Background for the audit
The PSA is to set standards for, and follow up to ensure that the players in the petroleum activities maintain high standards as regards health, safety and the environment, thereby contributing towards creating the greatest possible values for the Norwegian society.
The follow-up shall be system-oriented and risk-based, and shall be supplementary to the industry's own follow-up.
Storting White Paper No. 7 (2001-2002) relating to health, safety and environment in the petroleum activities, Chapter 4.12.2 stipulates i.e. the following regarding maintenance management:
"The authorities are of the opinion that it is necessary to further develop management models for operations and maintenance in cooperation with the industry in order to ensure a joint effort to strengthen the quality of maintenance in the petroleum activities through, inter alia, development of methods and technologies, competence enhancement and research."
Storting White Paper No. 12 (2005-2006) relating to health, safety and the environment in the petroleum activities indicates in Chapter 5.4 that deficient maintenance may increase the risk of major accidents, injuries and incidents, and the White Paper refers to a comprehensive review of audit reports which shows a relatively large share of non-conformities from the regulatory requirements.
These include deficiencies in the prioritising of maintenance, evaluation of critical conditions, follow-up of temporary equipment, unsatisfactory documentation and outstanding maintenance of safety-critical equipment. Moreover, the competence relating to maintenance management was, in some cases, inadequate.
Current requirements relating to maintenance management are stipulated specifically in the Activities Regulations and the Management Regulations.
Purpose of the audit
The purpose of the audit was to
Result of the audit
The results are based on the presentations of elements in Schlumberger's management systems and interviews with selected personnel, primarily the owners of the maintenance process, with subsequent verification of governing documents and systems for conducting maintenance on the company's facilities in Norway.
Schlumberger does not satisfy the regulatory requirements for maintenance management.
Our observations are characterised as nonconformities, cf. the classification in Chapter 5, and are grouped in the following main categories:
We have issued the following notification of order to Schlumberger:
Pursuant to Section 58 of the Framework Regulations relating to individual decisions, cf. Section 11 of the Management Regulations relating to manning and competence, cf. Section 19 of the Activities Regulations relating to competence, Schlumberger Norge AS is ordered to prepare a binding and scheduled plan for ensuring that the company has the necessary regulatory competence, cf. the report, nonconformity 5.1.1.
Pursuant to Section 58 of the Framework Regulations relating to individual decisions, cf. Section 3 of the Management Regulations relating to management of health, environment and safety, cf. Section 18 of the Activities Regulations relating to start-up and operation of facilities, cf. Chapter IX, Sections 43-46 of the Activities Regulations relating to maintenance, Schlumberger Norge AS is ordered to prepare a binding and scheduled plan for ensuring the preparation of governing documents which ensure and document that maintenance management takes place in a prudent manner, cf. the report, nonconformity 5.1.2.
Pursuant to Section 58 of the Framework Regulations relating to individual decisions, cf. Chapter IX, Sections 43-46 of the Activities Regulations relating to maintenance, cf. Section 13 of the Management Regulations relating to general requirements to analyses, cf. Section 9 of the Facilities Regulations relating to facilities, systems and equipment (marking), cf. Section 23 of the Activities Regulations relating to the use of facilities, Schlumberger Norge AS is ordered to prepare a binding and scheduled plan for ensuring that necessary maintenance is carried out, including marking and classification, preparation of maintenance programs and measurement of maintenance efficiency, cf. the report, nonconformities 5.1.3 through 5.1.7.
The deadline for complying with the order is set at 23 April 2010. We must be notified when the order has been complied with.
We have asked Schlumberger to notify us of any comments by 30 March 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 2010/96 (documents in Norwegian)
Øyvind Midtun, e-mail: Oyvind.Midttun@ptil.no
tel. +47 945 06 203