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Minutes from Safety Forum meeting no. 3/2012

The third meeting of the Safety Forum in 2012 had a demanding agenda, with the response to the PSA’s recommendations for the industry after Deepwater Horizon (DwH) and the conclusion of the debate on the Forum’s priorities as the main items.

In addition to these important issues, status reports were provided on all outstanding issues, serious incidents, and organisational and personnel changes in the Forum’s member organisations.

Furthermore, the PSA gave a briefing on its participation in an international regulatory audit series under the auspices of the North Sea Offshore Authorities Forum (NSOAF) following the DwH and Montara accidents.

Time was also allocated for briefings from the Norwegian Shipowners Association (NSA), which has been challenged over participation in various technical projects and processes.

Consultation process in the wake of Deepwater Horizon
The PSA responded to the parties at the March meeting over the consultation processes on the key documents concerning principles for barrier management in the petroleum industry (barrier memo) and measures in the industry to follow up DwH (action memo).

In this context, the PSA said that – in light of the comments on the barrier memo – a process would be pursued under the auspices of the Regulatory Forum.

Since it has been difficult for the PSA to identify specific feedback from the industry’s comments in the consultation processes on measures proposed in the action memo, the PSA had sent circular letters to the OLF, the Federation of Norwegian Industries and the NSA to request specific feedback on measures and who was to implement them.

Report with 45 recommendations
The OLF reported initially on its work to follow up DwH, and the efforts made to produce a report on experience and measures. This work forms the basis for the OLF’s response to the PSA’s identical letter. The OLF provided an overview of the project, and the conclusions of and recommendations from the work.

This project has aimed to draw lessons from the DwH/Macondo accident in order to reduce opportunities for a similar incident on the Norwegian continental shelf (NCS). The most important investigation reports have been reviewed and the consequences for Norway’s petroleum industry assessed.

The work builds on contributions from the parties, the Norwegian Clean Seas Association for Operating Companies (Nofo) and the companies in the industry. An invitation to participate in the project was also extended to the NSA. The OLF emphasised the importance of all the good work done by the parties in the industry, by the PSA, by foreign organisations and by Sintef.

A total of 45 recommendations have been made to the Norwegian petroleum industry in the OLF’s report. Most of these are preventive in character, but they include capping and collection, oil-spill clean-up, standards and industry practice.

Where blowout preventers (BOPs) are concerned, the OLF believes that this issue is best handled by the expert committee on wells of the International Association of Oil & Gas Producers (OGP).

Organisation and management, including improvements to management systems, will be followed up through the individual company. Work on expertise, teamwork and communication will continue in a separate sub-group. Reference will be made here to practice and methods for crew resource management (CRM) in the aviation industry. Collaboration has been pursued with the Norwegian Coastal Administration where the issue of unified command is concerned. Chemical exposure is another critical area. See the OLF’s website for details.

From recommendations to action
The PSA’s identical letter to the OLF, the Federation of Norwegian Industries and the NSA on experience from and follow-up of DwH requested specific feedback on measures and who was to implement them.

The OLF emphasised that the industry’s follow-up to the PSA’s identical letter had to be seen in light of the project’s work and recommendations, and other activities in the wake of the consultation processes, including follow-up of barrier management in particular.

In this context, the PSA noted that the barrier issue relates very much to drilling and well. The probability that the industry will face a well problem in the future has been reduced. The PSA accordingly expects the industry to raise some overall topics which will call for special attention and follow-up by the sector.

The OLF responded by pointing to the work being done on management systems and leading indicators, and the commitment to combating gas leaks in particular.

Challenges related to standardisation work in Norway were raised by a number of members in relation both to the resource position and to the backlog at Standards Norway, and the industry’s responsibility for developing and maintaining Norsok standards.

The Federation of Norwegian Industries stressed its support for the OLF’s work on the report, including issues other than drilling and well. Topics related to Norsok would be followed up in relevant fora.

The NSA referred to its letter of reply to the PSA’s consultative documents and its contribution to the OLF’s work on the report concerning experience and action. It is contributing to the Norsok work, and has plans for a conference devoted to following up the Macondo accident.

In conclusion, the Forum’s chair asked the NSA to provide an overall response concerning its follow-up of the PSA’s identical letter after the next meeting of the operations and environmental committee for offshore construction operations (DMU).

International regulatory collaboration
The PSA briefed the Forum on work with a regulatory audit series  directed at human and organisational factors related to well control.

This audit is to be conducted as part of the work programme in the NSOAF following the DwH and Montara accidents. Five member countries of the NSOAF, including Norway, will carry these out.

The audits will focus specifically on planning of well operations by the organisations and the way human and organisational factors help to maintain well control. They will look particularly at issues and roles related to responsibility and regulation, and will also have a reference to CRM. See CRM in high reliability industries.

Continuous follow-up – towards sign-off
A review of the status for all relevant and outstanding issues is a fixed item on the agenda at Forum meetings. See the link to the overview of outstanding issues on the Forum’s website.

This review includes follow-up of developments in a number of the Forum’s priority areas related to the management of major accident and working environment risk.

Where the chemical working environment is concerned, the PSA reported that it is assessing specific measures to evaluate company follow-up and the implementation of measures and expertise generated by the project on the chemical working environment in the oil and gas industry.

Developments in the industry’s new priority area on noise in the petroleum sector are being followed up in the same manner. In this context, it was emphasised again that technology which helps to reduce noise and environmental risk in drilling operations has been qualified and is ready for use.

Particular attention is naturally being paid internationally to the follow-up activities being pursued in the wake of DwH. That includes reactions from the parties in the Forum to the EU’s regulatory initiative in the form of a position paper from the Norwegian trade unions and industry associations.

This also provides part of the backdrop to the Forum’s decision to contact the directorate-general for energy in Brussels with a view to a meeting during the coming month as part of the Forum’s annual organisational and company visit.

Agreement on priorities
The debate on the Forum’s priorities beyond 2012 has been pursued with great intensity since 2011. Its backdrop includes guidance from the Forum’s mandate and from the working life and petroleum White Papers, and a proposed set of priorities which have been adjusted in line with conclusions reached by the debate through a series of meetings and specific proposals from members.

All the members agreed with the proposed main topics or headlines for the priorities, but certain formulations in the detailing were challenged and debated to arrive at a common understanding of terms.

The term “operating parameters” [or “frame conditions], for example, was discussed and challenged to clarify that this is not about commercial or pay-related interests, but concerns making provision to ensure that the activity is pursued in compliance with regulatory requirements.

This debate resulted in the draft of the priorities being amended in line with the decisions taken at the meeting. Click here for the final list of priorities.