The activity was conducted as interviews with personnel on board in combination with verification of documentation and technical solutions in the relevant areas.
Background for the audit
Rowan Drilling operates three jack-up drilling facilities on the UK continental shelf, but has no activities on the Norwegian shelf. The company has applied for an Acknowledgement of Compliance (AoC) from the PSA for the drilling facility Rowan Gorilla VI, based on a contract entered into with BG Norge for activities on the Norwegian shelf. This audit activity is part of the PSA's administrative processing of the AoC application.
Rowan Gorilla VI was delivered from an engineering workshop in the USA in 2001. The facility is registered in the US and follows USA flag state regulations. The facility holds a classification certificate from the American Bureau of Shipping (ABS) and Det Norske Veritas (DNV).
Purpose of the audit
The objective of the audit was to verify that aspects related to the company's maintenance management take place in compliance with the requirements of the activities regulations as stated in the application. Furthermore, the objective was to verify that technical and operational factors were in accordance with the shelf regulations for the systems concerned.
Result of the audit
During the audit it was noted that there was inadequate understanding of risk/safety among leading personnel on the facility. Knowledge of the Norwegian shelf regulations and the AoC arrangement was deficient, and the personnel on board had not participated in the compliance assessments that had been conducted in the respective areas.
As regards maintenance management, a number of new non-conformities were identified related to lack of testing and maintenance of safety-critical equipment and systems. The verifications and compliance assessments are inadequate and no maintenance management system has been established with procedures that fulfil the authorities' maintenance requirements.
In connection with the PSA's audit activity at Rowan's offices in Aberdeen on 13-15 November 2007, a non-conformity was identified as regards lack of a maintenance management system in Rowan's governing management system. This was communicated in the PSA's audit report of 12 December 2007.
This matter had still not been corrected when the audit on board took place. In addition, a lack of underlying procedures was identified in the company's maintenance system. Non-conformities and deficiencies were identified on safety-critical equipment such as lack of tagging of equipment, planned maintenance backlog, missing certificates and lack of testing of safety equipment such as fire and gas detectors, fire-fighting equipment and emergency shut-down systems.
For fire-fighting systems, gas detection and emergency shut-down, a number of new non-conformities were identified with respect to the applicable technical requirements. Some areas with fire hazards lacked fire-fighting equipment. The PSA found that the emergency shut-down system, the ventilation system and other systems that are important safety systems for handling abnormal situations, not only had technical deficiencies, but also lacked operational procedures or instructions.
During the verification on board, lack of good housekeeping and cleanliness were noted in some areas. In some areas, escape routes were partially blocked by hoses and other equipment.
This activity demonstrates inadequate quality of the compliance assessments that constitute the basis for Rowan Drilling's AoC application.