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AoC-Audit of Diamond Offshore

Diamond Offshore Drilling (UK) Lt. submitted an application for acknowledgement of compliance for Ocean Vanguard (photo). The Petroleum Safety Authority Norway performed an audit of Diamond Offshore management systems with selected verifications in the Aberdeen offices 24-26 February 2004.


The audit was executed by means of presentations by Diamond Offshore Drilling (DODI) and interviews and discussions with selected DODI onshore personnel plus verifications of typical documents with basis in the working environment-, drilling-, marine-, maintenance- and emergency preparedness disciplines.

Background for the audit

From 1.1.2004 (AoC) is a regulatory requirement for drilling units operating on the Norwegian Continental Shelf (NCS).

DODI bought the mobile offshore drilling unit Ocean Vanguard from Smedvig Offshore when the unit was named West Vanguard.

Smedvig got an AoC for West Vanguard in 2001 and it was in operation on the NCS until spring 2003. Later that year the unit was stacked in Scotland.

Based on the information from previous meetings with DODI and the ongoing modifications to start up operations on the UK Continental Shelf (UKCS) we chose to perform a system audit in the DODI offices rather than a number of discipline audits and verifications onboard the Ocean Vanguard.

Purpose of the audit

The AoC-audit goal was to verify that DODI has an established management system that is in accordance with requirements for activity on the NCS.

It should also verify that conformance/non-conformance/gap analysis of all the relevant regulations on the NCS has been performed and that such analysis can be documented.

In addition that nonconformances from the relevant regulations are identified and need for applying for exemptions are handled in accordance with internal systems and the Petroleum Safety Authority Norway's (PSA) requirements.

The audit team should verify that actions from previous meetings and deviation milestones are followed up and that relevant evaluations of relevant general letters to the industry have been adhered to and that required replies are given to the PSA.

On the basis of no major findings followed by quick replies from DODI our goal was to issue an AoC during the first quarter of 2004.

Result of the audit

The audit was held in an open atmosphere which helped us perform the audit according to plan.

The presentations by DODI given the first day of the audit gave us a very good start and insight into the Company's HSE management systems with special focus on the Global Excellence Management System (GEMS).

It is our impression that DODI has a well structured management system in GEMS where a lot of the company experience is incorporated with detailed check lists.

In addition it seems to be user friendly and functional for the office and rig personnel.

DODI as an AoC applicant is at all time responsible to ensure that systems and documents comply with relevant regulations for NCS.

A system for ensuring compliance, reporting non-compliances and issuing applications for exemptions from relevant authorities was not sufficiently in place.

DODI was not able to document the work performed to assess conformance between the relevant regulations applicable on the NCS and requirements incorporated in DODI's HSE management systems.

This must be presented in sufficient details prior to an issue of an AoC. This is also relevant for the evaluations of the Norwegian Maritime Directorate new regulations as of 1.1.2003.

The deviation list valid during the audit must be updated with a better description of each deviation and specific references to the relevant section in the regulation and the guidelines.

In addition specific closing dates must be included for each short term non-conformance.

Some nonconformances that have been indicated as closed out must be reopened based on our audit verifications. It is our impression that they were closed due to insufficient knowledge of the Norwegian regulatory system in the DODI organisation.

Regarding the working environment there are several items that must be solved prior to operation on the NCS.

This is especially related to establishing requirements for working environment factors, assessments, and plans for workforce participation, training and implementation of a safety delegate system on board the rig as well as implementing working environment committees according to Norwegian legislation.

The audit also revealed a need for adjustment and ciarification of the emergency preparedness organisation on the Ocean Vauguard compared with the regulatory requirements on the NCS.

Based on the audit findings and the management summary items listed above, the issue of an AoC to DODI for Ocean Vanguard will depend on the quality of DODI's answers to this report.

Contact person in the PSA:
Mike Theiss

The audit was held in an open atmosphere which helped us perform the audit according to plan.

The presentations by DODI given the first day of the audit gave us a very good start and insight into the Company's HSE management systems with special focus on the Global Excellence Management System (GEMS).

It is our impression that DODI has a well structured management system in GEMS where a lot of the company experience is incorporated with detailed check lists.

In addition it seems to be user friendly and functional for the office and rig personnel.

DODI as an AoC applicant is at all time responsible to ensure that systems and documents comply with relevant regulations for NCS.

A system for ensuring compliance, reporting non-compliances and issuing applications for exemptions from relevant authorities was not sufficiently in place.

DODI was not able to document the work performed to assess conformance between the relevant regulations applicable on the NCS and requirements incorporated in DODI's HSE management systems.

This must be presented in sufficient details prior to an issue of an AoC. This is also relevant for the evaluations of the Norwegian Maritime Directorate new regulations as of 1.1.2003.

The deviation list valid during the audit must be updated with a better description of each deviation and specific references to the relevant section in the regulation and the guidelines.

In addition specific closing dates must be included for each short term non-conformance.

Some nonconformances that have been indicated as closed out must be reopened based on our audit verifications. It is our impression that they were closed due to insufficient knowledge of the Norwegian regulatory system in the DODI organisation.

Regarding the working environment there are several items that must be solved prior to operation on the NCS.

This is especially related to establishing requirements for working environment factors, assessments, and plans for workforce participation, training and implementation of a safety delegate system on board the rig as well as implementing working environment committees according to Norwegian legislation.

The audit also revealed a need for adjustment and ciarification of the emergency preparedness organisation on the Ocean Vauguard compared with the regulatory requirements on the NCS.

Based on the audit findings and the management summary items listed above, the issue of an AoC to DODI for Ocean Vanguard will depend on the quality of DODI's answers to this report.

Contact person in the PSA:
Mike Theiss