The risk of health hazards in connection with noise exposure has been monitored for several years as a part of the Trends in risk level in the petroleum activities (RNNP). The development has not been satisfactory.
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In its work on the RNNP reports, the Safety Forum has emphasised the large number of noise damages and deficient noise follow-up as a highly prioritised commitment area for the industry.
In connection with the audit activity, the PSA has prepared and presented data from the RNNP regarding Statoil in general and Statfjord specifically.
The PSA’s work on groups exposed to risk also indicates the risk of noise damage and focuses on the particularly high risk for contractor groups and their use of hand-held tools. Hearing protection together with work time limitations are the only risk-reducing measures. Personal protection equipment is a weak barrier where the actual protection effect is associated with considerable uncertainty.
In general, extensive documentation exists based on mappings and risk assessments, but few technical measures are planned and implemented to reduce the risk of noise-related injuries. For the contractor groups, the use of hand tools is an important source of noise exposure, which is covered to a lesser degree by risk assessments.
Through the audit activity, the PSA will collect sufficient information concerning Statoil’s management of the noise issue on Statfjord to assess compliance with regulatory requirements. The PSA will focus in particular on the company’s measures to reduce the risk of noise damage.
The audit was well facilitated and we were met with openness and goodwill. Informative presentations were given by Statoil as well as involved contractor companies.
The following non-conformities were identified during the audit:
- Deficient mapping and risk assessments of noise exposure
- Employee groups are exposed to noise levels that are hazardous to hearing
- Non-conformance procedures not established
- Deficient plans for implementing risk-reducing measures
Deficient mapping and risk assessments of noise exposure
Statoil had not performed adequate mapping and risk assessments of hazardous noise levels for exposed employee groups on the Statfjord facilities.
- In the received information from the company, including information presented during the audit activity, it became evident that Statoil had not performed qualified risk assessments of employee groups exposed to noise. This leads to a weak decision basis for risk-reducing measures.
- Statoil based its risk assessment of noise on area maps and estimated work times in different areas. Detailed risk assessments of noise exposure had not been performed. The risk assessment was not verified by other methods, e.g. noise dose metrics, to take into account inter factors such as self-produced noise.
- Noise maps for the facilities had not been updated and do not necessarily reflect the current noise level. It was unclear when the noise maps will be updated.
- It was unclear to what degree modifications in connection with Statfjord late phase lead to reduced noise exposure.
- From the information presented during the audit activity, it emerged that the use of hearing protection and reduced work times are used as primary measures to combat hazardous noise exposure. The effect of this protection regime in unclear, as there are few areas employees can work in close to the maximum noise dose. A system could not be documented to ensure prudent noise doses when taking into account self-produced noise and there is a risk of exceeding the noise dose. Exceptions in work time limitations have been made for some groups with high noise exposure.
- Statoil had performed few noise exposure metrics measurements and measurements of impulse noise. It also became evident during the audit meeting that, to a large degree, detailed data on exposure time is lacking.
Employee groups are exposed to hazardous noise levels
Several employee groups have higher noise exposure than requirements stipulated in regulations and personal protection equipment is used as a primary risk-reducing measure without Statoil being able to document that it has assessed the noise reduction potential through technical and other collective measures.
- Statoil’s calculation of noise exposure following a simple method indicates that several groups could be exposed to noise levels higher than stipulated in the regulatory requirements of 83dB(A) during a 12-hour work day.
- Noise values from noise maps presented by Statoil compared with estimated work times for personnel groups indicate that groups can be exposed to hazardous noise levels.
- Statfjord has reported a large number of employees with hearing loss.
- The main contributors to noise damage risk do not seem to be systematically identified. The decision basis for selecting risk-reducing measures is thus inadequate.
- Statoil could not explain a process where technical noise reduction measures is systematically assessed and documented with the aim of reducing the risk of noise-related hearing damage.
- Through presentations, it became evident that Statoil’s risk-reducing measures were mainly the use of hearing protection together with work time restrictions. This is not in accordance with regulatory requirements regarding risk-reducing measures.
Non-conformance procedures not established
Statoil had not registered or followed up regulatory non-conformities or internal requirements for handling noise conditions on Statfjord.
- The Statfjord noise map showed that several areas exceed Statoil’s internal requirements for area noise stipulated in WR1146.
- Through the received information from the company, including the presentation given during the audit meeting, it emerged that Statoil had not processed non-conformities related to internal requirements in WR1146 and regulatory requirements for noise. Non-conformities are not registered and thus not individually or collectively followed up.
- During the meeting, Statoil could not demonstrate familiarity with relevant regulatory requirements for area noise for Statfjord.
- During the meeting it became evident that Statoil’s data on noise exposure for relevant groups was deficient.
- During the meeting, Statoil could not demonstrate that it has an overview of potential new noise contributions in areas modified after 1 August 1995.
- The choice of risk-reducing measures to prevent hazardous noise exposure was not made in accordance with regulatory requirements, cf. 5.1.2.
Deficient plans for implementing risk-reducing measures
Statoil could not produce plans with deadlines for implementing risk-reducing technical measures to combat noise on the Statfjord facilities.
- Through the information received from the company, including the presentation given during the audit meeting, it became evident that Statoil had not established risk-based measure plans with deadlines to reduce the risk of noise damage on Statfjord.
- During the meeting, we confirmed that a risk-based prioritisation had not been performed of measures to reduce noise in the respective areas on the facilities.
- It became evident during the meeting that the work had been postponed due to that fact that line management has been awaiting contributions from the recently established “noise project for UPN”.
With a basis in the non-conformities identified during the audit, the following notification of order has been issued to Statoil:
Pursuant to Section 17 of the Management Regulations relating to working environment analyses, Section 20 relating to non-conformance procedures and Section 22 relating to improvement, cf. Section 58 of the Framework Regulations relating to individual decisions, Statoil Petroleum AS is ordered to:
- review its system for managing the risk of noise damage for the Statfjord facilities and implement the necessary measures to comply with regulatory requirements. This work shall include:
- performing necessary assessments of the risk of noise damage for exposed employee groups, cf. item 5.1.1 of the report
- performing non-conformance procedures in connection with requirements for handling noise, cf. item 5.1.3 of the report
- develop plans with deadlines for risk-based corrective measures in connection with the risk of noise damage, cf. items 5.1.2 and 5.1.4 of the report
The deadline for complying with this order is set at 1 October 2010. The PSA must be notified when compliance with the order has been carried out.
Order and notification of order
An order is a administrative decision made pursuant to the regulations.
Before the PSA makes an order, it usually issues a notification of order to the companies concerned.
A notification of order is neither a measure nor a warning of sanctions, but part of the PSA’s administrative process as specified in its established procedural rules.
The notification is merely a first step before an administrative decision is made.