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Audit of management of working environment and wages and working conditions for foreign employees

Audit: From 6-8 October 2008, the Petroleum Safety Authority Norway (PSA) conducted an audit of StatoilHydro (SH) and selected contractors relating to management of working environment conditions and follow-up of wages and working conditions for foreign employees at Mongstad.


Interviews were conducted, documents reviewed and verifications made during the audit.

Mongstad (source: StatoilHydro)

Background for the audit
The PSA has conducted several audits specifically directed towards the working environment on land facilities after authority responsibility was transferred from the Labour Inspectorate to the PSA in 2004.

The background for these audits has been to gain insight into and an overview of working environment challenges and the players’ ability to manage working environment conditions. Identification and follow-up of employee groups exposed to risk are one of five main commitment areas for the PSA in 2008.

In the audit at Mongstad we looked at how groups of employees exposed to particular risks are identified and followed up as part of the systematic follow-up of the working environment.

We viewed foreign employees at Mongstad as a group potentially exposed to risk and therefore wanted to see how SH and contractors ensured that HSE conditions and wage conditions for foreign employees were in line with the regulatory requirements. Cooperation and distribution of responsibility with contractors and subcontractors was deemed to be part of the audit.

The audit was based on the following statutes and regulations:

  • The Working Environment Act and underlying regulations in the working environment area.
  • FOR-1996-12-06-1127. Regulations relating to systematic health, safety and environment work in enterprises (Internal Control Regulations).
  • FOR 2003-12-19 no 1595: Preliminary regulations relating to safety and working environment for certain petroleum facilities on land and associated pipeline systems.
  • LOV 1993-06-04 no 58:Act relating to general application of wage agreements, etc.
  • Regulations relating to information duty, duty to ensure and right of inspection of 22 February 2008 No. 166, Section 6.
  • Regulations relating to general application of wage agreements for construction sites in Norway of 21 November 2006 No. 1291.
  • Regulations relating to general application of wage agreements for certain petroleum facilities on land of 26 June 2006 No. 703.

Purpose of the audit
The purpose of the audit was to verify systems and practice for follow-up of the working environment at the facility. We wanted to look at how SH, through its system for management of the working environment, identifies and follows up groups in relation to the risks they are exposed to in the working environment.

We also looked at how SH and the contractors ensure that HSE conditions and wage conditions for foreign employees are in line with the regulatory requirements.

We also wanted to see how cooperation and distribution of responsibilities with the contractors and subcontractors functioned in this work.

The objective was also to identify to what extent SH’s management system functions in accordance with the regulatory working environment requirements and internal governing documents, so that employees and employee groups are identified and followed up in relation to the risks they are exposed to in the working environment.

Result of the audit
The PSA identified two non-conformities in relation to the regulatory requirements:

  • SH’s, DEG’s and NEM’s systems for follow-up of the information duty and supervisory duty were deficient.
  • DEG’s main contractor, NEM, could not present documentation for wage and working conditions for the employees of subcontractors and manning agencies.

Improvement items were identified in the following areas:

  • Risk factors related to the working environment in the EVM area were to a limited extent clarified and communicated to the employees.
  • Information given to foreign employees who do not speak Norwegian or English can be improved.

The PSA takes a positive view of the fact that SH and DEG, prior to the audit, had implemented a number of measures so that NEM could present the documentation requested. Both SH and DEG had conducted internal audits of NEM. SH also notified the PSA prior to the audit because lack of documentation from NEM led to a suspicion of social dumping.

The PSA also noted that SH early on in the construction phase for the EVM project had implemented measures to follow up wage and working conditions for foreign employees and handle challenges related to language and cultural differences.

The PSA also takes a positive view of the fact that both SH and DEG will implement measures to ensure compliance with the information duty and supervisory duty, and prevent similar situations from occurring in the future.