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Requirements for the operator

Information is provided here on the formal obligations and duties which apply to all operators on the Norwegian continental shelf (NCS), regardless of their size.

The operator is the company responsible for day-to-day management of activities in a production licence on behalf of the licensees. It has an overall responsibility for ensuring that operations are conducted in an acceptable manner and in accordance with applicable Norwegian regulations.

Section 12 of the framework regulations on organisation and competence stipulates that:

  • The operator shall have an organisation in Norway that, on an independent basis, is capable of ensuring that petroleum activities are carried out in accordance with the regulations.

In-house expertise
The regulations give operators great freedom to organise their operations as they wish – by using external resources to pursue activities, for example.

However, a company is not qualified to fulfil its duties pursuant to the health, safety and environmental (HSE) regulations unless it has its own personnel with expertise in this area.

This means that the operator must have in-house expertise in Norway which allows it to undertake such activities as:

  • qualifying contractors who carry out work of significance for HSE
  • defining assignments for these contractors
  • determining the quality of the products and services delivered by the contractors
  • taking decisions required to ensure that overall operations are conducted in an acceptable manner
  • defining whether and in which areas verification activities (follow-up) are required in its own organisation and at contractors
  • determining the verification basis for its overall petroleum activities
  • undertaking a coordinated assessment of the results of the verifications carried out
  • managing and coordinating the commitment of emergency response resources should hazards or accidents occur.

Boundaries between operators and external contractors
An operator can delegate certain assignments to external contractors. A basic requirement is nevertheless that the operator must be organised in a way which does not reduce its ability to fulfil its responsibilities pursuant to the regulations.

It should also be noted that:

  • the operator itself must take decisions at a strategic level – for third-line emergency response and communicating such circumstances to the media, for example.
  • when dealing with a number of considerations at a strategic level, the authorities will need a dialogue with and opportunities for direct and speedy clarification from responsible operator personnel
  • requirements for supervising contractors also apply to following up consultants and other types of suppliers
  • the operator must keep the regulatory authorities informed about developments in its operations, and which measures it intends to implement.

“See to it” duty (påseplikt)
The operator has a particular duty to ensure that its overall operations are conducted in an acceptable manner and in compliance with the applicable regulations at any given time.

This means that the operator must see to it that everyone carrying out work on its behalf complies with the requirements specified in the HSE regulations.

This duty to verify compliance is additional to each player’s duty to comply with the regulations, and is a general and overriding supervisory obligation.

The operator’s management system must make it clear how the “see to it” duty is discharged.