Their structure and fundamental principles remain constant, but Norway’s HSE regulations for the petroleum sector are otherwise in a constant process of change.
“These rules represent the very basis for the high level of safety in the industry,” affirms Hilda Kjeldstad, who took over on 1 January as the PSA’s new coordinator in this area.
“Further development of the regulations could be crucial for our ability to achieve additional risk reductions and safety improvements.”
She points out that these provisions not only represent a legal framework but have also been framed to serve a specific purpose.
“They’re intended to be an appropriate tool for continuously enhancing the level of safety, and an instrument for regulatory supervision and management.”
Norway’s present petroleum regulations are the outcome of a long series of improvements and reforms dating back to the start of activity on the NCS in the 1960s.
Learning from incidents has always been at the heart of these developments. The Alexander L Kielland flotel disaster of 27 March 1980, when 123 people died, is a case in point.
It led to extensive changes in both regulations and the regulatory regime in Norway. The accident was, for example, a crucial influence on the new Petroleum Act in 1985 and on the introduction of the internal control principle.
“Many of the important regulatory amendments continue to build on lessons learnt from serious incidents,” notes Kjeldstad. She has worked with the PSA since 2004 as a legal adviser and supervision coordinator.
“Our proposed amendments to the lifeboat regulations, for example, follow from the unsuccessful test launch on Veslefrikk in 2005, and on subsequent improvement work by the industry.
“Similarly, our proposals for revised rules on relief drilling are based on lessons from the 2010 Deepwater Horizon disaster in the Gulf of Mexico.”
The most recent major reform of the regulations came into force in 2011 with the introduction of an integrated set of provisions for petroleum operations both on land and offshore.
“Many of the important regulatory amendments continue to build on lessons learnt from serious incidents.”
Regulations are developed in close collaboration with companies and unions in the industry, and the Regulatory Forum serves as a key arena in this work.
It brings together employer, employee and government representatives several times a year, and regulatory changes are often initiated there.
“The forum ensure broad entrenchment and participation,” explains Kjeldstad. “In our experience, collaboration between the various sides functions well.
“Agreement doesn’t always prevail, but that’s how it ought to be. Positions and opinions differ, but meetings are characterised by openness and an understanding of each other’s roles.
“One area of disagreement is the relationship between functional and specific requirements for the working environment. Employees want more of the latter than the employers.
“When these two sides disagree, however, it’s our job as owner of the regulations to seek to strike a balance and to take account of everyone’s interests.”
“We can’t continue to reduce risk and improve safety without the support of the players, both directly through compliance and indirectly through work on industry standards,” says Kjeldstad.
“Predictability is also a key requirement, and we’re very concerned with that. The same applies to responsibility – each player must accept their duties pursuant to the regulations.”
She describes today’s provisions as robust and appropriate, and says the PSA sees no need for major structural changes to the regime at present.
That was also confirmed by a report on supervision strategy and HSE regulations in Norway’s oil sector from the committee of experts chaired by professor Ole Andreas Engen, Kjeldstad says.
Appointed by the Ministry of Labour, this body conducted a detailed review and concluded in August 2013 that the Norwegian regulatory regime functioned well.
“We have a goal- and risk-based regime, with the emphasis on functional requirements,” notes Kjeldstad. “These principles are felt to work well. Overall, we find the players are satisfied with the regulations.”
“Further development of a good safety level in the oil sector is a common responsibility,” she adds. “So it’s crucial that the industry knows the regulations and backs their basic principles.
“The precondition for functional regulation is the development of new and existing standards and norms to which reference can be made. Without that, the basis for this approach is lost.”
A fundamental principle in Norway is that the companies must apply new knowledge and ensure continuous development and improvement of the level of safety, Kjeldstad emphasises.
“That’s not just an expectation on our part, but a demand. If we see that industry players aren’t complying, we’ll have to assess the need to make the requirements more explicit. Accepting lower safety isn’t an option.”
Always to hand
Norway’s HSE regulations are easily accessible in electronic form at www.psa.no, along with associated guidelines, interpretations, consultation responses, amendments adopted and links to standards.
Figures show that the PSA’s regulation web pages receive about 10 000 hits a month. They have been tailored for mobiles and tablets, so that users in practice always have access to them.