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Report to AAD regarding the Byford Dolphin accident

The Norwegian Petroleum Directorate has sent a report to the Ministry of Labor and Government Administration (AAD) on the investigation of the fatal accident on Byford Dolphin on 17 April of this year.


Enclosure 2


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2. THE NPD'S FOLLOW-UP OF WORKING HOURS REGULATIONS ON THE
SHELF, IN GENERAL


The labor organizations have pointed out that there is an increasing iing incidence of planned use of overtime.

In the new regulations that entered into force on 1 January 2002, the duty to record working hours has also been expanded to apply toly to employees in leading or particularly independent positions in the petroleum activities.

The issues relating to working hours are also discussed in Storting ting White Paper No. 7 on health, environment and safety in the petroleum industry. The Ministry has asked the Norwegian Petroleum Directorate to follow up the activities in accordance with the intentions behind the new provisions and to use necessary policy instruments in this connection.

In an introductory phase, the NPD's objective has been to find out how big the problem is, and where it lies. As a continuation of this, the plan is to send identical letters at the end of September/beginning of October in which we ask the operating companies to review their working hing hour registration systems tems and actual timesheets for their own employees and contractor employees, including senior personnel, so that we can establish an overviewrview of the extent of overtime and extended stays offshore. Based on such material, we will consider additional follow-up and possible measures.

Based on concrete initiatives from NOPEF, the NPD has conducted audit activities vis-à-vis two contracting companies in the drilling and well service sector in the first half of 2002. We have reviewed the companies' timesheets for the second half of 2001 and the first quarter of r of 2002, plans/ agreements for work/on-call periods and free periods, and have also received information on the further development of relevant systems.

The two contracting companies that we have reviewed so far have had a potential for improvement as regards plans for work/on-call and free periods, reporting systems and procedures for recording working hours. We have raised these issues with the relevant contracting companies through the case process. No violations of the law have been uncovered, neither with regard to use of overtime nor work and free periods. NOPEF has been been continuously informed and has in part participated in the contact betweentween the company and the authorities. They have not objected to the treatment nor the result of the review.

In coIn connection with supervision of change processes, the scope of overtime and the length of offshore periods has also been a topic. No serious violations of the working hours regulations have been uncovereovered in this connection. There have, however, been some cases where personnel have been ordered to stay offshore for extra days, e.g. due to a high level of absence due to illness and lack of substitbstitutes, or because work operations were not completed, but not beyond the framework work laid down in the regulations. The NPD has, nevertheless, in several cases opted to point out the unfortunate aspects of such long offshoffshoffshore periods, and has asked the companies to organize things better in order to reduce the scope of extended offshore periods.

In connection with the investigation of accidentidents, the working hours of the personnel involved are routinely checked through interviews and, if there is a basis for it, also by a review oiew of timesheets. Based on this, there have been few incidents of violations of the working hours regulations.

The reinforcement of the regulations with regard to senior personnel has been strongly emphasized in the NPD's presentations in regulatory training, both under the direction of OLF and in other contexts. It is also an important part of the above-mentioned supervision of working hing hours.

Based on information the NPD has received from the Federation of Oil Workers' Trade Union (OFS) last week, we are also coso considering following up certain installations where OFS believes it can present documentation of illegal use of overtime. It may in part be relevant to follow up this issue in audits already planned for some of the specific installations.