The Trends in risk level in the petroleum activity (RNNP) report shows that nearly 40% of offshore employees who answered a questionnaire in 2015 fully or partly agreed that hazardous situations arise because not everyone speaks the same language. This percentage has fluctuated between 33% and nearly 45% over the last decade. At onshore facilities, the number in 2015 was lower – around 25% – a fall from a full 70% in 2007.
English is replacing Norwegian
The PSA is also receiving language-related whistleblower reports, notably that English is replacing Norwegian as a working language in the petroleum industry. It appears that, in some companies, governing documents, various meetings – including working environment committee and safety meetings – and other communications are in English, even where nearly all the employees are Norwegian.
For the employees, this means that they do not always understand the governing documents and they participate less in important discussions about the working environment and safety. This may lead to weakened employee participation, to decisions that affect health, safety and the environment being inadequately explained, and to important instructions being missed and disregarded in critical situations.
Some whistleblower reports also state that personnel with poor proficiency in both Norwegian and English go out on the facilities, and this is also perceived to be a safety problem.
Section 14 of the Framework Regulations states that the Norwegian language shall be used in the activities to the extent possible. This applies to both spoken and written use. Other languages can be used if necessary or practical to carry out the activities, provided this does not compromise safety.
The guidelines state that, if it is not considered appropriate to use Norwegian in documents of importance for safety, and if safety is not thereby compromised, the employer must be able to document this, in order to exempt the company from translating such documents into Norwegian.
There is also a requirement in the Regulations for Machinery for instructions for use being in Norwegian.
Where it is decided to use another language, it is the employer's responsibility to document that the Norwegian language is not appropriate, and that this does not compromise safety.
The regulations permit the use of languages other than Norwegian when necessary or appropriate for carrying out the activities, provided this is not detrimental to safety.
Must be documented
An employer may not require the employees to prove that the use of English compromises safety, as the PSA has been informed is the practice in some companies.
The PSA expects the companies to arrange matters such that the choice of language is appropriate for everyone involved in the activity, and such that safety and the working environment are safeguarded.
What is the PSA doing?
The PSA acts on all whistleblower reports it receives. We also follow up on the use of language in our audits, for example, by reviewing procedures and instructions for use.
We have found instances of information on working environment committee meetings being in English, as well as governing documents such as emergency preparedness manuals, including action plans.
One important precondition for being able to participate in matters of significance for health, safety and the environment is confidence in the communication and understanding the content what is being said or written. In emergency situations, it is crucial that all routines are understood.
The PSA will continue to keep this on the agenda. Among other things, during audits, we will check on the justification companies have for deciding that using a language other than Norwegian is necessary or appropriate for carrying out the activity, and that this does not compromise safety.