This supervision activity was conducted in accordance with the PSA’s procedure for performing audits. The choice of method is defined as an audit, and is a combination of different elements, such as review of documents, interviews, inspections, meetings/presentations and verifications. Observations were also made during meetings, drills and exercises.
The audit was implemented starting with a safety tour on board the facility. Afterward, a start-up meeting was held. Participants at this meeting were management personnel on board and on land (participating via video conference) and also representatives from the safety delegate service.
Subsequently, interviews were conducted with personnel with emergency response functions and the safety delegate service. The audit team also observed the execution of an emergency preparedness drill involving the entire emergency preparedness organisation on the facility. The audit team also observed a demonstration of an MOB boat (man over board) launch. An inspection was conducted on the facility.
Limited verifications were also conducted of competence summaries for personnel with emergency preparedness functions and documents relating to drills and exercises were reviewed. Finally, a summary meeting was held where the audit team presented its observations. It was pointed out that these were temporary in nature and that the final feedback would be presented in a formal audit report following the audit.
The audit activity was facilitated by Statoil, and the involved personnel contributed in a constructive and positive manner.
The audit activity was directed toward the emergency preparedness discipline and was mainly based on the petroleum regulations, including “Regulations relating to conduct of activities in the petroleum activities (the Activities Regulations) Chapter VI-II Competence and XI Emergency preparedness and the Regulations relating to design and outfitting of facilities etc. in the petroleum activities (the Facilities Regulations) Chapter III-IV Emergency preparedness”.
The purpose was to verify that work on the facility is in accordance with regulatory requirements, and also with Statoil’s own internal requirements.
The audit activity’s goal was to verify that the level of emergency preparedness on the Norne production facility was in accordance with regulatory requirements and Statoil’s own governing documents.
The following aspects were emphasised during the audit:
The audit activity was conducted according to the arranged plan. The general impression is that emergency preparedness is well maintained at Norne FPSO. The emergency preparedness organisation seemed robust.
Still, there is need for some improvement of technical and operational circumstances to better safeguard emergency preparedness and regulatory compliance.
We have comments on the following elements:
Three regulatory non-conformities and three improvement items were identified.
The PSA’s observations generally fall into one of two categories:
Deficiencies in safety signage and labelling: Labelling of the marked escape route leading to fire fighting, rescue and/or evacuation equipment was deficient.
This caused the safety signage to be complicated for those who are not familiar with the facility.
During the inspection at Norne, we observed that there was deficient labelling in the interior stairwell in the living quarters as to which rescue/evacuation devices personnel are being led to. In the exterior stairwell from the living quarters where the escape route led to the lifeboats, there was potential for improving visibility of the signage, and also labelling what personnel are being led to. The emergency signage should more often have been supplemented with additional signs and/or information signs which would illustrate, for example, a helicopter, a muster station, a lifeboat or an escape chute.
This was observed in both the exterior and interior areas. When requested, a plan could not be provided for the placement and improvement of safety signage and labelling on board the facility.
PA messages in the living quarters were not audible in all cabins: While reviewing technical safety condition, it became evident that it was not possible to communicate continuously during operations, and in hazard and accident situations, to some of the cabins. Following cabin renovation, it is not possible to communicate with the PA system to all the cabins.
During interviews, it was found that there is a separate waking team to compensate for not being able to continuously sound warnings in the cabins not covered by the PA system. During the requested technical safety condition review at the start-up meeting, it was pointed out that a non-conformity had been identified separately in this area, but permanent measures had not yet been taken.
The emergency preparedness plan was not in agreement with the preparedness plans (station bills) posted on the walls of the facility: The emergency preparedness plan “Emergency preparedness on the Norwegian shelf – Norne Production Facility” could not describe current preparedness on the facility. Cabin keys for several cabins showed the wrong lifeboat.
The alarm instructions in the emergency preparedness plan at Norne were not in agreement with the posted station bills on board, which indicated that the lifeboat assignment is listed on the bunk assignment note. This was also pointed out during the safety tour on board.
The alarm instructions in the emergency preparedness plan stated that your lifeboat assignment is indicated on the key chain on your cabin key. Therefore, there was no agreement between lifeboat references on the keychain and references on the bunk note. This can cause confusion as to which lifeboat you should evacuate to if a dangerous or accident situation should occur.
Unclear overview of Defined Hazard and Accident (DFU) situations:
There were three different versions of the DFU overview, which can lead to misunderstandings during immediate notification of dangerous or hazardous situations.
The DFUs described in the preparedness plan “Emergency preparedness on the Norwegian shelf – Norne Production Facility” (page 17) were not in agreement with the DFU overview used for drills and training on the facility. These two DFU lists were also not in agreement with the order of the DFU overview in “Area emergency preparedness plan Region 4 Area A Operations North”.
This was observed during execution of the drill on board, and we could also read it when comparing DFU training documentation with the DFU overview in the preparedness plan and the area emergency preparedness plan.
Deficient knowledge of ICT security guidelines on board: Deficient safeguarding of competence, knowledge of and familiarity with ICT security guidelines on board. It was also unclear who has the dedicated responsibility for following up ICT security on Norne.
During interviews with management and response personnel on board, we learned that very few of the crew were familiar with guidelines and requirements for ensuring security during use of ICT equipment on board. ICT security was also not a topic during the introduction round (safety tour) upon arrival at Norne. Neither was there a description of guidelines for ICT security in Norne’s personal HSE manual.
Deficient knowledge of area resources among the crew: Deficient safeguarding of competence, knowledge of and familiarity with the area emergency preparedness resources connected to Norne FPSO.
During interviews with response personnel, we learned that the knowledge of area resources was somewhat lacking, especially knowledge of the use of the area emergency preparedness vessel Stril Poseidon as the primary and secondary resource for combating relevant DFUs seemed somewhat deficient.
The audit team observed an emergency preparedness drill on board, where the crew practiced on handling a hydrocarbon leak.
This was commented on during the evaluation meeting following the drill and in the final debriefing session on board.