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Audit of ConocoPhillips and Subsea 7 regarding divers as a group at risk

The Petroleum Safety Authority Norway (PSA) has conducted an audit of ConocoPhillips and Subsea 7 linked to the follow-up of divers as a group at risk. The audit identified several items where there is room for improvement.

On 17 June 2009, the PSA conducted an audit of ConocoPhillips Scandinavia AS (ConocoPhillips) and diving contractor Subsea 7 regarding follow-up of divers as a group at risk. The audit was conducted in the form of a meeting with the companies and a review of requested documentation.

This audit is part of a larger, wide-ranging audit activity.

Based on experience gained in following up working environment and risk of personal injury in the petroleum activities, it seems clear to the PSA that there are different levels of risk among employee groups when it comes to work-related injury and illness.

Previous audit activities have shown that different framework conditions have an impact on how risk factors are handled, and that this in turn impacts the actual risk for the various groups.

Groups at risk (RUG) constituted one of the PSA's main priorities in 2007, 2008 and 2009. Audits of divers as a group at risk are part of this main priority in 2009.

The objective of the PSA's efforts in 2009 is as follows:

The PSA shall contribute to reducing the risk of injury and illness for particularly vulnerable groups by:

  • Following up to ensure that the companies further develop a comprehensive picture of the risk of illness and injury for groups of employees, and that new knowledge is used actively in a risk-based approach where efforts target groups where the need and effect are greatest
  • Contributing to clarify the connections between framework conditions and risk
  • Follow up to ensure that the players jointly develop framework conditions that contribute to ensuring HSE standards for all groups

In 2007 – 2008, the PSA conducted wide-ranging audit activities targeting seven operating companies and eight contractors. The audit was aimed at the companies' systematic work to develop a comprehensive picture of the risk for groups, as well as development of measures and cooperation between operating companies and contractors.

We were also concerned with ensuring that the companies assessed the significance of framework conditions such as work organisation, contracts and technology as regards risk.

One of the main conclusions of the PSA's audit activities in this area is that the position of contractor employee groups is considerably weaker than operator employee groups in relation to a number of elements in HSE management. It has emerged that framework conditions such as contractual conditions, financial conditions and work organisation can contribute to the contractor groups' poorer results.

The PSA hired Sintef (Technology and Society) in 2008 to clarify the concept of framework conditions, and to enhance understanding of the link between various framework conditions and risk. The report from this project is enclosed (Rosness, Blakstad og Forseth, 2009). Link to report (In norwegian only)

Diving contractors were not included in the audit activity in 2007-2008. Divers work under challenging working environment conditions. Therefore, the PSA wanted this group to be included in the work on groups at risk in 2009.

The regulatory basis for the audit activity is mainly:

  • Working Environment Act, Section 4-1 on satisfactory working environment based on an individual and overall assessment of factors in the working environment
  • Working Environment Act, Section 3.1 on requirements regarding systematic health, environment and safety work
  • Working Environment Act, Section 5-1 on recording of injuries and diseases
  • Working Environment Act, Section 4.6 on adaptation for employees with reduced capacity for work
  • Relevant regulations under the Working Environment Act, e.g Section 6 of the chemicals regulations on risk assessment
  • Framework Regulations, Section 9 on principles relating to risk reduction, Section 10 on organisation and competence, Section 11 on HSE culture and Section 14 on qualification and follow-up of other participants
  • Management Regulations, Section 1 on risk reduction, Section 11 on manning and competence, Section 17 on analysis of the working environment, Section 21 on follow-up and Section 22 on improvement
  • Activities Regulations, Section 4 on provision of medical examinations for employees, Sections 31-40 on arrangement of work and specific factors in the working environment and Section 41 on information on risk during conduct of work

Based on the above-mentioned regulatory requirements, an audit was conducted of ConocoPhillips' and the diving contractor Subsea 7's systematic work to follow up divers as a potential group at risk.

The companies were asked to document that a functioning management system had been established to ensure that risk factors for the divers are identified, mapped and followed up so that working environment and personnel safety aspects are fully satisfactory. We also wanted the companies to demonstrate that assessments have been made of the significance various framework conditions have on risk for the divers as a group.

In the meeting on 17 June 2009, we asked ConocoPhillips and Subsea7 to give a presentation emphasising the following factors:

a) Which surveys and assessments of working environment factors, individually and together (cf. Working Environment Act, Section 4- 1 on satisfactory working environment based on an individual and overall assessment of factors in the working environment) have been carried out for the divers group? Both risk of personal injury and illness shall be included in this assessment.

b) Overview of the incidence and assessment of work-related illness and injury in divers.

c) Account of the framework conditions the group works under, and an assessment of how these conditions can affect risk and how risk is handled. Important framework conditions for this group will be employment conditions and contractual conditions.

d) Overview of what is done to handle risk identified in relation to divers,

  • Prioritisation and implementation of measures based on working environment assessments and surveys
  • Verification from the company to ensure that measures are implemented and function as intended
  • Employee participation
  • Training and competence
  • Responsibilities and distribution of roles between operating company and contractor

e) An overview of the most important elements in the contract between ConocoPhillips and Subsea 7 that have a direct or indirect impact on the safety of personnel, both in a major accident perspective and an individual perspective. We also requested a brief description of factors that contribute to creating a common HSE understanding between the parties, other than what is described in the contract.

Through this audit, the PSA wanted to shed light on how ConocoPhillips and Subsea 7 assess and follow up the risk of work-related illness and injury for divers, and how they link framework conditions to risk.

The PSA also wanted the audit to contribute to increase the level of knowledge about groups at risk so that it can target risk-reducing measures where the need and effect are greatest.

The following improvement items were identified:

  • ConocoPhillips and Subsea 7 could not produce an overall assessment of factors in the working environment based on working environment surveys on board DSV Seven Pelican. No assessments were made of potential connections between various exposures to working environment factors or to a comprehensive assessment of risk factors for illness and personal injury for the divers group.
  • No noise exposure measurements have been implemented for diving work in the sea.
  • There was little use of information from the expanded health examinations (three-year annual health follow-up) in connection with prevention of work-related illness and injury.
  • No systems or routines have been established to make adaptations for divers who have suffered reduced capacity to work/work-related illness so that they can continue to work as divers. Nor were routines established to follow up sick leave on the part of divers.
  • Subsea 7 and ConocoPhillips have not made systematic assessments of the consequences of employment conditions for following up personnel on sick leave, adaptation for persons with reduced work capacity and for access to information about health damage. Nor has consideration been given to whether measures can be implemented to compensate for potential negative consequences of employment factors.

Other observations:

Experience from previous audits of groups at risk where ConocoPhillips participated were not known, and experiences gained from such audits were therefore not utilised.

Representatives from Subsea 7 pointed out that the incentives in the contract with ConocoPhillips are more preventive than is the case for certain other operating companies (for example as regards the status of maintenance, equipment quality, etc.). The companies believe that this has a positive effect on health, safety and environment for the divers. They also state that it is positive that Subsea 7 participates in drawing up the incentives in the contract.