Such over-exposure may occur because knowledge of health and injury risk fails to be applied,workers are not properly followed up for risk, or training fails to protect them.
“That’s an extreme way of putting the case, but it’s the core of our commitment in recent years to groups particularly exposed to risk,” says Olaf Thuestad, director for regulatory development at the PSA.
“We want to help the whole industry to learn more about the risks of occupational ill-health and injury for different groups, and to get better at taking action where it’s really needed.
“In our view, sharing knowledge across the industry and an active involvement by companies, unions and government will be important in achieving results.”
The PSA has built up a substantial database in this area, and has conducted a number of audits focused on the issue.
“We haven’t wanted to label particular groups, but have highlighted the characteristics of workers whom we believe could be particularly exposed,” Mr Thuestad explains.
“The strongest common denominator is that they’re found at contractor and subcontractor levels. Another sign of the seriousness of the position is that these groups face several risk factors and greater exposure in their working environment.”
PSA audits and data from its trends in risk level in the petroleum activity (RNNP) study reveal substantial differences in leader awareness and the quality of risk management in the companies.
A general assessment is that an important dividing line runs between operators and contractors, with risk management tending to become weaker down the contractual chain.
But this picture is not unambiguous, and honourable exceptions can be found. Weaknesses identified by the PSA in contractor systems for preventing illness and injury include:
These conclusions rest on data from many years of work on the annual RNNP study, audit experience and company self-assessments for about 20 different categories of worker.
In addition, the PSA has commissioned surveys and risk assessments covering access technicians and insulation specialists in order to expand the factual basis for its assessments.
Risk factors which had not been handled in a satisfactory manner were identified for both these groups of workers.
A combination of high risk exposure, weaknesses in systematic follow-up by contractors, and deficiencies in operator organization of work for large groups of contractor personnel forms the basis for giving priority to this issue at the PSA.
Responsibility for ensuring a fully acceptable working environment for all employee categories and individual workers might be thought to rest with the employer.
So says the Norwegian Working Environment Act. But things are not quite that simple in the petroleum business, where operators have both compliance and principal enterprise responsibility.
They are accordingly required to check that contractors are qualified for their work and that they comply with their obligations.
Operators must also ensure an integrated approach to meeting HSE commitments, and are responsible as owner for seeing that installations or plants meet all technical working environment standards.
“We see a lack of clarity in the division of roles and responsibilities between operators and contractors concerning work on groups particularly exposed to risk,” says Irene Dahle.
A principal engineer with the PSA, she is project manager for its commitment in this area.
“Better coordination between operator and contractor is necessary to ensure that the needs of individual groups are not neglected.”
Important frame conditions for a contractor’s HSE efforts are determined through the terms of their contracts, which often specify a general requirement to comply with the regulations.
“The challenge lies in the way the operator facilitates compliance and monitors that the contractor is actually observing these conditions,” says Ms Dahle.
“One area where this can be seen with particular clarity is the contractor’s responsibility to conduct surveys and risk assessments for its own worker groups.”
The PSA issued two notifications of orders in 2009 relating to inadequate identification of risk for contractor personnel. These were followed by orders this January.
But contracts represent only one of many instruments available to an operator in fulfilling its duty to verify compliance by contractors and discharging its responsibility towards them.
“In practice, long-term contractual relations are often more important for HSE work than the terms of a specific contract,” says economist and principal engineer Gunnar Dybvig, who has headed work at the PSA on HSE in contracts.
“Such long-standing ties can provide a better basis for establishing shared goals and thereby a common commitment to investing in and collaborating over improvements.”
In some cases, however, it is questionable whether a contract provides sufficient incentives to improve. A lump sum deal, for instance, could put greater pressure on HSE while one based on hourly rates provides more room for systematic work in this area.
“That said, we’ve seen growing attention being paid by the industry to the significance of contracts and other frame conditions,” says Mr Dybvig.
“A range of improvements have been adopted. These include reducing the number of links in the contractual chain to ensure closer follow-up of and simpler communication about risk.”