoring can also be used for:
a) assessments of the risk for environmental damage and ecological effects
b) verification of models for calculating environmental risk as a function of the existing and expected discharges from the offshore activities
c) verification of laboratory research
d) preparation of reports in accordance with national administration plans, including environmental indicators.
In addition, the results can be reported in accordance with international treaties; to OSPAR, for instance.
Results from completed environmental monitoring, baseline surveys and impact assessments for field development will, together with an overview of discharges, form the basis for planning and implementation of further environmental monitoring. In order to obtain an optimum description of the conditions around the individual facilities and in the region, it is important that the monitoring programmes are designed in light of the existing discharge situation. This means that the operators in the planning stage shall consider and include relevant pollution components in the monitoring programme, as necessary, based on what is discharged on the individual field and in the region. Such an evaluation requires that the monitoring, annual reporting in accordance with the c and defined challenges from the Environmental Impact Assessments be seen as a whole.
The cooperation requirement as mentioned in the third subsection, entails that several operators cooperate so that the monitoring activities are managed in relation to regional risk, and arrangements are made for using the best available technology (BAT). The requirement relating to cooperation also entails that there shall be agreements between operators that have partly or completely identical areas of impact for pollution from their own activities. It is vital that the monitoring is conducted in accordance with a defined framework to ensure comparable results between years, and between different regions. The will provide the operators with a template for a standardised way of carrying out the surveys, thus making it possible to compare results from year to year and between various regions. The guidelines cover the most important surveys that all operators shall carry out, and the operators themselves shall decide whether there is need for additional or other surveys on the individual field or in the region. Any deviations from the standard station grid that have been used in previous surveys or given in the guidelines, shall be justified in the programmes for the environmental surveys.
For monitoring and control relating to proper implementation as regards health and safety, see .
It may also be relevant to monitor areas in the beach zone and onshore if these areas are affected by the petroleum activities.
The Norwegian Environment Agency and the Norwegian Radiation and Nuclear Safety Authority may, as for the other operator activities, audit the environmental monitoring in their areas. This applies to all stages of the activities, from planning of the surveys through to the various operators’ internal use of the results.
Plans for and results from monitoring of the external environment shall be reported to the Norwegian Environment Authority, and to the Norwegian Radiation and Nuclear Safety Authority for radioactivity, in accordance with .
The scope of baseline surveys as mentioned in the first subsection, may be adjusted to the need for obtaining new knowledge.
The scope of the surveys as mentioned in the first subsection, litera a, depends inter alia on the distance to areas that have been surveyed earlier, and benthic conditions.
The scope of the surveys as mentioned in the first subsection, litera b, depends inter alia on which vulnerable environmental values (species and habitats) that may be expected in the area. Vulnerable environmental values may include coral reefs, sponges, spawning grounds (sandeel).
The Norwegian Environment Agency may, following a concrete in-each-case assessment, alter the duration of a baseline survey. Experience has shown that it is mostly a question of prolonging the duration. If the Environment Agency alters the duration of a baseline survey, it will be effectuated as an administrative decision, which must be notified beforehand and justified, and which can be appealed against.
As a whole, the monitoring of the benthic habitats shall contribute to explaining whether a station or a larger area around the individual facility or in a region is affected by discharges from the activities. The results from the environmental monitoring shall be such that they can be used to check the conclusions of the impact assessment (IA) for the individual field and for the region. The relation between IA, actual discharges and environmental monitoring shall be emphasised.
A normal frequency for environmental monitoring is every three years. The guidelines may allow for a lower frequency, based on pollution loads, history and regional knowledge.
Since 1997, Norway has used the terms “reference stations” and “regional stations” in connection with monitoring of the seabed on the Norwegian continental shelf. Both types of stations normally cover the background level of selected components in the area, and the reference stations can, in given instances, function as regional stations and vice versa. Reference stations and regional stations in one and the same region are used to estimate background levels in the regions.
The term reference stations is now discontinued, and all non-field-specific stations are called regional stations in the new .
Plans for environmental monitoring of the benthic habitats shall be submitted to the Norwegian Environment Authority in accordance with .
The environmental monitoring of the water column is carried out so that possible effects from the discharges of the petroleum activities on the pelagic environment, can be documented. The requirement on monitoring of the water column is not limited to monitoring of produced water, but also comprises relevant added chemicals and leakage and leaks from the seabed, plus other relevant discharges, if any.
The frequency of monitoring in the field is every three years. The monitoring should include hydrographical measurements, chemical measurements and monitoring of organisms in cages and free-living organisms. The scope of the monitoring must be discussed with the Norwegian Environment Agency.
There are currently few internationally accepted standardised methods for monitoring of biological effects in the water column. A number of methods are, however, under development, and many have been tested in the field. This primarily applies to various biomarkers which are being used more and more for monitoring impact and, gradually, for monitoring condition. Still, measurement of concentration levels in selected organisms will see further use in the environmental monitoring around petroleum facilities on the Norwegian continental shelf. The operators shall participate actively in the testing and development of suitable methods for environmental monitoring. The period between two monitoring activities in the field shall be used, hence, to develop and qualify new methods. The Norwegian Environment Agency should be consulted on significant items during the process, by presenting progress and plans for the coming year in an annual planning meeting as outlined in the .
As the monitoring is still at the stage of methods being developed and tested, the guidelines will be regularly revised. As soon as suitable methods for monitoring the effects of long-term discharge impact will be established, a selection of these shall be used in a more standardised programme.
Plans for environmental monitoring of the water column shall be submitted to the Norwegian Environment Authority in accordance with .
By environmental monitoring of offshore petroleum activities irregularities and deviations connected with the activities, can be detected. Examples of such deviations can be abnormally high THC values, which cannot be linked to known discharges. The operator has a duty to determine the reason for the deviation and take corrective action if necessary.
Deviations shall be reported to the Norwegian Environment Authority as soon as possible, cf. .
The purpose of detection and mapping of acute pollution is to ensure that the information concerning the pollution is sufficient, so that the correct actions are taken in order to stop and limit the pollution, cf. , and that acute pollution is notified, reported and reported in writing, cf. and . Acute pollution is defined in . Overall, compliance with the various requirements related to detection must ensure that all acute pollution is detected including smaller leaks that can produce effects over time.
The operator shall take measures against acute pollution that has been discovered, cf. and , cf. , second subsection.
The requirements for detection and acute pollution monitoring include all types of pollution (oil, cuttings, oily water, chemicals, etc.) and all parts of the environment (sea surface, water column, seabed, air). Monitoring of injection activity is also covered by this provision.
This section applies to detection and mapping of pollution due to unwanted incidents and accidents, and failure of barriers to prevent and stop pollution at the source. Requirements for barriers to detect abnormal conditions, etc. and safety functions are in accordance with , cf. the , first paragraph, letter h and . These are general requirements for safety under the , and they also include barriers and systems for preventing and halting acute pollution. Barriers and safety functions such as process monitoring, including pressure, flow and temperature measurements, and detection equipment on facilities below the sea surface will also provide important information for detection and mapping of acute pollution. It is therefore expected that information from the barriers and safety functions will also be included in the detection and mapping system as mentioned in the second subsection of this section.
The operator must assess the types and amounts of pollution that can be detected / mapped using the barriers and safety funtions mentioned above, and which require other methods. Other methods / elements that should be part of the detection and mapping system, are
a) detection and mapping equipment located on facilities, seagoing vessels, aircraft and satellites,
b) detection and mapping equipment by facilities under the sea surface,
c) associated competence for interpreting information from the different sensors,
d) visual observation of the sea surface carried out by personnel on facilities, seagoing vessels and aircraft. Observations must be based on expertise for visual quantification of oil and chemicals by means of area measurement and use of colour thickness charts for the relevant oil or chemical type,
e) model tools for predicting transport and spreading of acute pollution,
f) meteorological services necessary to support detection and mapping.
Continuous monitoring may include all or part of the facilities and areas around. For example, through radar systems on the surface and leak detection systems that cover parts of facilities on the seabed.
The fifth subsection clarifies the obligation to cooperate on emergency preparedness as stipulated in the .
Mapping of thickness distribution as mentioned in the sixth subsection, shall be done both to estimate discharges and as a basis for selecting a fighting strategy. For visual observation on the sea surface, oil and oil quantity estimation should be made according to
The requirements for continuous improvement laid down in also mean that the operator shall contribute to the necessary further development of tools for the detection and mapping of acute pollution.
replaces, from 1 January 2019, the requirements for discovering acute pollution that is given in the permits for petroleum activities pursuant to the . In the permits where such requirements have been made for the detection of acute pollution, the requirements will continually be taken out in connection with changes being made to these permits.
Follow-up surveys mean chemical and biological surveys both during and after acute pollution. It should be possible to utilise the results of such surveys both during the combat phase with regard to evaluation of relevant measures for optimal combating of the pollution, and in the restoration phase with regard to identification of environmental values that have been harmed. Such surveys may require special instrumentation and technical measuring equipment, particularly in the event of underwater discharges for surveys in the water column.
The Norwegian Environment Agency's provide a framework for the contents of such surveys.
A survey report shall be submitted to the National Coastal Administration and the Norwegian Environment Agency in accordance with .
To be able to characterize as soon as possible as mentioned in the first subsection, in the event of a discovery, the oil or condensate should immediately be sampled with a sample volume sufficient to characterize physical and chemical properties. If possible, the sample volume should be sufficient to perform meso scale weathering studies. Whenever possible, the results of the meso scale weathering studies should be available prior to start-up of production drilling.
Prior to new activities in the same reservoir or in the event of field development, a full weathering study should normally also be completed.
The results of the characterization constitute, inter alia, an important basis for implementing simulations of drift and dispersion, cf. , and for obtaining a correct description of the efficacy of current emergency preparedness material, cf. .
Weathering as mentioned in the second subsection, means how the chemical and physical properties of the oil/condensate change over time as a result of the external conditions it is subjected to. Relevant external conditions include expected wind and wave conditions on the location, and the possible occurrence of ice on the sea surface.
Oil and condensate that can occur as acute pollution as mentioned in the third subsection, also mean blends of different production streams.
Re Section 59a
Analysis of radioactivity in formation water
The results of the radioactivity analyses shall form the basis for assessments in the impact assessment in a future development of the discovery, and later for an application for the discharge of naturally occurring radioactive substances from the field.
The operator must obtain a permit from the Norwegian Environmental Agency for petroleum activities under . Application for permit under the Pollution Control Act is subject to , and a fee is fixed for the Environmental Agency’s processing relating to applications for permits pursuant to
The regulations’ general requirements for the petroleum activities on the continental shelf apply to all operators. The permits under the Pollution Control Act will normally contain conditions that are specific and adapted to each activity gives further provisions on the processing of permits under the Pollution Control Act. The Norwegian Environment Agency has described further expectations for the content of applications and expected processing time in the . gives provisions for fees for work with permits.
Section 11 of the Framework Regulations describes principles for risk reduction, including requirements regarding the use of best available techniques (BAT).
set specific requirements for follow-up and improvement in , including requirements for continuous improvement. In addition, the Norwegian Environment Agency shall be informed in case of changes in risk of pollution cf. .
Oil content as mentioned in the second subsection, means content of dispersed oil in undiluted water decided in accordance with .
In accordance with principles of risk reduction and management ( and ), the responsible party shall establish a management system that ensures compliance with the HSE regulations and continuous improvement. This entails that the responsible party shall establish and develop goals and strategies for compliance with the regulatory requirement to keep the oil content as low as possible. does also state that facilities for treatment of produced water shall be designed in such a way that oil content in each discharge is as low as possible.
OSPAR Recommendation 2012/5 is implemented in Norwegian legislation in . The Recommendation includes requirements to perform risk assessments on discharge of produced water, and that best available measures shall be selected in order to reduce risk.
Risk assessments should be performed with methods based on expected environmental concentrations and expected non-harmful concentrations (PEC/PNEC) on substance level. The method based on Environmental Impact Factor may be used.
“Significant changes in the discharge of produces water” mentioned in third subsection, includes:
a) the introduction of new measures expected to have an impact on the risk level, for example reinjection, chemical substitution and treatment measures
b) increased discharges as a result of changes in injection rate
c) significant changes in the composition of produced water, for example as a result of inclusion or exclusion of well streams or chemicals
d) 50 % changes in amount of oil to sea, oil concentration or chemicals with significant contribution to the risk, applying to installations with EIF between 10 and 50
e) 15 % changes in amount of oil to sea, oil concentration or chemicals with significant contribution to the risk, applying to installations with EIF higher than 50.
When assessing how the treatment facilities shall operate to minimize the environmental impact, the oil content of the discharge shall be evaluated against inter alia use and discharge of chemicals.
The risk assessments shall be reported in accordance with .
According to , «the responsible party shall choose the technical, operational, or organizational solution that (…) offer the best results. In addition, and demand continuous improvement. Therefore, the Norwegian Environment Agency expect that the results from the risk assessment are applied further in new BAT assessments and potential measures to reduce the environmental risk for each field.
New technology assessments are performed for all installations according to the results from risk assessments, but the level of detail may depend on the magnitude of the risk contribution or the oil content in the water discharged to sea. The assessments shall include measures to reduce the total discharged volume of water, for example with techniques such as water shut-off, downhole separation and injection, as well as treatment measures.
For fields with high risk contribution or with high oil content in the water discharged to sea, detailed assessments of costs associated with the various measures should be compared to the environmental benefits. For fields with a low risk contribution, the same degree of details in cost/benefit assessments will normally not be necessary, in particular as regards implementing of expensive technology. The Norwegian Environment Agency will consider the definition of low/high risk contribution when results from risk assessments are available. When technology is available for treating other substances than dispersed oil, the Norwegian Environment Agency may require such treatments.
Technical solutions that can reduce the environmental impact of discharges of oily water, may be downhole solutions for reduced water production, reinjection or new/altered technical elements in the treatment plant, for example.Assessments should be reported in accordance with .
Chemicals following the produced water to sea after treatment, shall be covered by the permit in accordance with first subsection. Adding chemicals that do not contain a specific function in the production or treatment process, is not allowed.
Measures as mentioned in the sixth subsection, may include monitoring of oil and seabirds, or mechanical dispersion, for example. There may also be other technical measures to reduce the visible oil on the sea surface, changing the discharge point or temporarily reduce the discharges of produced water, for example.
Re Section 60a
Discharge of drainage water and other oily water
Oily drainage water means hosing-down water from the facility decks and rain water.
Drainage water and other oily water not treated and then discharged to the sea from the facility in accordance with , or injected, are wastes and should be brought to an approved recipient ashore. In connection with the ban on adding unused chemicals, including chemical residues and other waste in drainage water and other oily water to be discharged to sea pursuant to this section, reference is made to , second subsection, and to .
Re Section 60b
Discharge of oily displacement water
Displacement water means seawater in storage cells for oil. The seawater enters the storage cells when oil is loaded for further export and escapes to sea when the storage cells are filled with new oil.
Polluting emissions to air on the Norwegian shelf come under the scope of the . With regard to energy-producing plants offshore (existing and new plants with a supplied total nominal thermal output exceeding 50 MW), the EU council directive 96/61/EEC on integrated prevention and limitation of pollution (the IPPC directive) also applies. Pursuant to the EEA agreement, the directive applies to Norway and has been implemented in Norwegian legislation. The directive sets requirements for the pollution control authorities' follow-up of the enterprises and the duties of these enterprises with respect to the environment. Norway's obligations under the directive will be fulfilled by application of the . Follow-up of the directive implies the stipulation of new requirements for emissions to air from energy-producing plants offshore.
The and the IPPC directive require that the best available techniques (BAT) be used when stipulating emission requirements to reflect what can be achieved by using BAT, while not specifying the actual techniques to be used. To help the authorities decide which techniques can be considered BAT, the EU is preparing instructive BAT reference documents, both for individual industries and across industries. These documents show which techniques can be generally considered to be consistent with the IPPC directive’s requirements relating to BAT. Thus, the BREF documents cannot be said to specify BAT requirements as such, but shall be regarded as guidelines for BAT assessments. The energy-producing plants offshore are included in the BREF for large combustion plants (LCP-BREF). When stipulating what shall be considered BAT in the individual case, the pollution authorities will emphasise available relevant BREFs, the installation’s technical characteristics, its geographical location and the local environmental conditions.
New fields and new development projects shall be operated in accordance with the directive from the date when the activities start (Article 4).
Choice of development solution may be of great importance to the technical and economic consequences by limiting the emissions to air. There may therefore be a mutual connection between the terms set in the emission permit to limit emissions, and the choice of development concept. Therefore, in the event of new developments and upgrading of existing ones, the operator should inform the Norwegian Environment Agency about its BAT assessments early in the development process, i.e. in ample time prior to making a choice and deciding on development solutions, and prior to entering into binding contracts. This applies regardless of whether this development is subject to the requirement for carrying out impact assessments. The BAT assessments should also be included in the impact assessment and in the application for emission permit pursuant to the . In the application, the operator shall demonstrate and substantiate that the chosen solutions can be considered BAT.
According to , the company shall apply for emission of NOx and CO2. It follows from that “a party subject to a quota obligation pursuant to , shall, upon application, be granted permission for emissions of greenhouse gases subject to quota obligations if said party can prove that he is able to monitor and report the emissions in a satisfactory manner.”
Re Section 61a
The requirement shall ensure that energy efficiency is maintained and improved continuously. An energy management system is a prerequisite for operating in accordance with BAT, cf. . For new fields, the energy management system, including a flaring strategy, shall be in place when the field starts production. The energy management system shall be updated regularly.
Re Section 61b
For new facilities, the requirement implies that the production facilities and the energy facilities shall be designed with the aim of achieving as energy efficient production and operation as possible throughout the lifetime of the field. For existing facilities, the requirement implies that continuous measures shall be taken to improve energy efficiency. Examples of measures are power co-operation, increased utilization of surplus energy, use of solutions that work efficiently also by changes in production volume, operational optimization and reduced flaring. provides guidance for energy efficient design and operation of processes and energy facilities.
A chemical is a generic term for chemical substances and/or substance mixtures.
The term “substance” implies, as referred to in OSPAR Guidelines for Completing the HOCNF, as the chemical element and its chemical compound in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product, and any impurity deriving from the process used. Solvents, which may be separated without affecting the stability of the substance or changing its composition, are excluded. Substances were previously called component.
All chemicals used in the petroleum sector, are also subject to the with regulations, including REACH.
OECD’s principles for good laboratory practice as mentioned in first section, imply the principles described in OECD Series on Principles of Good Laboratory Practice (GLP) and Compliance Monitoring (ISSN: 2077-785X). Norwegian Accreditation (NA) is the Norwegian agency for the accreditation of technical matters, including GLP as mentioned in the first subsection.
Re second subsection
“OECD guidelines for testing of chemicals” refers to The OECD Guidelines for the Testing of Chemicals.
Test no. 306 (Biodegradability in Seawater) is found in OECD Guidelines for Testing of Chemicals, section 3 (1981, ISSN: 2074-577x (online)). The guideline describes two potential tests – “shaker flask test” and “closed bottle test”. Only one test is required.
“Substances that are known to be toxic to microorganisms” denotes in particular biocides. For such substances, recommendations in Annex II of OECD 1992 302 should be followed.
If biodegradation data from fresh water tests are used, a safety factor of 0.7 should be applied, for recalculation of biodegradation.
Re third subsection
“OECD guidelines for testing of chemicals” refers to The OECD Guidelines for the Testing of Chemicals.
Test no 117 (Partition Coefficient (n-octanol/water), HPLC Method) and 107 (Partition Coefficient (n-octanol/water): Shake Flask Method) are found in OECD’s guidelines for testing of chemicals section 1 (1981, ISSN: 2074-5753 (online)).
The potential for bioaccumulation is given as the partition coefficient octanol/water, Log Pow.
OECD test no. 107 is a suitable method for substances that are water soluble and which do not dissolve or dissociate, but are not suitable for lipophilic organic substances, complex substances organo metals or surface active agents. The method can be used to determine LogPow-values from -2 to 4.
OECD test no. 117 is suitable for complex substances, but not suitable for strong acids and bases, metal complexes, substances reacting with the eluent or surface active substances. The method can be used to find log Pow-values from 0 to 6. If the results from OECD test no. 117 demonstrate several values, all peaks with an area above 5 % in the chromatogram shall be stated. The highest value of these is defined as the substance’s Log Pow.
“Substances that cannot be tested according to standardized methods”, denotes in particular surface active substances.
If log Pow is greater than or equal to 3, it is assumed that the substance bioaccumulates, unless experimentally determined bioaccumulation data (BCF) indicate the opposite.
Professional evaluation of bioaccumulation potential and estimated values for log Pow should be stated in the HOCNF comment field.
Re fourth subsection
With ISO 10253:2006 implies ISO 10253:2006: Marine algal growth inhibition test with Skeletonema costatum and Phaeodactylum tricornutum.
With "ISO 14669:1999" implies ISO 14669:1999: Determination of acute lethal toxicity to marine copepods (Copepoda, Crustacea).
“OSPAR’s protocol for testing of chemicals used in the offshore oil industry” refers to "OSPAR Protocols on Methods for the Testing of Chemicals Used in the Offshore Oil Industry (reference number: 2005-11 (a revised version of agreement 1995-07))". Testing of acute toxicity on fish is described in "Part B: Protocol for a Fish Acute-Toxicity Test", while testing of toxicity on Corophium sp is described in "Part A: A Sediment Bioassay using the Amphipod Corophium sp".
Corophium sp. is a benthic amphipod, and is therefore an appropriate model organism to study toxicity of substances that could be expected to end up in sediments.
Re sixth subsection
"Harmonised Offshore Chemical Notification Format", refers to annex 1 in OSPAR Recommendation 2010/3 on a Harmonised Offshore Chemical Notification Format (HOCNF). With "part 2" implies Part 2: Ecotoxicological information.
To fill out the HOCNF, see OSPAR Guidelines for Completing the Harmonised Offshore Chemical Notification Format (HOCNF) (Reference number: 2010-05) and Supplementary guidance for the completing of harmonised offshore notification format (HOCNF) for the Norwegian sector. Submitting the HOCNF to the Norwegian Environment Agency is not required, however, it has to be available on request.
The requirements apply for chemicals used in the petroleum industry (see Section 6 litera g of the Framework Regulations); including those associated with exploration, normal operation and maintenance during the extraction and processing of oil, gas and, condensate, shut-down of installations and plugging of wells, including emergency preparedness chemicals. Chemicals used exclusively for household purposes and on the facility’s living quarters, are exempt.
Chemicals used in auxiliary system, pipe lines and water-injection, including chemicals that remain in the well and chemicals that will follow the hydrocarbon stream even though they are not intended for discharge on the field, are covered by requirements for ecotoxicological testing and documentation.
In the context of testing of bioaccumulation and biodegradability of dope, the grease part is considered to be a substance. All components of grease must be expressed in HOCNF.
Chemicals in fire water systems have since 1st of January 2013 been covered by requirements for ecotoxicological testing and documentation.
Accidental emissions of chemicals occur in closed systems. If the system volume is large, it will mean there is potential for large emissions. Testing and ecotoxicological documentation shall ensure that there is available information about chemicals in such systems in case of accidental emissions. Consumption, as mentioned in sixth subsection litera b, denotes the first filling of the system, replacement and all other use of the chemical. Chemicals in closed systems with no discharge to the external environment, may for example be BOP-liquid or hydraulic liquid.
For testing and documentation of dispersants and shoreline cleaning agents, the requirements in .
Exact denomination of the strong acids and bases that are exempted for requirements on ecotoxicological testing, cf. subsection eight, with corresponding CAS-numbers, are included in the table below.
Polymers exempted from testing and ecotoxicological documentation in the form of HONF Part Two are considered to be non-degradable, but not toxic or accumulative. The operator may choose to provide data if he considers this relevant to the environmental assessments.
Re seventh subsection
Additive packages in Chemicals in closed systems with no discharge to the external environment, can be named additive packages as a single substance in the HOCNF, even if consisting of several substances.
Impurities from the production process as mentioned above, which comprises more than 1 percent of the substance mixture, are considered as substances to be mentioned in the HOCNF, but are not subject to testing requirements.
A chemical is a generic term for chemical substances and/or mixtures of substances.
“Substance” refers to, as in OSPAR Guidelines for Completing the HOCNF; the chemical element and its chemical compound in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product, and any impurity deriving from the process used. Solvents which may be separated without affecting the stability of the substance or changing its composition, are excluded. Substances were previously called component.
The priority list can be found in .
“OSPAR’s Priority List” refers to OSPAR List of Chemicals for Priority Action (Revised 2011) (Reference number 2004-12).
Substances covered by REACH’s list of candidates can be found in .
The exception from classification for mixtures in black category is sustained for substances where the content of substance is below the lowest concentration limit for classification, cf. the .
Mutagenic and reprotoxic substances denote substances that damage genetic material in gametes (Muta) category 1A and 1B and reprotoxic substances (Repr) 1A and 1B, cf. the
When assessing the properties of degradation products for substances with moderate degradation, results from testing of inherent biodegradability, among other things, may be used together with other available information on substances. The assessment should be documented. In the industry, the terms y1, y2 and y3 and respective yellow subcategories 1, 2 and 3 are often used.
If there is a lack of knowledge on degradation products, these should be considered to fall in subcategory 3 in accordance with the precautionary principle.
The strong acids and bases which are exempt from requirements for ecotoxicological testing, cf. eighth subsection, are treated as substances in yellow category.“OSPAR’s PLONOR list”, as mentioned in the second subsection, refers to OSPAR List of Substances Used and Discharged Offshore which Are Considered to Pose Little or No Risk to the Environment (PLONOR) (OSPAR Agreement 2013-06).
REACH Annex V includes substances that are exempted registration in REACH. Entry 8 and 9 in Annex V include naturally occurring substances. Some of these are classified as non-hazardous and can be equated with substances on the PLONOR list. Substances in Entry 7 can be treated likewise if it can be demonstrated that they are not hazardous, in accordance with Directive 67/548/EEC with regard to the marine environment, and not OBT or vPvN as given in the criteria in REACH Annex XIII, or identifies in accordance to Article 59 (1) or Article 57 (f). If questions whether a substance which is covered in REACH Annex V is in green category, the Norwegian Environment Agency shall be contacted for an assessment.
Environmental assessments shall also be performed for chemicals that are not covered by requirements to ecotoxicological testing and documentation. The operator should assess the toxicity, biodegradability and potential for bioaccumulation of these chemicals. The assessment should be documented and based on test data or literature data.
The assessment of the chemicals as mentioned in the first subsection, should also include treatment of waste/hazardous waste and necessary transport. Assessment of the fate of the chemicals in the environment may be included under “other matters of significance”.
The duty to substitute chemicals which may harm health or the environment with less damaging alternatives, also follows from .
Impurities as mentioned in the second subsection, mean, inter alia, heavy metals in weight materials.
Separate plans for substitution of chemicals in the red and black category, and the yellow category, subcategories 2 and 3, shall be reported annually to the Norwegian Environment Agency in accordance with , first subsection, litera c.
The basis for permits as mentioned in the first subsection, is the results from testing, categorisation and assessment of chemicals as mentioned in .
Ordinary pollution from homes, offices and the like, including sanitary wastewater, is permitted under . Use and discharge of chemicals from this site of the business does not therefore require authorization pursuant to , unless otherwise specified in the regulations.. The and its regulations apply to all chemicals used. This means, inter alia, that the substitution requirement also applies.
In activities that entail use and/or discharge of chemicals in amounts which the operator considers to be very small and not covered by applicable permits, the Norwegian Environment Agency may be contacted to clarify the need for a permit.
The ban on discharges of unused chemicals as mentioned in the second subsection, also applies to chemicals on the OSPAR PLONOR list.
The duty to reduce the use and discharge to the extent possible, also applies to chemicals for which there are no specific use and discharge limits, cf. .
Even if the operator has received permission to use and discharge chemicals, an assessment shall be made of whether there are other less environmentally harmful alternatives pursuant to the substitution duty in Section 3a of the , and of these regulations.
This provision legalises some cases of field testing that will not be permitted within the permit under the . Chemicals that are field tested according to this provision, are also exempted from the requirement for ecotoxicological documentation, cf. , seventh subsection, letter e. Testing of chemicals can also take place within the scope of the permit as long as the chemicals are environmentally as good or better alternatives than chemicals that are in use, and the consumption and emission amounts in the permit are not exceeded. Other field testing requires a special permit pursuant to the .The duration limitation in the eighth subsection letter a implies that the total duration of the field test may be longer than 14 days for discontinuous use. As a basis for finding an assumed colour category for field testing of chemicals, the operator must assess the toxicity, biodegradability and potential of bioaccumulation. The assessment should be documented and based on test or literature data.
When handling applications for the discharge of large amounts of water containing chemicals from pipelines as mentioned in the eight subsection, the Norwegian Environment Agency will place great emphasis on the recommendations from the relevant expert agencies. The conclusions following from the consultations with independent expert agencies, should be included in the application. Large amounts in this case refer to volumes greater than 1000 m3 of water.
As regards use of dispersants and beach cleaning agents for combating acute oil pollution, reference is made to . The Norwegian Coastal Administration is the professional authority in an acute situation if dispersants are not included in the operator’s emergency preparedness plans.All use and discharge of chemicals shall be reported in accordance with .
Regarding planning and use of dispersants and beach-cleaning agents, refer to See also the and .
Re Section 66a
Use and discharge of radioactive trace elements
Although the permission is given for use and discharge of a certain amount of radioactive trace elements, emissions shall be as low as possible.
Emergency preparedness chemicals shall be tested and assessed as mentioned in and .
The assessment shall not be submitted.
Any possible use and discharge of chemicals for emergency preparedness, cf. , shall be reported as mentioned in .
The responsible party shall assess whether there are less hazardous emergency preparedness chemicals than those in the list of emergency preparedness chemicals, in accordance with Section 3a of the .
Normally, the Norwegian Environment Agency will not impose further requirements for handling of cuttings with appendages of water-based drilling fluid. This will be considered, however, in areas with vulnerable benthic communities.
Cuttings means both solid material from the formation and solid material added as part of the drilling fluid or other fluids used in drilling and well activities. Organic drilling fluid means mineral oil-based and synthetic drilling fluid.
Even if the oil or base fluid in synthetic drilling fluid as mentioned in the second subsection, is less than ten grams per kilo of dry substance, the operator should consider additional cleaning or other disposal methods than discharge to sea, for example injection.
Information on case processing times can be obtained from the Norwegian Environment Agency upon request.
By formation testing, this section refers to testing of a single well's production or injection properties for a maximum of ten days of flow, cf. the Section 3.
By clean-up of of wells, this section refers to activity carried out on producing wells where hydrocarbons and other liquids are brought to the surface to clean the well and perforations before the well is put into production or back into production.
Minimization as mentioned in the first and second subsections, shall be understood as minimization given that the purpose of the activity is achieved and the measures are in a reasonable proportion to the damage and inconveniences to be avoided.The assessment of the choice of method and planning of the activity should include energy consumption, emission components and emission amounts to air and sea, chemical use, generation and handling of waste and risk of acute pollution, both at sea and with any handling on land. The time and place of the activity in conjunction with the presence of vulnerable environmental values should also be included in the assessments.
Measures to minimize emissions may include access to tanks with sufficient storage capacity and continuous testing of the test facility to ensure optimal combustion.
Measures as mentioned in the third subsection, may include monitoring of oil and seabirds, or mechanical dispersion to remove oil from the sea surface.
The test facility, including equipment for the separation of water, oil and gas and flares, shall comply with the requirements for the use of best available techniques (BAT), cf. the , second paragraph, cf. the and
Well clean-ups and start-up of production wells can lead to operational challenges and the risk of reduced cleaning efficiency in the production water treatment plant to a greater or lesser extent. These are activities that are planned and where operational challenges and disturbances in the treatment plant can be prevented, including through good planning based on knowledge of expected content and amounts of chemicals in the fluid flow, impact on the treatment plant and the establishment of methods for operating the processing plant in various operations.
If oil and chemical-containing water from clean-up and boilers are landed, the colour categories and chemical assessments used for offshore petroleum activities cannot be transferred directly to the operations on land. The environmental significance may be different from land discharges, in shallow waters with other natural resources and recipient conditions. This also applies to chemicals in the green category, which are considered not to present a risk of damage to open-sea discharges.
If oil and chemical containing water is sent to recipients on land outside Norway, the operator is obliged to ensure that the treatment of the water at the recipient is legal, but the requirement for permit will not always be relevant.
An overview of which substances the requirement applies to, can be found in . The measurement programme as mentioned in the second subsection, should include a description of the method for manual measurement if an automatic analyser is out of commission. The measurement programme should also cover changes in procedures in cases where unstable operation of the installation is expected or detected.
Re Section 70a
Measuring the discharged amount of radioactive substances
Organic drilling fluid means mineral oil-based and synthetic drilling fluid. Solids include cuttings, produced sand and other solid materials from the well, such as packing and inert materials.
The requirement relating to measuring also applies to sediments and deposits from process equipment
Handling of waste as mentioned in the second subsection, shall be done in accordance with . Reference is made to on the duty to avoid pollution, on prohibition against litter and on handling of production waste. Unless otherwise specifically determined, regulations relating to waste from the petroleum activities are applicable to the extent they are suitable. In this connection, reference is made to and , Prohibition against incineration at sea, and on dredging and dumping in sea and watercourses.
The prohibition against the leaving behind of equipment on the seabed as mentioned in the third subsection, is a specification of and . The prohibition entails that equipment that is used in activities associated with the petroleum activities, including well heads, shall be retrieved after use if leaving it behind will result in damage or negative consequences to the environment. The Norwegian Environment Agency may, upon application, permit the leaving behind of equipment on the seabed. The Norwegian Environment Agency will, however, follow a strict practice when handling applications for leaving equipment behind, and permission will be granted in exceptional cases only. The operator is recommended to contact the Norwegian Environment Agency with regard to the assessment of whether concrete cases of leaving behind will result in damage or negative consequences to the environment, and before submitting applications for leaving behind. As far as the prohibition against dumping is concerned, reference is made to .
The plan for treatment of waste as mentioned in the fourth subsection, should include reduction of waste volume, source separation, reuse, recycling and potential energy recovery.
Waste oil as mentioned in the fifth subsection, means used lubricants and similar oils (used in engines, gear boxes, hydraulic systems, transformers, switches etc.) that can no longer be used as originally intended.
To fulfil the requirement relating to the strategy as mentioned in the first subsection, the standard ISO 15544 should be used for health and safety-related emergency preparedness.
The defined hazard and accident situations as mentioned in the first subsection, mean a representative selection of hazard and accident situations used in the dimensioning of the emergency preparedness.
In order to fulfil the requirement relating to establishing emergency preparedness as mentioned in the first subsection, the standard, Chapters 5.1.5 and 9, should be used for manned underwater operations.
The emergency preparedness shall be coordinated, cf. , and the operator shall cooperate with other operators, cf. .
The results of the environmental risk and emergency preparedness analysis and the description of planned emergency preparedness, as mentioned in the first subsection, should be submitted as part of the application for permit pursuant to the .
Contractual cooperation as mentioned in the first subsection, means, for example, entering into agreements relating to common emergency preparedness plans or agreements to use the emergency preparedness resources of others to ensure optimal emergency response in major acute incidents within an area or region. The availability of public resources in acute pollution situations will depend on no other prioritised activities being underway. Necessary evaluations of sensitivity and uncertainty with respect to availability of such resources shall be performed.
Emergency preparedness organisation as mentioned in the first subsection, means the personnel, including a physician, directly associated with unit resources, area resources, external resources and regional resources.
In order to ensure robustness as mentioned in the first subsection, emphasis should be placed on the individual's education and expertise, experience, physical suitability, personal qualities and experience from drills and training when selecting the personnel.
The hazard and accident situations as mentioned in the first subsection, also include other hazard and accident situations than the defined, complex hazard and accident situations, stress situations and situations where key personnel are incapacitated or are unable to carry out their duties.
Necessary functions as mentioned in the second subsection, means, inter alia, operational leadership, operation, detection and mapping of acute pollution, environment, economy, logistics and information.
The emergency preparedness plans should include
a) a description of purpose, scope and responsibility,
b) a description of organisation, notification, mobilisation and communication,
c) action plans,
d) a description of fields and facility(-ies) and prioritised vulnerable environmental values in the impact area for acute pollution,
e) a description of unit resources, area resources, regional resources and external resources and equipment,
f) instructions for emergency preparedness personnel,
g) any coordination procedures vis-à-vis other involved parties, cf. , second and third subsections,
h) any cooperation procedures and agreements, cf. .
Action plans as mentioned in litera c of these guidelines, should cover, inter alia,
a) emergency preparedness strategy, emergency preparedness measures and decision criteria for the emergency preparedness phases,
b) in order to handle acute pollution, the emergency preparedness strategy should comprise objectives for protection of prioritised vulnerable environmental values. The description of emergency preparedness measures and decision criteria for the various emergency preparedness phases should include response times for relevant emergency preparedness measures, detection and mapping, choice of emergency preparedness measures based on minimum environmental harm considerations, shore clean-up and environmental surveys in case of acute pollution,
c) for the health-related emergency preparedness, treatment of
a) personal injuries in the event of major accident situations,
b) personal injuries in the event of industrial accidents,
c) acute illness,
d) psychological reactions,
e) communicable diseases,
To fulfil the requirement relating to emergency preparedness plans, the standard, Chapter 9.1, should be used for manned underwater operations.
With regard to , certain supporting documents have been prepared as an aid to enterprises wishing to include dispersion as a method of emergency preparedness. They consist of “Control form for use of dispersants” and “Decision form for use of dispersants with guidelines”. Further information can be found on the websites of the Norwegian Environment Agency ( ) and the Norwegian Coastal Administration ( ).
Giving the right notification as mentioned in litera a, means notifying, inter alia,
a) the facility's central control room or other central function,
b) the Joint Rescue Coordination Centre
c) one or more parts of the operator's emergency preparedness organisation,
d) the contractors' emergency preparedness organisations,
e) other licensees and partners in the event of an agreement relating to coordinated emergency preparedness resources, or in the event of joint use of production and/or transport systems.
The scope of the notification will depend on the situation at hand. The Joint Rescue Coordination Centre as mentioned in litera b of these guidelines, handles further notification of bodies that have national emergency resources. This includes notification of the Norwegian Coastal Administration, which is responsible for the public emergency preparedness in relation to acute pollution. For information, see also .
To fulfil the requirement to notification of well control incidents, the should be used.
The requirement relating to rescue as mentioned in litera c, entails that the responsible party shall be able to
a) locate missing personnel using personnel control systems,
b) bring personnel to safe areas on vessels, facilities or land,
c) give injured personnel lifesaving first aid and medical treatment on their own facilities, the standby vessel or other facilities.
The requirement relating to rescue also entails that MOB boat systems have their own crews. For information, see .
The requirement relating to evacuation as mentioned in litera d, entails that the evacuation measures shall be of a nature that provides the highest possible likelihood that personnel can be evacuated from an exposed area to a safe area on the facility and, if applicable, to safe areas on vessels, other facilities or on land. As regards sick and injured personnel, the requirement implies that transport to the land-based health service takes place in a safe and prudent manner. For information, see also .
In order to fulfil the evacuation requirement as mentioned in litera d, the standard, Chapter 9.5, should be used for divers under pressure.
The requirement relating to normalisation as mentioned in litera e, also implies that
a) injured or sick personnel are given the necessary treatment and care, such as medical treatment on land and follow-up of physical and psychological delayed injuries, and that the next of kin are provided with the necessary information, care and follow-up after major accidents,
b) damage to the facility and reservoir is stabilised and corrected,
c) the operation of the facility is resumed.
The total emergency preparedness shall be dynamic and suited to the needs in various areas and time periods. It may be necessary, for example, to increase the availability of resources in the Barents Sea in periods of high activity.
Measures as mentioned in the third subsection, can for example be development of a new concept or new solutions, rescheduling of activities or strengthened emergency preparedness.
When preparing the plan as mentioned in the first subsection, the basis should be the emergency preparedness action plans, cf. .
As mentioned in , the plans for action against acute pollution shall be submitted to the Norwegian Coastal Administration.
In the event of action against acute pollution, both mechanical and chemical alternatives shall be considered. Chemical combatting shall be used if this, overall, results in the lowest strain on the environment, cf. the .
Documentation as mentioned in the fourth subsection, means a clarification of
a) measures taken,
b) results from mapping, cf. , and environmental surveys in connection with acute pollution, cf. ,
c) damage or negative consequences to the environment,
d) criteria for concluding measures.
In order to communicate as mentioned in the first subsection, it should be possible, inter alia, to
a) provide important information to personnel on the facility during operations and in hazard and accident situations,
b) communicate important information between personnel in the control centre, personnel engaged in the operation of process facilities, drilling operations and lifting operations,
c) establish and maintain direct and continuous communication between communication operators, field and platform management, internal and external emergency resources during hazard and accident situations,
d) provide communication in the event of a coordinated action against acute pollution.
The requirement relating to external communication as mentioned in the first subsection, means that manned facilities shall have 24-hour continuous telecommunications services with monitoring service on VHF channel 70 (DSC) and channel 16. The service can be established on one’s own facility or as a part of a joint solution where several facilities are within a specifically defined area.
In connection with such a solution,
a) a central communications centre should be established on one of the facilities and an alternative centre should be prepared on one of the other facilities,
b) the facilities covered by the solution should be covered by mutual VHF radio communication and be organised under the second-line emergency preparedness management,
c) efficient routines should be established to achieve contact with the facilities when the local radio station is not manned,
d) the facilities shall have mutual permanent communication systems.
The other facilities covered by this solution should have a communication operator who primarily handles communication tasks in hazard and accident situations.
A person responsible for communications as mentioned in the second subsection, means a person who has a particular responsibility to ensure the professional operation of the facility's radio station and use of the other communication systems at all times.
For information, see .
In order to fulfil the requirement relating to the programme as mentioned in the first subsection, the standard, Chapters 4.3, 4.7, 4.10.2 and 9.3 should be used in the area of health, working environment and safety.
For wells that are to be temporarily plugged back, the programme should also describe
a) plans for future use of the well,
b) securing of the wellhead,
c) planned location inspections and their frequency,
d) an evaluation of well integrity seen in the context of the design life for the barriers, cf. also .
The updating as mentioned in the second subsection, implies, for example, that a new programme shall be prepared for wells that have not been put to use according to the original plan, or that have been temporarily plugged back for three years.
In order to fulfil the requirement relating to well location and wellbore as mentioned in the first subsection, the standard, Chapters 4.3 and 5.7.4 should be used, with the following addition:
a) the well's location and wellbore should be stated in Universal Transverse of Mercator (UTM) coordinates.
Formation fluids as mentioned in the first subsection, also means hydrates and water under pressure.
In order to fulfil the requirement, the standard, Chapter 5.7.2 should be used in the area of health, working environment and safety.
The requirement relating to collection implies, inter alia, that data that could indicate a possible well control incident, are monitored, recorded and processed.
In order to fulfil the requirement relating to collection, the standard, Chapters 4.7, 5.7.3 and 5.7.4 should be used, with the following addition: when testing the formation's fracture strength, pressure testing to the maximum anticipated pressure for the well section should be carried out.
In order to fulfil the requirement relating to the barrier as mentioned in the first subsection, the standard, Chapters 4.2, 4.3, 4.4, 5.1, 5.2, 5.3 and 15 should be used in the area of health, working environment and safety. For information, see also .
Where a homogeneous liquid column constitutes the primary barrier, the barrier requirement as mentioned in the first subsection, entails that there is sufficient drilling fluid material and drilling fluid available to maintain the barrier, cf. also .
The handover as mentioned in the third subsection, includes handover between companies and handover between units on the facility. Examples of such units are “production”, “well service”, “operation” and “maintenance”.
Pumping and fluid capacity, as mentioned in the third subsection, means preparedness for handling a failure in one or more well barriers, cf. on well control. By heavy well intervention, as mentioned in the third subsection, is meant coiled tubing and snubbing operations. By light well intervention, as mentioned in the third subsection, is meant cable and pumping operations. In order to fulfil the requirement in the third subsection, standard, Chapters 4.2.8 and 10.4 should be used.
In order to fulfil the requirement for handover of wells as mentioned in the third subsection, the standard, Chapters 4.10, 8.2, 8.3, 8.6, 8.7 and 8.8 and should be used for drilling and well activities.
Well control incident as mentioned in the first subsection, means the failure of one or more well barriers where the failure results in unintended flow of formation fluid into the well, cross flow in the well or outflow to the external environment.
Intervening directly in or on the well as mentioned in the first subsection, means re-establishment of barriers by using established well control methods or by using capping equipment.
In the event of using established well control methods, the standard, Chapter 4.2.8 should be used.
In the event of using capping equipment for subsea wells, the standard, Chapter 4.8.3 should be used.
In order to regain well control by relief well drilling as mentioned in the first subsection, the standard, Chapter 4.8.2 should be used.
When planning activities as mentioned in the second subsection, the standard, Chapter 4.8 should be used, with the following addition: evaluation of technical and operational feasibility, plus location, operation and well specific risk assessments for the method chosen.
Organisational independence as mentioned in the second subsection, is described in the guidelines to .
To fulfil the requirement to plans as mentioned in the fourth subsection, the standard, Chapters 4.8 should be used, with the following additions:
a) the plans should describe the need for and availability of facility(ies) and services,
b) plans for relief well drilling and capping operations that require modifications of facility(ies), use of additional equipment, vessels or new technology, should detail how this can be mobilised and operative prior to start-up of the operation that requires this.
Controlled well stream means formation testing, test production, clean-up and stimulation of the well. Discharges from formation testing and clean-up of wells are regulated in .
In order to fulfil the requirement to operational limitations in the area of health, working environment and safety, the standard, Chapters 6, 7, 8 and 14, plus tables 15.27, 15.32, 15.34, 15.35, 15.36, 15.45 and 15.46 should be used. Cf. also .
To fulfil the requirement relating to securing as mentioned in the first subsection, the standard, Chapter 9 should be used in the area of health, working environment and safety. For information, see also .
The monitoring as mentioned in the first subsection, should be carried out by monitoring the pressure above the lowermost barrier.
In order to control the well integrity as mentioned in the second subsection, one should, inter alia, be able to monitor pressure conditions or set a blind plug just above or below the packer element. For surface-completed wells, it should be possible to monitor the pressure in the annulus and in the production tubing, or as an alternative, in the last casing set. For subsea-completed wells, it should be possible to monitor the pressure in the production tubing and in the production annulus.
If it is necessary to abandon the radioactive source in the well, as mentioned in the third subsection, the standard, Chapter 9 and table 15.24 should be used, with the following additions:
a) an internal overview of abandoned sources should be established and maintained. The overview should contain details about every single source and its position,
b) radioactive sources abandoned in work strings should be secured in a manner which clearly indicates any unintentional drilling close to/in the direction of the source’s position.
also requires that information on abandoned sources shall be given to the Norwegian Radiation and Nuclear Safety Authority .
In order to fulfil the requirement for remote-operated pipe handling, should be used. For information, see also .
The requirement regarding limitations as mentioned in the second subsection, implies, inter alia, that the work area for the remote-operated systems shall be determined.
Personnel as mentioned in the third subsection, means those manning the control and monitoring functions, and personnel staying inside the work area of these systems. The personnel should be able to have corresponding contact and communication among themselves.
In order to fulfil the requirement relating to marine operations as mentioned in the first subsection, Table 1 Equipment Class should be used for vessels and facilities with dynamic positioning, with the following addition:
in the event of dynamic positioning near other floating facilities or vessels, consideration should be given, inter alia, to
a) mutual movement and different movement patterns,
b) the effect of current and noise from propellers,
c) interference with other or joint transponders
d) varying shadow effect for antennas connected to the dynamic positioning system.
For calculation of anchoring systems, see also .
Table 1 Equipment Class
For a description of the equipment classes in this table, see IMO/MSC Circular 645, Chapter 2, Equipment Classes.
a) Manned underwater operations
where loss of position entails a high risk for divers or diver platforms
b) Other manned underwater operations
where loss of position entails risk for divers or diver platforms
c) Support vessels for manned underwater operations conducted from work boats
where loss of position for the support vessel has direct consequences for the work boat
d) Drilling and well activities
where well control is ensured by a facility with dynamic positioning
e) Facilities that produce or store hydrocarbons
f) Flotels with gangway connected
Two reference systems may be accepted for arrival and departure
g) Activities carried out by lifting vessels or pipe-laying vessels in the vicinity of the facility (here permanently placed and mobile/floating)
It may be acceptable for only two out of three reference systems to be operational upon arrival and departure
h) Other activities within the safety zone, where the vessel represents a risk to the facility
The requirement applies if the vessel exceeds the vessel size the facility is designed for with regard to withstanding a collision.
Two reference systems may be accepted for arrival and departure
i 1) Tank vessel loading from facilities handling hydrocarbons
i 2) Tank vessel loading from subsea loading and off-loading installations
where the tank vessel is not moored or anchored to these installations
i 3) Tank vessel loading from subsea loading and off-loading installations
where the tank vessel is moored or anchored to these installations
1* or 2*
j) Loading operations from buoys
k) Other well activities
The requirement applies to well maintenance facilities if well control is handled by another facility
l) Shallow drilling
if encountering hydrocarbons is not expected
*Class 1 if the distance between associated facility(-ies) and tank vessel is 2.5 km or more, Class 2 if not.
Notes to the table
1) For dynamic positioning, consideration should be given to the reference systems' limitations as regards reliability, availability and quality.
2) High risk as mentioned in this table litera a, means the cases when the diver does not have an unrestricted return to the diving bell, or where loss of the vessel's position can lead to loss of or damage to the diving bell, and possibly the associated bottom weight.
3) The requirement relating to Equipment Class 3 for drilling and well activities as mentioned in this table litera d, does not apply to shallow drilling and core drilling. For shallow drilling, however, other requirements in the table may be relevant, such as the requirement relating to Equipment Class 2 for other activities within the safety zone without risk to health, environment and safety. Well activities that require Equipment Class 3, include well intervention, such as wireline operations. Other well activities as mentioned in this table litera k, with requirements for Equipment Class 2, where the production facility has well control equipment, may be well stimulations and unmanned underwater operations, including the use of remote-controlled subsea vessels or subsea tools.
4) The recommendation for Equipment Class 2 for tank vessels as mentioned in this table, is conditional upon the preparation of a positioning capacity plot for the dynamic positioning system.
In order to maintain the position as mentioned in the second subsection, floating production, storage and offloading facilities (FPSOs) and floating storage units (FSUs) that offload to tank vessels, should be equipped with directional control. For information, see also .
Floating production and storage facilities should at all times know their own position and direction and the position and direction of nearby facilities and larger vessels, cf. .
In loading operations where no hawser is being used, the tank vessel should be able to stop the loading automatically if the limits for distance and direction are exceeded, at the same time as emergency shutdown valves are being closed on the facility and on the vessel, cf. .
Operation of positioning and anchoring systems should be in accordance with .
For vessels anchored within the safety zone which are larger than the facility has been designed to withstand collision with, the anchoring should fulfil (the Anchoring Regulations 09), and should conform with if they lie adjacent to the facility.
In order to fulfil the requirements relating to work as mentioned in the first subsection,
b) NEK EN 50110-1 Safety when working on and operating electrical installations (in Norwegian only)
c) , Section 1 up to and including Section 5 and Section 7 up to and
including Section 12,
should be used, as well as
d) IMCA D 045, R 015 Code of practice for the safe use of electricity under water, which should be used for manned underwater operations.
Being the designated responsible person as mentioned in the second subsection, entails having a particular professional responsibility for ensuring that electrical installations comply with applicable regulations at all times, and for keeping up-to-date on electrical installations and equipment under planning, construction and commissioning, etc. As regards qualifications for the person with responsibility for the electrical installations, see Section 21.
In order to fulfil the requirement relating to lifting operations as mentioned in the first subsection, the standard should be used. Cf. also and of these regulations.
For information, see also
The standard should be used during manned underwater operations.
Stays at working depth as mentioned in litera a, means the time between completed compression, alternatively first compression if work is to be carried out at several pressure levels, and start of final decompression.
Bell runs as mentioned in litera c, shall be calculated continuously from when the clamp between the bell and the chamber is first loosened and stops when the clamp is reconnected, ready for pressure equalisation and final transfer of the divers back to the chamber complex.
Surface personnel as mentioned in litera h, means the diving supervisor or possibly a diving supervisor candidate under qualified leadership.
When stipulating breaks as mentioned in litera h, the workload should be used as a basis; however, the breaks should not be shorter than a half hour.
See , too.
1. Regulations and guidelines issued by the authorities
The Ministry of Labour and Social Affairs
The Ministry of Labour and Social Affairs, the Ministry of Justice and Public Security
The Ministry of Labour and Social Affairs, The Ministry of Justice and Public Security, The Ministry of Climate and Environment
Regulations of 30 May 2008 No. 518 relating to registration, evaluation, authorisation and restriction of chemicals (REACH) (in Norwegian only).
The Ministry of Health and Care Services
, chapter 19, 21, 22, 36 and 39(in Norwegian only).
The Ministry of Labour and Social Affairs, the Ministry of Justice and Public Security, the Ministry of Agriculture and Food, the Ministry of Climate and Environment
The Ministry of Justice and Public Security, the Ministry of Health and Care Services
The Directorate for Civil Protection and Emergency Planning
The Civil Aviation Authority
The Norwegian Petroleum Directorate
The Norwegian Maritime Authority
The Norwegian Environment Agency
(In Norwegian only)
The Norwegian Board of Health
The Norwegian Radiation and Nuclera Safety Authority
Guidelines for the radiation protection regulations (in Norwegian only):
2. Standards and guidelines
American Petroleum Institute (API)
API Spec 17B Recommended Practice for Flexible Pipe, Fifth Edition, May 2014.
Submarine Pipeline Systems, Edition October 2017,
Verification for compliance with Norwegian shelf regulations, Edition July 2017,
DNV GL rules for classification: Floating production, storage and loading units, Edition July 2018,
Drilling Facilities, Edition January 2018,
Recertification of Well Control Equipment, Edition February 2017,
Risk Based Inspection of Offshore Topsides Static Mechanical Equipment, Edition July 2017,
Fleet in service, Edition January 2018.
European Diving Technology Committee (EDTC)
Inshore and Offshore Diving Industry Personnel Competence Standards, January 2018, Updated March 2018. Published in cooperation with the International Marine Contractors Association (IMCA).
European Standard (EN)
NS-EN 13306:2017 Maintenance Terminology, Edition 1, February 2018.
International Electrotechnical Commission (IEC)
NEK IEC 60300-3-11 Dependability management - Part 3-11: Application guide – Reliability centred maintenance. Edition 2, August 2009,
NEK IEC 61508 Functional safety of electrical/electronic/programmable electronic safety-related systems, Edition 2, Parts 1-72010,
Part 1: General requirements,
Part 2: Requirements for electrical/electronic/programmable electronic safety-related systems,
Part 3: Software requirements,
Part 4: Definitions and abbreviations,
Part 5: Examples of methods for the determination of safety integrity levels,
Part 6: Guidelines on the application of IEC 61508-2 and 61508-3,
Part 7: Overview of techniques and measures,
NEK IEC 61892 Mobile and fixed offshore units - Electrical installations, Parts 1-7, (2007-2015).
The International Marine Contractors Association (IMCA)
IMCA D 045, R 015 Code of practice for the safe use of electricity under water, October 2010.
International Maritime Organization (IMO)
IMO/MSC circular 645, Guidelines for vessels with dynamic positioning systems, 6 June 1994.
“Please observe that IMO now has issued IMO MSC.1/Circ.1580 (16 June 2017) Guidelines for Vessels and Units with Dynamic Positioning (DP) Systems. IMCA has issued it as document 245 IMO (August 2017).
PREAMBLE 1 and 2 included below:
1 The Guidelines for vessels with dynamic positioning systems (MSC/Circ.645) were approved by MSC 63 in May 1994 to provide the industry with an international standard for dynamic positioning systems on all types of vessels. These Guidelines for new vessels and units with dynamic positioning systems have been developed to provide an amended standard reflecting the development in DP operation since 1994 and the current industry practice and DP technologies.
2 It is recommended that the present Guidelines be applied to vessels and units constructed on or after 9 June 2017. For vessels and units constructed on or after 1 July 1994 but before 9 June 2017, the previous version of the Guidelines (MSC/Circ.645) may continue to be applied, however it is recommended that section 4 of the present Guidelines be applied to all new and existing vessels and units, as appropriate.”
International Organization for Standardization (ISO)
ISO 15544:2000/Amd 1:2009 Petroleum and natural gas industries – Offshore production installations – Requirements and guidelines for emergency response, Edition 1, 2010,
ISO 10417:2004 Petroleum and natural gas industries - Subsurface safety valve systems - Design, installation, operation and redress, Edition 2, 2004,
ISO 17776:2016 Petroleum and natural gas industries - Offshore production installations - Guidelines on tools and techniques for hazard identification and risk assessment, Edition 2, 2016,
NS-EN ISO 14224:2016 Petroleum, petrochemical and natural gas industries - Collection and exchange of reliability and maintenance data for equipment, Edition 3, 2016,
NS-EN ISO 20815:2010 Petroleum, petrochemical and natural gas industries – Production assurance and reliability management (ISO 20815:2008, corrected version 2009-06-15), Edition 1, 2010.
Norwegian Standard (NS)
NS-EN ISO 9000:2015 Quality management systems – Fundamentals and vocabulary, Edition 1, 2015,
NS-EN ISO 13702:2015 Petroleum and natural gas industries – Control and mitigation of fires and explosions on offshore production installations – Requirements and guidelines, Edition 1, 2015,
NS-EN ISO 10423:2009, Petroleum and natural gas industries – Drilling and production equipment – Wellhead and Christmas tree equipment, Edition 1, 2010,
NS-INSTA 800-1:2018 Cleaning quality – Part 1: Measuring system for assessment and rating of cleaning quality, Edition 1, 2018,
NEK EN 50110-1:2013 Safety when working on and operating electrical installations – Part 1: General requirements, Edition 1, 2013,
NS-EN ISO 19901-1:2015 Petroleum and natural gas industries -- Specific requirements for offshore structures -- Part 1: Metocean design and operating considerations, Edition 1 2016,
NS 9600:2010 Rope access techniques, Parts 1-4, Edition 1, 2010,
NS 9700:2016 Scaffolding and covered constructions, Parts 1-2, Edition 1, 2016.
Drilling facilities, Edition 3, December 2012,
Well integrity in drilling and well operations, Edition 4, June 2013,
Integrity of offshore structures, Edition 8, September 2012,
In-service integrity management of structures and maritime systems, Edition 2, October 2017,
As+sessment of structural integrity for existing offshore load-bearing structures, Edition 2, April 2015,
Safe use of lifting equipment, Edition 3, June 2017,
Working environment, Edition 5, March 2018,
Environmental care, Edition 4, October 2017,
Manned underwater operations, Edition 5, November 2015,
Documentation for operation (DFO), Edition 4, March 1998,
Preservation, Edition 3, August 2015,
Mechanical Completion and Commissioning, Edition 3, August 2015,
Risk based maintenance and consequence classification, Edition 4, December 2017,
Temporary equipment, Edition 4, September 2012,
Norwegian Oil and Gas Association
, revision no. 22, 19 October 2015,
, revision no. 6, 29 January 2016,
, revision no. 2, 15 November 2010,
, revision no. 03, June 2018,
, revision 1, 1 September 2009,
, revision 5, 3 June 2015,
, revision no. 6, 8 November 2017,
Norwegian Shipowners’ Association
, 6 November 2013