Audit of how groups at risk are followed up on Borgland Dolphin
The Petroleum Safety Authority Norway (PSA) conducted an audit of the work done by Dolphin and Halliburton to identify and follow up groups at risk in their own activities. We identified one nonconformity in relation to the regulatory requirements.
The verification offshore on Borgland Dolphin (photo) was carried out from 22-24 June 2010.
The companies were asked to demonstrate to the PSA that a functional management system had been established to ensure that risk factors for the relevant groups were identified, mapped and followed up in a manner designed to ensure satisfactory working environment and personal safety conditions.
Particular emphasis was placed on how Dolphin and Halliburton evaluated the significance of framework conditions on the risk for groups employed by contractors. Dolphin identified mechanics as a group at risk, while Halliburton identified cementers.
We started the audit activity with a kick-off meeting on land on 17 September 2009. Statoil (which at that time was the operator of Borgland Dolphin), Dolphin and Halliburton gave presentations at this meeting, with emphasis on the following factors:
- Which groups are considered to potentially be most at risk on Borgland Dolphin (one group with Dolphin and one group with Halliburton), and the basis for such assessment
- What types of mapping and assessments have been made of working environment factors for the groups, separately and collectively, (cf. Section 4-1 of the (Norwegian) Working Environment Act regarding fully satisfactory working environment based on a separate and collective assessment of working environment factors)? The risk of both personal injury and illness shall be included in this assessment.
- Overview of the incidence and assessment of work-related illness and injury on the party of the groups
- An account of the framework conditions the groups work under, and an evaluation of how these conditions can affect risk and how risk is handled
- Overview of what is done to handle risk (of injury and illness) identified in relation to the groups, including:
- Prioritisation and implementation of measures based on working environment assessments and mapping
- Verification from the companies to ensure that measures have been implemented and function as intended
- Employee participation
- Training and competence
- Responsibility and distribution of roles between operating companies, shipowners, contractors and subcontractors
- An overview of the most important elements in the contracts between Statoil, Dolphin and Halliburton that have direct or indirect impact on personnel safety, both in a major accident and individual perspective.
This audit is part of the PSA’s main priorities for 2009 and 2010: Groups at risk. This has also been one of the PSA’s main priorities in 2007 and 2008.
During the period 2007 – 2008, the PSA conducted an industry-wide audit activity aimed at seven operating companies and eight contractors under contract.
The audit targeted the companies’ systematic work to develop a comprehensive picture of risk for groups, development of measures and cooperation between operating companies and contractors in this work.
We also wanted to make sure that the companies evaluated the impact of framework conditions in risk.
One of the main conclusions from the PSA’s audit activities in this area is that groups employed by contractors have a substantially weaker position as regards several of the elements within HSE management as compared with groups employed by operating companies.
We have learned that framework conditions, such as contractual aspects, financial aspects and organisation of work can contribute to a poorer outcome for contractor groups.
Shipowners were not included in the audit activity in the period 2007 and 2008, and we therefore wanted to include shipowners in one of the audit activities aimed at safeguarding groups exposed to risk in 2009.
The goal of the PSA’s efforts in 2009 was to contribute to reducing the risk of injury and illness for particularly vulnerable groups by:
- Following up to ensure that the companies further develop an overall picture of the risk of illness and injury for groups of employees, and that new knowledge is used actively in a risk-based approach where efforts are focused on groups where the need and effect are greatest
- Helping to clarify the links between framework conditions and risk
- Following up to ensure that the players work together to further develop framework conditions that contribute to ensuring high HSE standards for all groups
The objective of this audit activity was to verify that:
- A functioning management system was established to ensure that risk factors for the mechanics group (Dolphin) and the cementers group (Halliburton) were identified, mapped and followed up so that working environment and personal safety were fully satisfactory
- Dolphin and Halliburton have assessed the importance of framework conditions for risk to mechanics and cementers
The audit was well-organised and we were met with openness and good will.
We also observed good follow-up of working environment factors in several areas.
Among other things, mapping of chemical exposure and area noise had been carried out for both groups. Several improvement measures in the area of working environment had also been implemented, such as:
- Measures to improve lighting
- Improved access to manifoil (cementers)
- Noise curtains in engine room and mud pump room
- Improvements as regards dust exposure for cementers
The audit identified one nonconformity in relation to the regulations:
- Deficient mapping and assessment of ergonomic factors, self-produced noise and vibration from handheld tools and overall noise exposure during the course of a shift
Four improvement items were identified:
- Training and information regarding working environment risk can be improved
- Measures and follow-up in the area of working environment can be improved
- There were weaknesses associated with chemical management
- Roles and responsibilities in relation to follow-up of working environment conditions were not clearly and uniformly defined.