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Notification of order after audit of management of working environment in the removal phase on the Frigg field

During the period 31 May - 3 June 2005, the Petroleum Safety Authority Norway (PSA) conducted an audit of the management of working environment in the removal phase aimed at Total E&P Norge AS' (Total's) and Aker Kværner Offshore Partner's (AKOP's) activity on the Frigg field. The audit revealed breaches of the regulations. The scope and severity of these nonconformities is such that we have issued Total a notification of order.


The audit was conducted by means of interviews with Total on land on 31 May 2005 and 3 June 2005, as well as a verification offshore at the Frigg Central Complex on 1-3 June 2005. A summary meeting was held on land on 3 June 2005.

The audit also included the main contractor, Aker Kværner Offshore Partner (AKOP), which is carrying out the removal work on Frigg, and their subcontractors.

The audit particularly focused on:

  • System for following up working environment conditions offshore
  • Follow-up of contractors and safeguarding of the supervisor responsibility
  • Safeguarding of working environment and safety in planning and execution of work operations
  • Implementation and follow-up of working environment surveys
  • Follow-up of work-related illnesses and reduced working capacity
  • Follow-up of work loads

Background for the audit
Removal and disposal of offshore installations is a topic that will be increasingly relevant as more and more installations on the Norwegian Shelf approach the end of their lifetime. Removal and disposal of such installations entails unique challenges linked both to safety and working environment for employees.

Follow up of the working environment is an important part of the preventive HSE work, and is thus a central element in the PSA's priorities.

In December 2004, an audit was conducted of the cleaning of the Frigg installations, in cooperation with the SFT (Norwegian Pollution Control Authority). The audit targeted working environment and the external environment in the cleaning phase, and it was conducted as a verification offshore.

Observations from this audit indicated a need for additional follow-up of the working environment in the removal phase.

Removal of installations is largely carried out by contractors, while the operating companies have a clear duty of supervision. A good and functional interaction between the operator and the contractor is a prerequisite for ensuring that the activities are planned and carried out in a prudent manner.

Therefore, the relationship between operator and contractor is also a central element in the PSA's priorities.

Objective of the audit
The objective of the audit has been to obtain an overview of Total's management system for systematic follow-up of the working environment in the removal phase, as well as to verify compliance with requirements for systematic follow-up of the working environment.

Another objective has been to obtain an overview of working environment challenges linked to removal activities in general, as well as how these are followed up by Total as operator, and by AKOP as main contractor.

Result of the audit
The audit revealed several weaknesses in Total's and AKOP's management systems for following up the working environment in the removal project. Eight nonconformities and two aspects with potential for improvement were noted. The PSA is of the opinion that deficient involvement of working environment competence is a contributory cause to many of these nonconformities.

In the audit, nonconformities were noted relating to the following circumstances:

  • Potential exposure of employees as regards waste gases from torch cutting, and unfortunate strains as a consequence of manual handling, working positions, repetitive movements, work intensity, etc.
  • Deficient implementation of working environment surveys and risk assessments linked to the removal work.
  • Deficient governing documentation for the removal work.
  • Deficient training of the employees in working environment factors of significance for the removal work.
  • Deficient use of working environment competence in management of the working environment in the removal phase.
  • Deficient follow-up of AKOP as main contractor.

In addition, factors with potential for improvement were observed in relation to rest and restitution, and compliance with the (Norwegian) Tobacco Act.

The audit resulted in Total implementing immediate measures linked to observation 5.1.1, chemical exposure. Reference is made in this connection to the plan for implementation of measures submitted to the PSA on 6 June 2005.

Notification of order
In total, these observations indicate deficient management of the working environment in the removal project on the part of both Total and AKOP for their respective areas of authority. The scope and severity of these nonconformities is such that we have issued Total a notification of order.

The nonconformity relating to exposure to chemicals is considered to be particularly serious. Total and AKOP have implemented measures to ensure that hot work on painted surfaces can be carried out in a prudent manner. Therefore, no order has been issued with specific reference to this nonconformity.

In the notification Total is ordered:

  • to ensure adequate resources with relevant, specific working environment competence, as well as to use this competence in a systematic manner in the follow-up of the working environment in the removal phase.
  • to review its system for managing working environment in order to identify and implement measures to ensure that the work operations are planned and executed in a prudent manner. The order also encompasses the supervisory duty in this area.

The notification of order must also be viewed in context with a corresponding notification of order issued to AKOP. The companies must work together to draw up plans for measures, and stipulate responsibility for executing the measures, based on the companies' respective areas of responsibility for the removal activity.

The deadline for drawing up plans designed to comply with the order is set at three weeks after the order is issued. The plans, with a description of measures and deadlines for implementation, shall be submitted to the Petroleum Safety Authority Norway.

In addition to nonconformities, the report also contains observations of circumstances where there is a potential for improvement. Total is also requested to provide an evaluation of these circumstances.

Contact in the Petroleum Safety Authority Norway
Inger Anda, press spokeswoman
E-mail: inger.anda@ptil.no
Telephone: +47 970 54064