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A reliable system

The acknowledgement of compliance (AoC) is an important tool for monitoring the safety of mobile units on the NCS . But it rests on trust and a clear allocation of responsibility.




This article was originally published in
Safety - Status and Signals 2012-2013

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A total of 51 AoCs were in place at 1 January 2013, qualifying 39 drilling rigs, six flotels, three production floaters and three well intervention vessels to operate on the NCS.

Possession of such acceptance means that the PSA is confident that the relevant drilling rig, for example, can conduct petroleum activities in compliance with the regulations.

It does not signify that the regulator has any responsibility for ensuring that this unit operates in accordance with the rules – that rests solely with the owner/operator.

An AoC from the PSA merely indicates that the conditions for safe operation are present, backed by an extensive review of the unit and the organisation which will be operating it.

Responsible
The vessel contractor is responsible for ensuring that the operating organisation complies with the regulatory requirements.

This duty also extends to the relevant management systems and the unit’s technical condition, and to measuring and documenting that the regulations have been met.

It must be possible to provide such documentation at any time while the unit has an AoC, and the regulator can check this information through audits and other measures.

A unit is subject to a detailed check before being accepted, and it is still the case that this process more often than not reveals nonconformities or improvement points.

But the PSA does not issue an AoC until such deficiencies have been corrected or compensated for, so that the level of safety on the unit accords with the regulations.

Questions were posed publicly in 2012 about the safety of Scarabeo 8 and Floatel Superior in the wake of serious incident  which had occurred on these units.

Nonconformities identified on them by the PSA were listed by the media and other observers, with the implication that they were unsuitable for their assignments.

But it must be stressed that these deviations were irrelevant in these cases, because they had all been identified by the PSA during the AoC award process.

Units cannot operate on the NCS while this assessment is under way, and none are accepted until nonconformities from the regulations have been dealt with.