Interviews were conducted, documents reviewed and verifications made during the audit.
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:
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:
Improvement items were identified in the following areas:
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.