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Audit of working hours schemes and follow-up of foreign workers on Melkøya

From 7-9 March 2006, the Petroleum Safety Authority Norway (PSA) conducted an audit of working hours schemes and working conditions for foreign workers at Statoil's facility on Melkøya. The audit was aimed at Statoil as principal/main company, Aker Kværner, Serveringspartner and AFS Pihl as main contractors, as well as some of their subcontractors.


The audit was carried out by means of meetings, interviews, verifications and a review of documents.

Melkøya (source: Statoil)

LNG plant on Melkøya (Source: Statoil)

Background for the audit

Different types of working hours schemes are used on Melkøya. Some of these have been agreed between the parties, while other schemes have been established following the consent of the Petroleum Safety Authority Norway (formerly the Norwegian Labour Inspection Authority).

Many of the workers follow a trial scheme (14-21) established through agreements between the parties. The HSE implications of this scheme have not yet been evaluated to any significant degree.

"Social dumping" is defined as one of the PSA's main commitment areas in 2006. For the PSA, preventing "social dumping" means both following up regulations relating to general application of wage agreements, as well as following up and preventing potential HSE consequences associated with "social dumping" and immigrant labour.

Foreign workers who do not speak Norwegian or English have a language handicap in relation to work on Melkøya. This can have an impact on working environment and safety, in part because communication becomes more difficult.

It may also be assumed that workers from foreign countries have only limited knowledge of the Norwegian HSE regulations and traditions. High standards in HSE require clear, unambiguous communication and a common understanding of risk factors.

The following regulations constitute the formal basis for the audit:

  • Working Environment Act and relevant working environment regulations thereto.

  • Regulations relating to systematic health, environment and safety work in enterprises (the Internal Control Regulations).

  • Temporary regulations relating to safety and working environment for certain petroleum facilities on land and associated pipeline systems (provisional regulations).

  • Regulations relating to general application of wage agreements for certain petroleum facilities on land (the General Application Regulations).

  • Regulations relating to safety, health and working environment at building and construction sites.

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Purpose of the audit

Through this audit activity, the PSA wanted to focus on the HSE aspects of the various working hours schemes used at the land facilities under the PSA's jurisdiction, as well as ensure that foreign workers have equal wages and working hours conditions as Norwegian workers at these facilities.

The audit activity was also aimed at compliance with agreements, statutes and regulations.

Result of the audit

The audit revealed the following nonconformities in relation to regulatory requirements and conditions in signed agreements:

  • Contract labour for the firm Kaefer has worked under a 14-21 scheme for nearly one year without approval.

  • Certain Havator employees have violated the terms of the working hours schemes by working overtime. The violation includes both overtime that is not in accordance with the agreement as well as breach of the resting time provisions of the Working Environment Act.

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The following observations were made of areas where there is room for improvement:

  • Inadequate follow-up when establishing working hours schemes and putting them into pracice.
  • Little or no clarification of safety and health risk associated with expanded working hours schemes.
  • Ventor has a deficient employment contract for its personnel.
  • Deficient follow-up and training in Kaefer with regard to subcontractors'/contract labour firms' follow-up of the General Application Regulations.
  • The content of the HSE introductory course is not adapted for foreign workers who lack knowledge of the Norwegian regulations and Norwegian employee participation and HSE traditions.

Positive factors:

  • The Melkøya project has invested considerable work in translating important HSE information into various languages.

  • Kaefer has used external consultants to check that the contract labour firms follow the provisions of the General Application Regulations.

  • Statoil has conducted a verification of contractors' follow-up of the General Application Regulations.

    The Melkøya project has invested considerable work in translating important HSE information into various languages.
  • Kaefer has used external consultants to check that the contract labour firms follow the provisions of the General Application Regulations.
  • Statoil has conducted a verification of contractors' follow-up of the General Application Regulations.
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Significant information activity is planned surrounding the General Application Regulations.

Contact in the PSA:
Mike Theiss