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Notification of order following audit of follow-up of groups at risk on Eldfisk

Audit: During the period from 27 November to 3 December 2009, the Petroleum Safety Authority Norway (PSA) carried out an audit of ConocoPhillips Scandinavia AS (CoPSAS) and the contractors Fabricom AS (Fabricom) and the IKM Group AS (IKM) and their identification and follow-up of groups potentially at risk on Eldfisk.


The audit was carried out by means of a start-up meeting on land on  27 November 2009 with CoPSAS, Fabricom and IKM, as well as verification on Eldfisk from 1 to 3 December 2009.

Eldfisk Complex

Eldfisk (source: CoPSAS)

We have assessed how the companies' system for managing the working environment safeguards follow-up of groups particularly at risk.

CoPSAS was assessed in relation to their supervisory responsibility and facilitation of conditions for the relevant contractor employees on Eldfisk. The company's follow-up of own groups potentially at risk was therefore not assessed. Fabricom and IKM were assessed in relation to follow-up of own employees.

The companies were to demonstrate to the PSA that a functioning management system had been established which had ensured that risks for groups of employees were identified, mapped and followed up so that working environment and personal safety issues were fully safeguarded in all parts of the contract chain.

Special focus was placed on how CoPSAS, Fabricom and IKM assessed the significance of the framework conditions for risk for contractor employees. In this context, framework conditions means, for example contractual issues and division of responsibility between the operator, contractor and subcontractor.

Background for the audit
This audit is part of the PSA's main priorities for 2009: Groups at risk.

This has also been one of the PSA's main priorities in 2007 and 2008.

From 2007 to 2008, the PSA carried out  an inter-company audit of seven operators and eight contractors under contract.

The audit was aimed at the companies' systematic work to develop a comprehensive picture of groups at risk, the development of measures and cooperation between operator and contractor in this work.

Purpose of the audit
The purpose of the PSA's focus in 2009 is that the PSA shall contribute to reducing risk of injury and illness for groups that are exposed to particular risk by:

  • Following up that the companies will further develop a comprehensive picture of risk of illness and injury for groups of employees, and that new knowledge will be actively used in a risk-based approach where focus is on groups where the need and effect are the greatest
  • Contributing to clarify connections between framework conditions and risk
  • Following up that the players jointly further develop framework conditions which contribute to ensure high HSE standards for all groups.

Result of the audit
CoPSAS has shown insufficient exercise of its supervisory duty as regards follow-up of working environment conditions for contractors.

CoPSAS is responsible for ensuring that working environment conditions for contractors are mapped and risk-assessed.

We observed that several good measures and processes in the HSE field had been initiated, but identified the following nonconformities in relation to the regulatory requirements:

  • Systematic mapping and risk assessments of working environment conditions for IKM's testing operators had not been carried out.
  • IKM's testing operators have not received systematic training in assessing which risks relate to work they perform.
  • Systematic mapping and risk assessments of working environment conditions for Fabricom operators had not been carried out.
  • CoPSAS has shown insufficient exercise of its supervisory duty as regards follow-up of working environment conditions for contractors. CoPSAS is responsible for ensuring that working environment conditions for contractors are mapped and risk-assessed.

Furthermore, six potential improvement items related to the following areas were identified:

  • Use of HSE coordinator's working environment competence
  • Insufficient access to suitable protective gear

On the basis of our findings during the audit, we have issued the following notification of order to COPSAS:

Pursuant to Section 17 of the Management Regulations relating to analyses of the working environment, Section 4-1 subsection 1 of the Working Environment Act (AML) relating to requirements for individual and overall assessment of factors in the working environment which can impact the employees’ physical and mental health and welfare, cf. Section 5 of the Framework Regulations  relating to responsibility, first and second subsection and Section 58 relating to administrative decision order ConocoPhillips to:

  • Assess the systems which shall ensure follow-up of working environment conditions for contractors who work on ConocoPhillips' facilities (cf. the report's items 5.1.1 and 5.1.2), including ensuring that IKM Testing and Fabricom submit binding plans with set deadlines for risk-reducing measures, including training for their contractors.
  • Ensure that necessary measures for ensuring that working environment conditions are followed up according to the regulations are carried out. This includes making sure that mapping and risk assessment of working environment conditions for contractor groups are carried out – cf. the report's item 5.1.4. is carried out.

The deadline for complying with the order is set at 1 May 2010. We must be notified when the order has been carried out.

We have asked CoPSAS for any comments regarding the notification by  31 January 2010.

We have issued the following notification of order to Fabricom :

Pursuant to Section 17 of the Management Regulations relating to analysis of the working environment, Section 4-1 subsection 1 of the Working Environment Act (AML) relating to requirements for individual and overall assessment of factors in the working environment which impact the employees' physical and mental health and welfare, cf. Section 5 of the Framework Regulations relating to responsibility, first subsection and Section 58 relating to individual decisions, Fabricom is ordered to consider the systems which are to ensure follow-up of working environment conditions for their employees who work on ConocoPhillips facilities (cf. the report's items 5.1.1 and 5.1.2) and carry out necessary measures for ensuring that working environment conditions are followed up according to the regulatory requirements.

The following elements must be included:

  • Mapping and risk assessments of working environment conditions – cf. the report’s item 5.1.1
  • Training within relevant working environment risk – cf. the report's item 5.1.2
  • Binding plan for implementation of risk-reducing measures

The deadline for complying with the order is set at 1 May 2010. We must be notified when the order has been carried out.

We have asked Fabricom for any comments regarding the notification by  31 January 2010

We have issued the following notification of order to IKM:

Pursuant to Section 17 of the Management Regulations relating to analysis of the working environment, Section 4-1 subsection 1 of the Working Environment Act (AML) relating to requirements for individual and overall assessments of factors in the working environment which can impact the employees' physical and mental health and welfare, Section 20 of the Activities Regulations relating to training in safety and working environment and Section 41 relating to information on risk during conduct of work, Section 11 of the Management Regulations  11 relating to manning and competence, cf. Section 5 of the Framework Regulations relating to responsibility, first subsection and Section 58 relating to individual decisions, IKM Testing is ordered to assess the systems which are to safeguard follow-up of working environment conditions for their employees who work on ConocoPhillips' facilities (cf. the report's items 5.1.1 and 5.1.2) and carry out necessary measures to ensure that working environment conditions are follow up according to the regulations.

The following elements must be included:

  • Mapping and risk assessments of working environment conditions – cf. the report’s item 5.1.1
  • Training within relevant working environment risk – cf. the report's item 5.1.2
  • Binding plan for implementation of risk-reducing measures

The deadline for complying with the order is set at 1 May 2010. We must be notified when the order has been carried out.

We have asked IKM for any comments regarding the notification by 31 January 2010.

About “orders” vs. “notification of order":
An order is a administrative decision made pursuant to the regulations. Before we issue an order, we usually submit a "notification of order" to the companies involved.

A notification of order is neither a measure nor a warning of sanctions, but part of our administrative process in accordance with the established rules of procedure. The notification is just a first step before an administrative decision is made.

Journal 2009/972 (documents in Norwegian)

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