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Audit of HSE management system - Floatel International

During the period 27-30 September 2010, the Petroleum Safety Authority Norway (PSA) carried out an audit of Floatel International AB's (FI) management system for health, safety and the environment (HSE). The audit activity was part of the processing of the application for an Acknowledgement of Compliance (AoC) for the living quarters installation Floatel Superior.

The audit was carried out through conversations and review of governing documents at the company's office in Gothenburg.

Floatel International has applied to the PSA for an AoC for Floatel Superior (FS). FS is a semi-submersible DP-class living quarters and construction facility. The facility was delivered by Keppel Fels in Singapore in March 2010. Floatel Superior will be operated by Floatel International with a project office in Norway and technical and administrative support from the main office in Gothenburg.

The audit of the company's management system was part of the processing of the AoC application.

The objective of the audit activity was to verify that the company's management systems have been established in accordance with regulatory requirements, e.g. as regards:

  • Ensuring competence, training and familiarisation
  • Identification and handling of nonconformities
  • Follow-up and investigation of incidents
  • Planning and conduct of internal audits
  • Working environment follow-up
  • Emergency preparedness
  • Preparation and establishment of operations organisation

The activity showed that Floatel International was in the process of completing necessary management systems for operation of Floatel Superior on the Norwegian shelf.

We identified 13 nonconformities and nine improvement items.

It is our opinion that the main cause of several of the findings identified during the audit, was deficient quality assurance of the compliance checks that have been carried out to evaluate the company's management system toward the petroleum regulations.

Nonconformities and improvement items
The identified nonconformities and improvement items can be divided into three main groups:

  • Ensuring competence, training and familiarisation
  • The company's systems for follow-up of working environment conditions
  • Emergency preparedness matters

Ensuring competence, training and familiarisation

• Establishment of competence requirements (Nonconformity)
Specific competence requirements had not been established for all relevant personnel.

• Training and familiarisation (Improvement item)
It was unclear whether sufficient internal training had been provided prior to start-up.

• Identification and handling of nonconformities (Nonconformity)
A system had not been established to safeguard regulatory requirements for identification and handling of nonconformities, including requirements for applications for exception from regulatory requirements. This deficiency in FI's management system had not been identified in the compliance checks vis-à-vis relevant sections of the regulations.

• Follow-up and investigation of incidents (Improvement item)
Deficient description of follow-up and investigation of incidents

• System for planning and conducting internal audits (Improvement item)
Nonconformities in relation to internal audit plans were not treated as internal nonconformities

The company's systems for follow-up of working environment conditions

• Lacking compliance checks toward applicable regulatory requirements (Nonconformity)
Compliance checks could not be produced that showed compliance between requirements in its own management system and requirements in certain incorporated regulations from the Norwegian Labour Inspection Authority that apply to the petroleum activities.

• Unclear requirements for working environment conditions (Nonconformity)
It was not specifically evident from the company's governing documents for operation of the facility which specific working environment requirements, suitable for mapping purposes and verification, that applied to the following working environment factors:

  • Emergency lighting
  • Chemical substances and employees' exposure to chemicals
  • Ergonomic requirements for information displayed on VDU screens and other display media to ensure good human-machine interaction in the control room, thus minimising the risk of human errors
  • Requirements for presentation of alarms
  • Psychosocial matters
  • Safety signage and signalling
  • Working environment conditions related to the factors “arrangements, ergonomics and technical appliances”, which are part of the company's working environment area charts (WEAC)

• Status as regards safeguarding working environment conditions in various rooms/areas on the facility (Nonconformity)
Clear documentation could not be presented to demonstrate accordance between the regulatory requirements for individual working environment factors and the applicable requirement basis. In particular, this concerned qualitative working environment conditions, cf. the working environment factors mentioned in the lower part of the WEAC form.

• Systems for management of chemical health hazards (Nonconformity)
Analyses could not be presented as regards the working environment in relation to the risk of hazardous chemical influences after the facility started operations.

• Preparation of procedures for handling chemicals (Nonconformity)
The existing procedures for handling chemicals were prepared according to another country's regulations. Compliance checks/procedure evaluations that ensure satisfaction of applicable regulatory requirements could not be produced.

• Noise exposure measurements (Nonconformity)
It could not be documented whether plans had been or would be carried out of 12-hour noise dose measurements for personnel groups working in areas with noise levels harmful to hearing.

• Working environment competence and company health service (BHT) (Nonconformity)
Sufficient expertise within health services and working environment could not be documented.

• Organisation of working environment committee (Nonconformity)
Governing documents did not exist that described the organisation (composition) of the joint local working environment committee (FSAMU) on Floatel Superior.

• Mapping of working environment conditions during the operations phase (Improvement item)
Governing documents did not exist that described how the mapping of working environment conditions will be organised and carried out when the facility has been in operation for some time.

• Safety inspections and HWES inspections (Improvement item)
Governing documents could not be presented that described how safety inspections and HWES inspections would be organised and carried out for running surveillance of the HSE conditions on the facility when it starts operations.

• Toolbox talks (Improvement item)
Governing documents could not be presented containing requirements for organisation and conduct of personnel toolbox talks on the facility when the facility starts operations.

• HSE and working environment program (Improvement item)
No HSE or working environment program had been prepared to describe the company's planned HSE activities when the facility starts operations.

Emergency preparedness matters

• Barriers (Improvement item)
There was deficient knowledge in the organization as to what constitutes a barrier.

• Incompatible work tasks (Improvement item)
Assessments had not been carried out to ensure that emergency team personnel do not receive incompatible work tasks.

• Training and drills (Nonconformity)
No distinction is made between training and drills, and the frequency of training and drills is not in accordance with the regulations.

• Action plans for defined hazard and accident situations (DFUs) (Nonconformity)
Action plans had not been established in the emergency response plan.

• Performance requirements for emergency preparedness on board (Nonconformity)
No enterprise-specific performance requirements for emergency preparedness (VSKTB) had been established on board.

Øyvind Midttun, Press contact
Email: oyvind.midttun@ptil.no | +47 51 87 34 77