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Requirements applicable to the licensee

A licensee must facilitate the operator’s work in the production licence and verify that the latter is fulfilling its obligations.


The licensee must therefore be able to document that it has sufficient resources and expertise to determine the quality of the operator’s HSE management.

The “see to it” duty (påseplikt) also requires the licensee to supervise the operator in a systematic manner. Its management system must clearly show how this obligation is met.

The licensee’s “see to it” duty includes ensuring that:

  • the operator has a functioning management system
  • the operator has an adequately qualified organisation with sufficient capacity
  • the operator deals with problem areas and other conditions attracting the attention of the authorities
  • key applications are submitted to the authorities.

In addition, the licensee has:

  • a duty to take action if it discovers that conditions fail to comply with the regulations
  • an independent duty to obtain adequate information.

Duty to audit
The licensee must take a risk-based approach to discharging its “see to it” duty. This means that the licensee, depending on the specific case, may have a duty to audit the operator.