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The lifeboat issue – notification of order to 22 operating companies and shipowners

Notice: The PSA has decided to issue a notification of order to a total of 22 operating companies and shipowners, requiring them to conduct a comprehensive evaluation of means of evacuation, and to establish an action plan aimed at rectifying potential deficiencies.

In a circular issued last summer, the PSA asked operating companies and shipowners to prioritise the work of dealing with the challenges posed by using lifeboats as a means of evacuation.

The players were asked to conduct evaluations on the basis of information available through the Norwegian Oil Industry Association's (OLF's) lifeboat projects, the consultation process for NORSOK R-002 and the Norwegian Shipowners' Association's (NSA's) project (NSA LSA).

After issuing the circular, the PSA has met with individual operating companies and drilling contractors. We have found significant variation in the work carried out by the players as regards evaluating the consequences of the results and information that has emerged in the OLF and NSA projects, and in NORSOK R-002.

Some players have conducted an evaluation and mapping of the problems associated with their means of evacuation. These players have been in contact with the PSA and have informed us about the challenges they have identified, and have presented action plans for rectifying deficiencies.

Based on the impression we have formed through our follow-up of the industry and the need for initiating potential measures, the PSA has decided to issue a notification of order to certain players, requiring them to implement a comprehensive evaluation and to establish an action plan to rectify any deficiencies.

The regulatory requirements (Section 68 of the Activities Regulations) states that it must be possible to quickly and efficiently evacuate personnel on facilities at all times, and furthermore that accessible means of evacuation are a central precondition for compliance with Section 8 of the Framework Regulations relating to prudent petroleum activities.

On this basis, we hereby issue notification of the following order:
”Pursuant to Section 68 of the Activities Regulations relating to handling of situations of hazard and accident, Section 8 of the Framework Regulations relating to prudent petroleum activities and Section 17 of the Framework Regulations relating to general requirements to material and information, cf. Section 58 of the Framework Regulations relating to individual decisions, the recipient of this letter is ordered:

1. Based on information from the project work in OLF and NSA, as well as Norsok R-002, to implement a documented comprehensive evaluation of the possibilities for evacuation from own facilities measured against regulatory requirements and in light of the information and knowledge that has emerged in the aforementioned projects. The deadline for complying with the order is set at 14 June 2010.

2. Establish a plan with dates outlining measures aimed at rectifying issues in Item 1 that are not in accordance with regulatory requirements. The deadline for complying with the order is set at 14 June 2010. The measures must ensure that the requirement of quick and efficient evacuation at all times and under all conditions has been safeguarded in a satisfactory manner.

The PSA must receive confirmation that a comprehensive evaluation has been carried out, and that an action plan with necessary compensating measures has been established so that the responsible party is in compliance with all regulatory requirements regarding evacuation before the next winter season.

Explanation of the terms "order" and "notification of order "
An order is an individual decision made pursuant to the regulations. Before we issue an order, we normally send a "notification of order" to the affected companies.

A notification of order is neither a policy instrument nor a warning of sanctions, but rather a step in a process subject to formal rules. The notification is merely a first step before an individual decision is issued.

An order is a powerful preventive policy instrument which has a binding legal impact on the recipient.