We have received and reviewed ConocoPhillips's comments to our notification of order and the response to the report, dated 10 February 2005, as well as the binding schedule for implementation of measures, dated 8 April 2004.
Having reviewed the received documentation we consider the requirement for an establishment of specific requirements for the working environment in operations to have been complied with.
Beyond this we do not find the situation significantly changed compared to the time of notification of order, although the schedule received can be accepted as a part of ConocoPhillips' plans to comply with the second part of the order.
On this background the following order is given:
Pursuant to Section 11 of the Management Regulations on manning and competence and Section 20 of the Activities Regulations regarding training in safety and working environment in accordance with the Working Environment Act, cf. Section 58 of the Framework Regulations on administrative decisions, ConocoPhillips Skandinavia AS is ordered to ensure sufficient resources with relevant specific working environment competence, as well as the systematic employment of such competence in the follow-up of the working environment.
The order also includes implementation of measures to improve the understanding within the organization that the working environment shall be managed as systematically as other HSE issues.
Furthermore, ConocoPhillips Skandinavia AS is ordered to go through their system for the management of the working environment for their own, as well as for the contractor's employees, including:
The establishment of routines for a systematical mapping and evaluation of the working environment against the requirements, cf. Section 13 of the Management Regulations concerning general analysis requirements and Section 17 regarding working environment analysis, cf. Item 5.1.2. of the report.
Improvement of systematics for the identification, risk evaluation and handling of deviations from the regulations as well as from internal requirements, cf. Section 20 of the Management Regulations on deviation handling; cf. Items 5.1.3 and 5.1.4 of the report.
Systematic follow-up of working environment surveys and priority of improvement measures, cf. Section 21 of the Management Regulations re. follow-up, Section 22 of the Management Regulation on improvement and Section 14 of the Framework Regulations on the qualifying and follow-up of other participants, cf. Items 5.1.5, 5.1.6 and 5.1.8 of the report.
We will initiate a follow-up meeting with ConocoPhillips for further elaboration on the measures that the company must implement to comply with the order. The deadline for the development of plans to comply with the order is set for three weeks after this meeting has been carried out. The plans containing specific descriptions of measurements and deadlines for implementation must be forwarded to the Petroleum Safety Authority Norway.
We must be notified when the order has been complied with.
We want to underline that the order concerning working environment expertise is specifically tied to the company's overall resource situation in this area, and also the use of available working environment expertise. No questions have been raised regarding the competence of the individual persons.
This decision may be appealed in accordance with Section 28 of the Public Administration Act. The deadline is four weeks after receipt of this letter. The Ministry of Labour and Social Affairs is the administrative appeals body. The complaint must be sent to the Petroleum Safety Authority Norway.
We have requested the company to make this order known to the employee representatives and to the safety delegates, cf. Section 77 of the Working Environment Act.
Contact in the PSA:
Telephone: +47 970 54064