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Notice of order following audit of Equinor Mongstad

The Petroleum Safety Authority Norway (PSA) has conducted an audit of Equinor Mongstad directed at the company’s management of the working environment for the insulation, scaffolding and surface treatment (ISS) trades. Several breaches of the regulations were identified, and the PSA has therefore given the company notice of an order.

Conducted from 23-25 May 2018, the audit of Equinor Mongstad had the following objectives:

  • assess whether management systems and practice at Equinor Mongstad and the ISS contractors concerning regular working environment surveys and follow-up of working environment risk met the requirements in the regulations
  • assess how Equinor Mongstad and the ISS contractors ensure that contract workers have a fully acceptable working environment
  • follow up that Equinor Mongstad, in collaboration with the contractors, ensures that operating parameters specified in the contract do not have negative consequences for health, safety and the environment (HSE)
  • assess how Equinor Mongstad and the contractors make provision for genuine worker participation.

Deficiencies were identified in Equinor Mongstad’s system for following up the working environment for ISS personnel. It had not sufficiently assessed and followed up factors which could be significant for risk in the work of these trades at the Mongstad facility north of Bergen.

The company had failed to follow up organisational and psychosocial working environment factors adequately in order to prevent negative HSE consequences attributable to the operating parameters. Surveys and incident follow-up by ISS contractor Beerenberg revealed that personnel in these trades felt that pressure to make progress had costs for HSE, and yielded negative findings on the reporting culture. The mapping was not requested or followed up by Equinor Mongstad. This therefore meant that no assessment was made either of whether negative findings related to the organisational working environment and safety climate could be understood in the light of the unit price compensation format or other operating parameters controlled by Equinor Mongstad.

Equinor Mongstad and Kaefer Energy had not followed up whether the working environment in certain areas and work operations was fully acceptable. That applied in part to sand/slurry blasting conducted in a noisy area which was also difficult to access. Nor were health checks carried out for personnel from Kaefer Energy or Global Work, who executed this work.

It emerged from the audit that an incident had occurred in May 2017 where surface treatment personnel from/under contract to Beerenberg were exposed to an unacceptable working environment. During sandblasting, a number of workers were subject to critically high temperatures. The work lasted seven days, without the risk being identified and followed up by Equinor Mongstad or Beerenberg. Equinor Mongstad had not classified the potential in the incident, but assessed the actual injury case as a serious temporary work-related illness. Given the information which emerged, the incident could have led to serious acute health damage and, in the worst case, life-threatening conditions. Equinor Mongstad’s classification could therefore have contributed to undercommunicating the true health risk.

The incident should have been notified to the PSA. This was not done.

Collaboration between the company medical services (CMSs) at the contractors and the Equinor Mongstad health and working environment department was inadequate. Nor did the CMSs at the contractors and their subcontractors collaborate. The Equinor Mongstad health and working environment department was therefore unaware of surveys conducted by a contractor.

An improvement point related to worker participation was identified in the audit. Safety delegates at the contractors could have been involved to a greater extent in the preventive and systematic HSE work. Certain safety delegates had not received the training required by law, and lacked an adequate understanding of their role.

Nonconformities and improvement point
Nonconformities from the regulations were observed by the PSA in the following areas:

  • management of the organisational and psychosocial working environment (5.1.1)
  • risk assessment of work operations (5.1.2)
  • inadequate risk assessment of the incident (5.1.3)
  • failure to notify the incident (5.1.4)
  • collaboration with CMSs (5.1.5).

Furthermore, the PSA observed an improvement point related to:

  • making provision for worker participation.

Notice of order
Based on its audit findings, the PSA has now given Equinor Mongstad notice of the following order.

Pursuant to section 18.6 of the Working Environment Act (WEA) on orders and other individual decisions and section 69 of the framework regulations on administrative decisions, see section 4.1, items (1) and (2) of the WEA on general requirements regarding the working environment, and sections 18 and 22 of the management regulations on working environment analysis and handling of nonconformities respectively, Equinor Mongstad is ordered to:

- conduct a systematic review of its systems for managing working environment risk at Equinor Mongstad in order to ensure that ISS personnel are not subject to unfortunate physical and mental stresses, and to ensure that safety considerations are taken care of, see nonconformities 5.1.1, 5.1.2 and 5.1.5

- develop a binding and scheduled plan for corrective measures, see nonconformities 5.1.1, 5.1.2 and 5.1.5, which identifies the prioritisation of these measures, with a description of possible compensatory measures to be adopted until the nonconformities are corrected.

The deadline for preparing the plan is set at 11 January 2019.

The report contains nonconformities other than those which form the basis for the notice of an order, and the PSA has asked Equinor Mongstad to explain no later than 2 November 2018 how these will be dealt with.

Where the nonconformities related to inadequate risk assessment of incidents and failure to notify incidents are concerned, Equinor has also been asked to investigate whether similar deficiencies in classifying and notifying incidents exist at other land-based plants.

The PSA has also requested the company’s assessment of the improvement point observed.

Explanation of the terms “order” and “notice of order”
An order is an administrative decision made pursuant to the regulations. Before the PSA issues an order, it generally sends a "notice of order" to the affected companies.

A notice of order is neither an instrument nor a notice of sanctions, but a step in the PSA’s administrative process in which it requests the party to assess the factual basis. The notice is only a first step before an administrative decision is made.

An order is a strongly preventive instrument which is legally binding on the recipient.

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