safety status & signals 2010 - 2011 forEword Responsible publisher Petroleum Safety Authority Norway Professor Olav Hanssens vei 10 P O Box 599, NO-4003 Stavanger, Norway Tel: +47 51 87 60 50 E-mail: postboks@ptil.no Web: www.psa.no Editorial staff Inger Anda (editor-in-chief ) Øyvind Midttun (editor) Ole-Johan Faret Thor Gunnar Dahle Angela Ebbesen Odd Bjerre Finnestad Janne-Beth Carlsen N´Jai (design and illustration) Gunlaug Leirvik (editorial assistant) Rolf E Gooderham (English editor/translator) Safety – Status and Signals is the PSA’s annual report in a magazine format. Its articles deal with some of the most important petroleum safety issues addressed by the Norwegian authorities in 2010, and look ahead to key challenges identified by the PSA for the industry in 2011. However, this year’s issue has another dimension. We have opted to highlight some of the success stories – safety areas where the PSA has achieved its goals, in collaboration with the industry. Five articles on that theme cover the Norwegian regulatory model, diving safety, international collaboration between regulators, a parallel look at the story of mechanical pipe handling and the lifeboat challenge, and the requirement for an acknowledgement of compliance (AoC). We hope that this publication will be studied in detail by companies and employees alike in the petroleum industry, and that its contents will contribute to learning as well as encouraging debate. Efforts have also been made to popularise the material in the hope that the general public can also increase their understanding of the issues raised by safety in the petroleum industry. Being involved is a social responsibility. Inger Anda Editor-in-chief Photos Morten Berentsen (unless otherwise stated) Print run Norwegian: 3 000 English: 1 500 Paper Cover: 290 g Mirriboard copper Inside pages: 150 g Multiart silk Printer Spesialtrykk Published 10 February 2011. Final copy date 25 January 2011. Safety – status and signals must be read in conjunction with the formal part of the PSA’s annual report, which will be published on 27 April 2011, together with the annual Trends in risk level in the petroleum activity (RNNP) report. The summary version of the latter can be read and downloaded in English from www.psa.no/risklevel, while the Norwegian summary, the full report and the formal annual report will be available at www.psa.no. 2 CoNTENTS MAIN fEATUrES: 1 BUILDING A RESPONSIBLE BUSINESS 2 REVOLUTION UNDER WATER 18-22 3 PROMOTING COORDINATED ACTION 26-29 4 SUCCESS IN THE LONG TERM 34-37 5 FLOATING ON TRUST 44-46 one for all and all for one An American tragedy four top tasks Keeping old heroes going Combating the cold Standard solutions Averting unwanted contact Blackout bother repetition at refinery rights also involve duties Supply side under stronger scrutiny A close call downhole Lifting safety Putting the facts in place 8-13 4 14 23 24 25 30 31 32 38 39 40 42 47 48 ABBREVIATIONS USED IN THIS PUBLICATION: AoC: Acknowledgement of Compliance HSE: Health, safety and the environment NCS: Norwegian continental shelf OLF: Norwegian Oil Industry Association PSA: Petroleum Safety Authority Norway RNNP: Trends in risk level in the Norwegian petroleum activity S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 3 One for all A company unleashing a serious incident will hurt not only itself and operations in one country, but also a whole industry. and all fOr One By INGER ANDA Another serious petroleum accident in Norway or internationally will hit not only the company concerned but also the whole industry’s reputation, says PSA directorgeneral Magne Ognedal. “Players must accept and display greater responsibility than in the past.” T he Deepwater Horizon rig exploded in the US sector of the Gulf of Mexico on 20 April last year. It took more than three months before operator BP succeeded in capping the subsequent blowout. As a result, 2010 will always be remembered as the “Deepwater year”. This incident has yielded new content for and awareness of the major accident concept. “Very great attention is being paid worldwide to safety in the petroleum sector after the US disaster,” observes Mr Ognedal. “That’s positive in many ways, because it can help to sharpen and enhance safety for people, the environment and material assets.” He notes that the position is very challenging for both oil companies and the supplies industry, pointing out that each player is and must be responsible for safety in their own operations. “However, a climate has now been created in the petroleum sector where a company unleashing a serious incident will hurt not only itself and operations in one country, but also a whole industry – collectively and internationally. The players will have to relate to this in the future.” The most interesting question in this context is how they are to tackle that position, Mr Ognedal points out. “Prevention, learn- ing, expertise and continuous improvement – these four areas contain some of the most important keys for avoiding major accidents.” PREVENTION Prevention is fundamental to good safety, he notes. “This concept embraces all systems and mechanisms required to maintain good control and avoid accidents. “Understanding risk is central here. We must all recognise first and foremost that the petroleum industry involves risk – just like any other activity.” However, accepting risk does not mean accepting accidents, he emphasises. “Quite the contrary. But we must constantly remind ourselves that accidents have happened – and can happen again. “The risk of a major accident is present, in Norway and in all other nations with an oil and gas industry. This means that incidents will occur. “Risk must accordingly be managed, with clear management responsibility, at every level and in every company which participates in the industry.” Preventive measures can be a challenge, Mr Ognedal concedes, because they require that action is taken – often at a cost – without a disaster or other accident having occurred. “However, history offers many examples where extensive measures are adopted after S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 5 disasters. Companies in the petroleum business should consciously ask whether it would not be far better to have an established system which means that preventive measures based on learning, new technology and so forth are implemented, in order to be able to prevent accidents and disasters.” LEARNING Operators in Norway have an independent duty to work responsibly, Mr Ognedal notes. That assumes not least a commitment to learning. Magne Ognedal, director-general of the PSA. Photo: Emile Ashley “I take it for granted that company managements and all players in the business keep continuously updated about incidents in Norway, the major accident on Australia’s Montara field in 2009, Deepwater Horizon and so forth – and ensure that the key lessons are incorporated in their own organisation,” he says. But how, he asks, should one learn from accidents or apply such knowledge to reduce the probability that new incidents will occur? “One thing’s certain, though – unless government, companies and the unions all sit down and study, assess and analyse the reasons for a disaster, we have no chance of learning anything.” However, theoretical understanding is not enough, Mr Ognedal maintains. Lessons must be incorporated in management’s focus on and understanding of risk, in governing documents, training, routines, procedures and compliance. “They must remain with the companies through restructurings, changes of ownership and mergers, and must be incorporated in regulations and government follow-up,” he notes. A project team has been set up by the PSA to help it learn from and see connections between 6 Deepwater Horizon, the Montara event and other relevant incidents. Its overall goal has been to assess experience gained from and investigations conducted into major accidents so that relevant measures can be instituted and contribute to progress and improvement on the NCS. “Because it’s indisputable that a major accident can also occur here, even though safety in Norway must generally be regarded as good,” Mr Ognedal observes. EXPERTISE The companies need expertise and the ability to manage such knowledge in order to operate safely, he adds. “Statoil has pursued major reorganisations in Norway in recent years after its merger with Hydro Oil & Energy, and has had to deal with the impact of many experienced employees retiring early. “The PSA assumes that the company is managing this process in a good way, but it’s worth underlining once again the need to plug knowledge gaps and ensure a well-functioning organisation with competent personnel at every level.” He points out that good safety calls for ability and experience, close collaboration and the involvement of the necessary expertise throughout, both on land and offshore. “That’s particularly important in connection with drilling and well operations, including on the exploration side. Managing demanding drilling work in a good and safe way is a company responsibility. Prestige or lines on an organisation chart must carry insignificant weight in such a context.” CONTINUOUS IMPROVEMENT This is a fundamental principle for the petroleum industry, Mr Ognedal emphasises. The companies undertake to apply the best available technology, best practice and new knowledge. “Although the principle of continuous improvement is well known and firmly established in the business, this doesn’t mean it always gets observed. “Given the challenges facing the industry, it’s necessary to remember that running a company in accordance with the continuous improvement principle is a management responsibility. “We must all continuously secure information and knowledge about conditions relevant to the industry of which we’re a part. “On the basis of what we then know – at any given time and in every context – we must then drive developments forward so that the petroleum industry becomes ever safer and more robust. “It must be regarded as a failure when a company repeats a mistake which could have been avoided by giving priority to learning from errors and experience of its own and of others.” Good safety calls for ability and experience, close collaboration and the involvement of the necessary expertise throughout a company – both offshore and on land. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 7 1 “It’s impossible to inspect quality into the petroleum industry. The latter must itself ensure quality.” Magne Ognedal Supervision coordinators and contacts in the PSA. From left: Semsudin Leto, Ingvill Hagesæther Foss, Hanne Etterlid, Erik Hørnlund, Leif J Dalsgaard, Kjell Arild Anfinsen, Rune Solheim, Hilda Kjeldstad, Hans Kjell Anvik, Odd Rune Skilbrei and Anders Tharaldsen. 8 BUIldInG a reSPOnSIBle BUSIneSS 1 By ØYVIND MIDTTUN The whole purpose of the PSA can be summed up in a single word: safety – for people, for the environment and for the material assets managed by the industry. I n the broadest sense, all the PSA’s activities are directed at ensuring that Norwegian petroleum operations are conducted in an acceptable manner. That makes it important to place the responsibility where it actually belongs – with the industry. FORGED Little or no relevant industrial activity existed in Norway when the oil companies arrived in the 1960s and a new administrative structure had to be forged by government. The development of today’s Norwegian regulatory regime for oil and gas operations had to start from scratch. That was a challenge, but also an opportunity. It meant that the new Norwegian Petroleum Directorate (NPD) established in 1973 could be specifically tailored for the job. At the same time, an important development occurred in the process industry. Attention shifted from conventional quality control at the end of the conveyor belt to further up the production line, and ultimately right into top management. The NPD made a similar move to a new supervisory role, shifting attention from classic “shop floor” checks to work processes, decision-making mechanisms, management and control. CHANGES The supervisory approach being pursued on the NCS in 2011 is the result of a continuous series of changes and improvements since the early 1970s. A bold step was taken by the safety authorities in 1981 with the introduction of a guideline for safety assessment of platform concepts which quantified an acceptable level of risk. At the time, it was not considered “good form” to talk about risk. The little number 10-4, which was a way to describe risk, accordingly created some political disquiet. Nevertheless, it was the passage of the new Petroleum Activities Act in 1985 which has been seen as the dividing line between old and new times. This legislation marked an important step towards a more performance-oriented and risk-based system of government regulation. CONTINUED Since being separated from the NPD in 2004, the PSA has continued the development initiated in 1973. The number of players on the NCS has grown considerably over the past decade. A picture with a few large companies has been replaced by Statoil as the dominant operator and a range of small participants. Despite this trend, the petroleum industry still comprises a limited number of well-resourced firms. It remains a capitalintensive and highly competent business facing big demands. Among the latter are an independent duty to ensure that HSE is managed properly, that the regulations are observed and that operations are pursued in an acceptable manner. The companies must be conscious of these reponsibilities. APPROACHES Roughly speaking, two approaches exist for regulating safety in the petroleum industry – detailed control and performance management. The first of these rests on a regulatory system which sets specific requirements for the structures, technical equipment and operations required to protect against hazards and accidents. In a model of this kind, the safety authorities define the appropriate standards and check that the companies are complying with them. Detailed control often encourages a passive attitude by companies. They expect the regulator to inspect them, identify errors and deficiencies, and explain how these are to be corrected. FUNCTIONS Performance management is the exact opposite. The regulations here are framed to specify the goals to be achieved – or, put another way, which functions must be fulfilled. Norway’s petroleum regulations are based today on such functional requirements, which specify the level of safety to be achieved. GENERAL Many of today’s regulatory requirements are formulated in fairly general terms. As noted above, they primarily spell out which conditions or functions are to be fulfilled. To avoid misunderstandings about what is needed to comply with the rules and to ensure predictability, a number of recommendations and guidelines have been provided. These often refer to recognised Norwegian or international industry standards relating to structures, equipment and procedures. MANAGEMENT The regulator’s job is to describe which goals the companies must reach, and to ensure that they have established management systems which keep operations in compliance with the regulations. Companies can to a great extent choose for themselves which solutions they will adopt in order to meet the official requirements. This Norwegian model is based on the conviction that the government cannot inspect quality into the industry. The latter must itself ensure that quality is achieved and maintained. KEEP PACE Today’s solution means that the regulations do not need to be constantly revised in order to keep pace with technological advances and changes in operating mode. In return, the PSA’s specialists must monitor and participate in developing and revising industrial standards to help make sure that these are constantly relevant and reflect best practice. The work involved in a performance management system can easily be underestimated, so it is important to emphasise that this form of regulation demands much more of the industry, employees and government than detailed regulations. That applies to expertise and management as well as flexibility. However, the payoff comes in the form of better safety management by an industry which has been given responsibility. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 9 1 By INGER ANDA The PSA is securely positioned by a small wood in Stavanger. But the heartbeat of Norway’s huge oil and gas industry is easy to detect within its walls. T he Norwegian petroleum industry operates around the clock throughout the year, and the PSA’s supervisory umbrella covers in practice all operators and contractors involved in this business. Its regulatory responsibility follows an offshore field or å land-based plant through every phase from design and planning, via construction and production, to cessation and removal. Dry figures show that the PSA supervises some 75 fixed installations in the North, Norwegian and Barents Seas, as well as roughly 300 subsea facilities. In addition come more than 40 mobile units qualified for use on the NCS and eight land-based petroleum plants from Melkøya in the north to Slagentangen on the south-east coast. The PSA is also responsible for supervising about 14 000 kilometres of pipelines carrying oil and gas to the UK and continental Europe, and between installations on the NCS. The PSA also serves as the labour inspectorate for roughly 25 000 people working offshore, and regulates safety at 50-60 oil companies qualified as operators. A large number of licensees, contractors and vessel owners involved in the petroleum sector – some 120 in all – come under its supervision as well. INTELLIGENT The PSA is able to follow up an industry of this size and scope by working intelligently and applying its resources in the best possible way. This means in practice that it concentrates on the overall dimensions and on company management systems, aided by Norway’s regulatory regime. That is largely based on functional reqirements. These rules specify which safety level should be attained, but give companies a fairly free hand in deciding how they are to comply with and operate within the requirements set. A number of systems, databases, reports, contact points and people in the PSA form components of the “ECG” which A FINGER ON 10 Discipline leaders in the PSA. From left: Sigve Knudsen, Ole Jacob Næss, Ingrid Årstad, Kjell Marius Auflem, Svein Anders Eriksson and Torleif Husebø. 1 monitors the pulse of Norway’s petroleum business from its Stavanger offices. The agency’s primary job is supervision, but the way this term is applied in the Norwegian oil and gas sector can be hard to understand and explain. Put briefly, however, the PSA’s supervision covers much more than a visit offshore or to a land-based plant, embracing as it does the total contact between supervisor and supervised. Including audits, investigations and dealing with applications for AoCs and consents, this regulatory model is primarily preventive in nature. ORGANISED The PSA is organised in discipline and supervisory sections, with the first of these comprising about 20 small and specialised areas grouped under six main headings. These are “home” for staff members, and it is here that the professional, overall assessments and analyses are made. The supervisory section comprises teams drawn from various disciplines to assess licensees, other players and their operations. All operators on the NCS are allocated to one of three such teams. While the largest is dedicated to following up offshore activities by Statoil, by far the dominant player on the NCS, the other two cover the small and medium-sized operators. Responsibility for contractors is assigned to another team, as is supervision of mobile units and their owners and the eight land-based plants. The regulatory development and legal affairs area currently embraces 10 staff, who work on the regulations and support case management. In addition, they follow up agreements, relations with the European Union/European Economic Area, and national and international standardisation as well as pursuing special projects – including support for the Ministry of Labour. The teams exercise the PSA’s use of formal instruments, as covered below. DIALOGUE The bulk of practical supervision consists of dialogue between the PSA and the industry – requesting plans, analyses, documentation, information and so forth. A formal, notified audit usually begins in good time before the team starts its field work, through meetings with the relevant company which involve both appropriate managers and employees. Notice is usually given about a month in advance. Separate meetings are held with the safety delegates to ensure that employee views are heard. Audit results are summarised in reports, which are then posted to the PSA’s website. Defined supervisory work is supplemented by multi-disciplinary initiatives aimed at the industry as a whole to influence a positive development within a specific subject. Sources A full picture of the PSA’s sources of information involves too broad a canvas for a brief article, but some of the most important include the following. THE PULSE S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 11 1 Notification of undesirable incidents Companies are required to notify the PSA about undesirable incidents. The regulations clearly define what must be reported and notified, and some 800-900 notifications are received every year on a dedicated form. Hot line The PSA has a hot line staffed around the clock for reporting emergencies. Such reports are first received and registered by the duty officer, who also makes the initial assessment of their seriousness and the possible immediate action required. If necessary, the duty officer will activate the PSA’s emergency response centre to monitor a serious on-going incident. This can be done at short notice around the clock. Tailored follow-up Any undesirable incident notified is allocated to a case officer, who checks it, categorises its seriousness (which may differ from operator’s assessment) and selects a tailored follow-up for the operator/company. In the event of very serious events, the PSA may decide to launch an investigation or another kind of close follow-up. The response to less serious incidents will be tailored to their nature. RNNP The RNNP process is an important tool for monitoring the industry, since it measures the development in its level of risk both offshore and on land. This yields an annual report based on the large volume of data provided by the companies at the end of each year, which is then quality-assured by the PSA. These RNNP reports, published around 20 April, provide a realistic picture of developments in the risk level from year to year. Industry, unions and government all agree that they give an accurate picture of conditions. Whistleblowers Whistleblowers help to shape and complete the picture of the safety position. The PSA receives information from employees in the industry about poor safety or conditions open to criticism in their workplace. Such inputs are closely followed up in accordance with established and legally required routines. The anonymity of whistleblowers is protected. DDRS The daily drilling report system (DDRS) is a helpful tool for regulators, with companies required since 1984 to provide information on all NCS drilling via this database. Essential facts about each current operation can be extracted by the PSA from the DDRS, thereby assuring itself if necessary that undesirable well incidents have actually been reported. It can also verify the sequence of events with the aid of print-outs. FORMAL INSTRUMENTS Formal instruments (available reactions) at the disposal of the PSA span from dialogue to orders, shutting down installations or fields, daily fines and exclusion from the business. The agency applies the necessary measures to ensure that activities are conducted in accordance with regulatory requirements. Although many people compare the PSA with the police, it is important to remember that the goal of supervision is not exposure or punishment. The PSA’s job is to define the terms for responsible operation of the petroleum industry and to check that companies are working on prevention and continuous improvement of safety levels. The criminal law is the province of the police. Supervision by the PSA assumes a responsible industry which meets its obligations and complies with the regulations. The system is based on trust. Companies involved in the Norwegian petroleum business have an independent responsibility to operate safely. The government’s job is to supervise that they do so. PULLING PROPERLY TOGETHER Cooperation between companies, unions and the PSA is solidly rooted in history and the regulations. But specific action had to be taken to get this to work in the right way. By ANGELA EBBESEN Employee participation runs like a red thread through Norway’s regulatory regime for the oil industry, and is essential for cooperation to function both locally and centrally. But good collaboration does not just happen. Partnerships between employeers, unions and government at every level depend on a sense of equality between the participants, good dialogue and an acknowledgement of roles and responsibilities. Such mutual recognition between companies and employees did not exist in Norway at the end of the 1990s. On the contrary, relations were often confrontational. ON TRACK A number of important measures adopted by the government got collaboration back on track, including the creation of a genuine 12 basis for dialogue through the PSA’s RNNP process. Focusing on the risk level and HSE challenges in the industry, this work also contributed to a shared understanding of hazards. The tripartite Safety Forum was established in 2001 in order to initiate, discuss and follow up current safety, emergency preparedness and working environment issues. It has become an arena for mutual and strategic information-sharing and debate, where employers, unions and government give signals, clarify roles and allocate responsibilities. Set up in 2004, the Regulatory Forum ensures tripartite involvement in developing the regulations, and is a continuation of the earlier external reference group for regulations created in 1985. EXPERIENCED Both these fora are chaired and operated by the PSA, with companies and unions represented by experienced personnel from their respective central organisations. All three sides have contributed knowledge and experience through a number of specific projects and processes. This lowers the level of conflict and enhances respect for each other’s roles. Involvement in work on White Papers, the RNNP and developing regulations has contributed to a shared understanding of risk, ownership of solutions and measures to reduce risk. OPEN AND HONEST Norwegians tend to take their country’s tradition of openness for granted, but the significance of this part of the national culture must not be underestimated. By ØYVIND MIDTTUN Norway is a transparent nation. An open approach has been and remains a fundamental principle of its government administration. That has rubbed off on the country’s biggest industry. Demands for information sharing, reporting and exchanging knowledge doubtless felt foreign to the international oil companies who arrived on the NCS in the 1960s and 1970s. But the rules of the Norwegian game were the same regardless of whether one’s head office was in Houston or Stavanger. INFORMATION The openness principle is central to the PSA’s information policy, which specifies that data provided to the industry, the media and the general public will be open, available and reliable. As far as is possible and acceptable, the agency will inform people about the industry and reply to questions. That carries an obligation. WEBSITE The PSA’s website is an important channel for openness, presenting all consents and AoCs issued as well as every audit and investigation report from the agency. In addition, circular letters are posted to the site along with articles about measures and initiatives being pursued by the PSA. The most important goal of the site and the agency’s other information work is to contribute to experience transfer and knowledge building about safety issues in the oil and gas sector. ARCHIVE The PSA’s central electronic archive is at the heart of its information flow. All documents, whether received or sent, are registered and recorded there. This archive also handles the many requests for access to information, which are rising year by year. A new record of 2 784 applications was set in 2010. Virtually all of these are granted, with only 128 refused wholly or in part last year – a good indication that the PSA is firmly committed to the principle of greater transparency and the ambition of the Storting (parliament) for more openness in government administration. COOPERATION Openness contributes to information exchange and learning, creates credibility and lays the basis for cooperation between companies, unions and government. This represents the very essence of the approach taken by Norwegian regulators to the oil and gas industry. Being open about challenges, problem areas, incidents and near misses is also an important requirement for efforts to reduce risk. 1 WELL VISITED Figures for the number of hits on the PSA’s website confirm that this is a very important channel for spreading information about who it is and what it does. The following were registered in 2010: • roughly 385 000 visits • about 1.5 million page hits – in other words, the average visitor looked at four pages/articles per visit • 25 600 unique visitors during November 2010 (new monthly record) • visits from 184 countries/territories • most foreign visits from the UK, the USA and Denmark • one visit apiece from New Caledonia, Togo, Turkmenistan, Laos, Aruba and Gibraltar, among others. Source: Google Analytics Tussle over transparency A hard fight is being pursued internationally to increase the level of openness in the oil industry. Organisations such as Transparency International, Publish What You Pay and the Tax Justice Network are in the front line of the battle. The UN’s Global Compact initiative also plays an important role in this context. Much of the effort is focused on exposing large cash flows, with the aim of combating the corruption which means that huge sums earned from petroleum end up in the wrong hands. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 13 The global oil and gas industry has been responsible for several disasters over the past decade, but few have heard of them. When Deepwater Horizon exploded in the Gulf of Mexico, safety in this business became a worldwide issue. 14 By INGER ANDA AN AMERICAN TRAGEDY Some of the incidents which rocked the industry in recent years are known to and much discussed by insiders. They include Montara off Australia in August 2009 and the Aban Pearl and Petrobras P36 sinkings off Venezuela last year and Brazil in 2001 respectively. But neither the industry nor society as a whole has taken much notice of platform losses which reportedly occurred off Egypt in the past three-four years. Little information is available about these events. A number of other serious oil and gas accidents in nonwestern parts of the world have also failed to arouse much interest. But the tragedy in the US Gulf has become a global disaster. Almost 4.7 million Google searches for Deepwater Horizon were recorded this January. Everyone has heard of this accident, seen the pictures, heard the comments and noted that an oil disaster has occurred off Louisiana. DISASTER The incident was certainly a disaster in anyone’s terms, and accords with the PSA’s own definition of a major accident in the petroleum industry. This is an acute incident, such as a major spill, fire or explosion, which immediately or later causes a number of serious personal injuries and/or loss of human life, serious harm to the environment and/or loss of large material assets. Deepwater Horizon meets all these criteria. Eleven people were killed and 17 injured – some seriously. Huge volumes of oil were discharged to the sea. The financial losses are astronomic. This US disaster has been responsible for nothing less than a paradigm shift in society’s perception of the importance of safety in the petroleum industry. Most of the world’s major producing nations have initiated follow-ups, projects and studies in the wake of the tragedy, and demands and expectations for action are being voiced. These include calls for global regulation, international coordination, crossnational regulatory requirements and a more unified safety regime in general for petroleum operations. Supranational bodies and certain nations have launched initiatives on international cooperative efforts to assess how regional and global challenges can be tackled. They include the European Union, the Oslo-Paris convention for the protection of the marine environment of the north-east Atlantic (Ospar), the G20, the International Association of Oil & Gas Producers (OGP) and the International Association of Drilling Contractors (IADC). PROJECT The PSA established a project team on 7 May 2010 with some 20 members drawn from relevant disciplines to follow up the Deepwater Horizon disaster. Its overall goal is to systematise and assess experience and investigations in the wake of this incident, so that appropriate lessons can contribute to learning and improvement on the NCS. The project will identify areas where enhancements can be made to the requirements in Norway’s regulations and/ or other types of measures related to Norwegian petroleum operations. Other assignments for the team include: • charting and assessing all aspects of Deepwater Horizon which relate to safety and emergency preparedness, and clarifying the scope, course and causes of the accident • identifying and describing observations concerning direct and underlying causes as well as non-compliance with regulations, methods and procedures • assessing and comparing relevant US and Norwegian regulatory requirements • describing the actual consequences of the accident, including harm to people, material and financial assets and the environment (duration and quantity of oil discharges) • assessing the potential of the incident to cause such harm • helping to convey information to other players and government agencies, primarily via established collaboration arenas at national and international level. The project will assess Deepwater Horizon in relation to similar incidents in order to identify common features, with particular reference to Montara, Aban Pearl and the loss of mooring chain on Ocean Vanguard off Norway in 2004. Plans call for the team’s conclusions to be published this spring. No final date had been set when this issue went to press. Key elements will be published on the PSA website. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 15 By INGER ANDA Be prepared Studies of emergency preparedness and well integrity, design and construction were launched in Norway after a review of initial analyses and reports from the Deepwater Horizon incident. This work is being coordinated by the OLF at the request of the PSA. The industry’s need to assess the validity of emergency response principles for halting a possible subsea blowout in Norway was stressed by the PSA on 15 June in a letter to the OLF. In addition, the industry association was asked to evaluate existing strategies for limiting the volumes discharged from a blowout while it is under way. That would also mean identifying possible improvements in the form of new practices, development of technology and/ or a revised understanding of preparedness requirements. COMPARISON The PSA compared the 21 recommendations in the report on Deepwater Horizon published by US interior secretary Ken Salazar in late May with the minimum requirements in the Norwegian regulations. These proved to accord almost entirely with the US proposals. However, the PSA resolved to initiate analyses of the following areas in Norway: 1. Well integrity, including: - organisational factors – educating, training and qualifying people with critical functions in planning and executing well operations - operational and technical management systems for well control - operational and maintenance requirements for blowout preventers (BOPs), including existing systems for certifying such equipment 2. Well design and construction It was resolved to pursue part of the work under the two first sub-items in the list above in cooperation with the Well Integrity Forum (WIF). This group was established at the PSA’s initiative in 2006 and is run by the OLF. The assessment of the Salazar findings was commissioned on 1 July, and its results had not been finalised when this issue went to press. See the PSA website for the latest status. 16 Much attention in the wake of the Deepwater Horizon accident has focused on technology and emergency response requirements. But divisions of responsibility, roles and collaboration between management and employees are also important factors. NOT ONLY DOWNHOLE Widening the perspectives of work being done in the wake of the US disaster is a key concern for Kjell Marius Auflem, the PSA’s discipline leader for drilling and well technology. He also headed the PSA’s project team on lessons from Deepwater Horizon for the first six months. “I’ve noted that most people are talking about technology, deep water, cement, BOPs, casing and tubing after Deepwater Horizon,” he says. “I believe it’s equally important to focus on responsibilities, roles and union-management cooperation. “It’s gratifying to affirm that conditions in these areas are good in Norway, including a well-functioning system of safety delegates who have the right to halt work.” He emphasises that a good safety culture is one which involves employees, shows respect for divergent opinions and tolerates challenges to decisions when life and health are under threat. “That said, a number of technical conditions need to be looked at more closely after the US accident, including the design of BOPs. “The PSA, acting on behalf of the International Regulators’ Forum, has launched a study through the IADC and the OGP to assess this in more detail. “Cementing and the quality of cement plugs will also occupy a key place in the technical part of the post-Deepwater studies.” FACING A MEDIA STORM That everybody’s eyes turned to the USA after the Gulf tragedy is perhaps not surprising. But it was less easy to predict that the PSA would be overwhelmed with calls from the world press MANY LESSONS TO LEARN The US presidential commission’s report on Deepwater Horizon was published just after Hilde-Karin Østnes took over as head of the PSA’s post-accident project in January. “This is a very voluminous document, which we’re going through in great detail,” says Ms Østnes, who comes like her predecessor from the drilling and well technology discipline. “The report is fairly scathing in its judgement of the way the companies involved handled the conditions which led to the rig explosion. “That offers many lessons for the industry, also in Norway. But it remains to be seen whether these and other findings prompt the PSA to propose regulatory changes or the like at home.” Although the division of responsibility in the PSA and its opposite number in the USA are very different, she also considers it interesting that the commission report so openly emphasises the need for a competent and clear regulator with adequate resources. “It’s also worth noting that the commission deals with the industry’s independent duty to operate safely, and calls for a model which focuses more on the approach to risk and on enhancing the responsibility of the US industry. “That coincides with the safety regime we’ve had in Norway for many years”. The duty press officers at the agency observed developments in the days, weeks and months after the Deepwater Horizon disaster with some astonishment. Their normal job is to answer questions from regional and national media – in that order. But most of the questions they received in the weeks after 20 April came from abroad. Calls were made by the USA’s biggest and mightiest newspapers, British media, Swedish radio channels, prestigious international magazines, and print and broadcast journalists in a number of European nations. This endless stream of inquiries involved not only big and all-embracing questions but also queries at a level of detail which even the biggest experts in Norway might hesitate to answer. It became clear during the spring and summer why all this attention concerning an accident in the far south of the USA was being directed specifically at Norway. The country is regarded internationally as one of those with the best offshore safety, the soundest regulations and the most demanding government supervision. That reputation carries an obligation as well as being rather awesome – at least for the authorities and perhaps for the industry. But it might also serve as an inspiration. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 17 2 By OLE-JOHAN FARET reVOlUTIOn Under WaTer Diving on the NCS is conducted on acceptable terms and at a level of risk comparable with other petroleum industry in Norway. These conditions have prevailed for longer than many might think. T - - he bare figures illustrate the revolution which has occurred in underwater working off Norway: - no deaths related to diving in the petroleum industry since 1987 few serious personal injuries or cases of the bends over the past two decades, but some serious near-misses – particularly in subsea lifting operations substantial improvements in equip ment and the working environ ment over the past 30 years. RESPONSIBILITY The Norwegian Petroleum Directorate (NPD) took over responsibility for marine diving operations from the Labour Inspectorate in 1978, and established a five-person section for this area. Separate regulations for offshore diving were adopted in the same year, while diver certification was 18 introduced in 1980 and training gradually improved. Combined with intensified inspection and a steady tightening of the regulations, this converted North Sea diving into safer modes – and brought it into line with other petroleum activities. This positive trend continued in the 1990s through such measures as: - standardisation of diving tables and a number of new or tougher requirements in the diving regulations of 1991 - increased attention paid to health issues, including longand short-term diver monitoring - introduction of a clear hierarchy of responsibility in the industry, with the operator’s compliance responsibility ensuring that the diving companies work safely and in line with regulatory requirements. The NPD – the PSA since 2004 – has also made a substantial contribution by acting as a prime mover for improvement and by setting the terms for the industry. NO GUARANTEE “Knowledge, statistics and a positive attitude in today’s diving business provide no guarantee that a serious incident couldn’t happen tomorrow,” emphasises PSA special adviser Olav Hauso. He points out that the physical strains imposed on divers – water and high pressure – will always pose a risk. “We now have good regulations, serious players, new diving support ships, solid diving expertise and positive accident statistics. “However, my greatest fear is that we’ll lock ourselves into a selfsatisfied condition. It’s important to keep up the pressure and not fall for the temptation to treat safety efforts lightly.” The PSA’s core team dealing with the diving business comprises three people with long and wide – but also highly varied – experience. Mr Hauso decided to move to the diving sector in the early 1980s after two years with the Norwegian Petroleum Directorate (NPD) as a newly graduated naval architect. He secured a job with France’s Comex, which also employed the five men who died in the Byford Dolphin accident, but returned to the NPD in 1986. A few months later, a Briton working from Seaway Condor died during work on the Oseberg field in the Norwegian North Sea. Mr Hauso helped to investigate that incident. “These accidents, along with a death in 1983 on Seaway Falcon on Ekofisk, made an impression on me,” Mr Hauso says. “It prompted a strong involvement over many years in helping to enhance safety and avoid more such tragedies.” 2 DEADLY SERIOUS The 1983 accident on Byford Dolphin, which claimed the lives of five divers, still has a deep effect on Olav Hauso. That incident has influenced subsequent work on diving safety in Norway. FRAMEWORK He headed a far-reaching NPD project in the late 1980s to develop a new framework which could reduce diving risk to the same level as in the rest of the petroleum industry. “The most important milestone was passed in 1991, when new regulations for manned underwater operations were adopted,” says Mr Hauso. These rules tightened the requirements in such areas as a risk-analytical approach to activities, and new standards were set for technical, organisational and operational solutions. A separate chapter was devoted to health considerations, with the Norwegian Board of Health responsible for following up in this area. “These regulatory requirements are still appropriate,” says Mr Hauso, and notes that – while the HSE regulations have since been amended – key demands from the 1991 diving rules are implemented in the Norsok U-100N industry standard. WORKED Mr Hauso has worked on diving at the NPD/PSA for more than 25 years, including six as head of the NPD unit which embraced this activity until a reorganisation in 2000. A direct line still runs from the accidents mentioned above, he says. “The most important consideration for me is that we haven’t had a fatal diving accident on the NCS since 1987. “I hope that good statistics will be maintained. We have to know the history of this work so that new generations in the industry don’t repeat earlier errors. “It’s then important that we use the potential offered by the tripartite collaboration between companies, unions and government to secure good workplaces and a safe industry.” Olav Hauso has had a strong commitment to diving safety for many years. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 19 2 THIRSTY FOR KNOWLEDGE A big commitment to research and development (R&D) characterises Norway’s diving sector. The PSA’s John Arne Ask has been a prime mover or participant in many major projects and studies. Dr Ask, who has a PhD in physiology, joined the Norwegian Petroleum Directorate (NPD) in 1989 and has subsequently played an active role in supervising the diving industry. That includes being an observer and participant in a number of R&D projects devoted to learning more about health risks. He has not been alone. “Few if any occupational groups have been so well followed up as offshore divers, both for safety at work and with regard to their short- and long-term health,” says Dr Ask. ISSUES Large sums of money have been spent since the 1980s on getting to grips with technical/operational and work environment/health issues related to diving. “It made a big change to come from a university with limited resources and struggles over research funding to the diving field, where plenty of cash was available,” Dr Ask observes. Funded by both government and oil companies, with Statoil in the lead, this R&D work has yielded important knowledge about risk, which benefits diver safety. “One example in which I was personally involved was the trials conducted to learn more about the threat of dehydration in diving,” Dr Ask reports. “These showed that divers have extremely high fluid loss when working. That prompted changes to the rules on the time spent in water, requiring breaks with a plentiful supply of liquid.” TABLES Another important improvement was the introduction of standardised diving tables in the early 1990s. Such tables had previously been regarded as a competitive element, with the “smartest” versions giving their users a commercial edge. “Through a government initiative, the diving industry developed tables for all saturation diving on the NCS,” Dr Ask says. “That’s almost eliminated decompression sickness (bends).” The big commitment to R&D in the diving field has contributed to substantial results and expertise-building from both pure and applied studies at various institutes in Norway. “The Norwegian University of Science and Technology (NTNU) in Trondheim, for instance, has succeeded in combining medical and technical expertise,” reports Dr Ask. “That’s allowed it to develop a group of researchers who rank among the world leaders for extreme working environments. Work on decompression and bubble formation in blood, for instance, is relevant for astronauts – who can also suffer the bends.” 20 John Arne Ask believes that few occupations, if any, are as well monitored as petroleum industry diving. 2 Bjarne Sandvik was a North Sea diver himself for much of the 1980s. VETERAN SUBSEA With only three years of service at the PSA, Bjarne Sandvik might seem to be the new boy among the agency’s diving specialists. But such appearances are deceptive. Mr Sandvik was an offshore diver himself for much of the 1980s, and then worked as a manager related to diving. So he has a solid basis for the views he expresses at the PSA. “I know that conditions could be tough in the 1970s, but my main impression as a North Sea diver in the following decade is that we were reasonably well looked after,” he says. “I experienced an increasingly serious approach across the board, both from Stolt Nielsen Seaway – the diving company I worked for – and by the operators.” The quality idea sneaked its way in, he recalls. “We were more and more involved in fairly tough internal audits to ensure that we had the work under control. “A growing focus on developing procedural tools was another example of the way safety was being taken seriously. “Although some memorable incidents occurred, I never experienced unacceptable pressure on us divers which compromised our safety.” CLEAR He also has the clear impression that the NPD, as the regulator at the time, was actively involved in both regulatory development and not least in issuing safety reports. These attracted great attention and formed the basis for experience transfer and improvements to safety and the working environment. “The safety reports were often issued on the basis of incidents or problems reported to the authorities,” explains Mr Sandvik. “They focused on specific issues, and functioned as an effective channel for spreading knowledge rapidly to the whole industry. And they were taken seriously. “I particularly remember safety report no 1 for 1986, which gave us divers a minimum 12-hour rest break at a fixed time of day. That contributed directly to a dramatic improvement in our working conditions.” NOT EASY Although safety was eventually taken seriously, Mr Sandvik says that being a North Sea diver was not an easy life by any means. People competed over the available jobs. “Many of us were looking for work at one time, and it was crucial to be acceptable to the diving manager and superintendent. They had power, and were fully aware of it. “Nevertheless, once you were on the inside and had been selected to make saturation dives, safety was handled in a good way.” For various reasons, the diving contractors have always had relatively few permanent employees – apart from a golden age in the 1980s. While the regulations do not specifically require permanent jobs, Mr Sandvik regards organisational conditions – including employment and a predictable personnel policy – as an important area for further advances in diver safety. That not least influences opportunities for achieving good follow-up of diver health, he adds. “Although the PSA has limited powers in this area, we can’t avoid emphasising perhaps the most important frame condition for divers – who’re a group particularly exposed to risk, of course.” S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 21 2 ROLE AND RESPONSIBILITY When the PSA was formally separated from the NPD on 1 January 2004, one of the responsibilities it inherited was regulating and supervising professional diving in the petroleum industry. Covering both the NCS and the land-based plants, this includes developing regulations, conducting audits and verifications and considering documentation submitted with consent applications. In addition, the PSA holds meetings with the players and participates in regulator fora both nationally and internationally ACTIVITY DOWN BUT STABLE After peaking at more than 100 000 work-hours in 2006-07, the volume of saturation diving on the NCS has declined to about half that level and is expected to stay there for the next few years. An estimated 200 people are directly involved in petroleum-related diving in Norway, including 50-100 divers. The majority of these are Britons. Norwegians account for only 10-15 of the saturation divers, and there are few if any signs that this figure is set to rise. What’s in a name The word diving has been replaced in a number of context with the more heavyweight expression “manned underwater operations” or MUO. This designation was introduced with a revision of Norway’s regulations in 1991, because these apply not only to regular diving but also to one-man submersibles and atmospheric suits. “Diving” then became too narrow. Saturation diving The diver works from a bell, which transports them under pressure from a chamber on the support ship to the work site, and remains pressurised in the chamber between bell runs. Surface-oriented diving BROAD AGREEMENT The PSA’s view that diving operations on the NCS are conducted in an acceptable manner is shared with both sides of the industry. A working party set up by the Safety Forum in 2004 and drawn from companies, unions and government, for instance, concluded the following year that offshore diving was pursued in line with the regulations and the level of risk accepted for all operations. 22 The diver enters the water at the surface, carries out the job at the relevant working depth – down to about 50 metres – and returns. Additional chamber compression/ decompression may be part of such diving. By ØYVIND MIDTTUN fOUr TOP TaSKS Management and major accident risk, groups exposed to risk, barriers and the natural environment have been defined as the PSA’s main priorities for 2011. A limited number of priority issues are identified by the agency every year as the ones which need particular attention from the industry. These are selected on the basis that improvement is needed and that a special commitment and willingness will be required to secure the necessary measures or processes. The PSA believes that action in these areas will have the biggest effect – in other words, give society and the petroleum industry the best return for its efforts. In addition, the main priorities provide an important guideline for planning activities at the PSA, which has selected the following issues for special attention in 2011. Management and major accident risk Management at all levels of the industry will work to reduce major accident risk, and ensure that this work is pursued in an integrated manner. Initiatives and decisions taken by managements significantly affect frame conditions for such threats. It is important to recognise that the industry poses risk, but that this can be managed. Accepting a certain level of risk does not mean that an accident is acceptable. Several close shaves in recent years are a reminder that the underlying threat of a major accident always exists. PSA audit results, experience from major accidents internationally and recognised accident theory all highlight the key role played by management in reducing such risk. Learning by senior executives and their contribution to implementing similar lessons in the organisation are important elements. By giving a high priority to this issue, the PSA will follow up and exert influence to achieve improvements. Barriers Safety barriers must be maintained in an integrated and consistent manner in order to minimise the risk of a major accident. Experience shows that reduced performance or breaches of barriers are often a causal factor in incidents. The sum of technical, operational and organisational conditions is crucial in ensuring that a barrier works efficiently at all times. The PSA considers it important that the maintenance and improvement of barriers are further developed. Enhancing awareness and expertise represent key elements in this context. In order for the industry to continue developing and improving its systems, it is important that everyone concerned – such as contractors and vessel operators – participates actively and accepts their share of the responsibility. Maintaining barriers on ageing installations, not least in connection with production life extensions, is also a key concern here. Groups exposed to risk The risk of injury and ill-health varies from one occupational category to another in the petroleum industry. The PSA is challenging the industry’s ability to tailor its follow-up with measures designed for the groups which need them most. The clearest distinction in worker risk in the petroleum sector lies between contractor personnel and operator company employees. Many contractor personnel score high for risk factors, where noise, hazardous chemicals and physical strain are the most important. Psychosocial conditions and work with a high accident potential are also significant. The cost of occupational ill-health and injury is high, and the losses are considerable for those affected, for the companies and for society. Follow-up by the PSA has shown that contractors have some way to go in developing management systems, expertise and capacity to handle risk factors. At the same time, good frame conditions are essential if they are to succeed. The PSA will pay particular attention in 2011 to noise levels which can cause hearing damage and to risk conditions for a steadily growing body of contract workers. Natural environment The PSA’s role in efforts to protect nature and the environment from harm is aimed primarily at the preventive side – in other words, helping to stop accidents from happening. Good management is again an important aspect of environmental protection. The RNNP process has now been expanded to cover the risk picture for acute discharges as well. These findings help to form the basis for the PSA’s risk-based supervision, and must be used by the industry to act on the principal contributors to risk. In 2011, the PSA will look at links between the potential for major accidents and environmental harm. How company managements get involved in and contribute to managing such risk will also be in focus. Learning from accidents and incidents is a key element in that context. The PSA also contributes to the national commitment on reducing greenhouse gas emissions. It does this by adapting the regulations to facilitate adoption of new technology and solutions by the industry which can cut emissions. At the same time, it checks that the players ensure such new solutions are also acceptable in safety terms. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 23 Keeping old heroes going Veterans of the NCS such as Åsgard, Valhall, Hod and Gyda have had their producing life extended – but not at the expense of safe operation. By OLE-JOHAN FARET The need to secure an official consent to let fields stay on stream longer than originally planned was included in Norway’s offshore regulations in 2002. By clarifying the extension process, this has helped older fields and facilities on the NCS, many with heroic names taken from Norse mythology, to continue producing. Ageing installations have been a priority at the PSA for a number of years, since roughly half the production facilities on the NCS are already beyond their design life. And 25 more are due to pass this milestone over the next decade. “New technology, operating methods and improved recovery methods mean that licensees often want to use existing facilities beyond their planned duration,” explains Gerhard Ersdal, project manager for ageing and production life extension at the PSA. “This will often make socio-economic sense. At the same time, it’s not acceptable to keep an installation on stream if it puts safety at risk.” FACTORS Both technical and non-technical factors can require a facility to be updated. The first category includes time-dependent conditions such as corrosion or fatigue, and long-term developments like collisions or seabed subsidence. Non-technical considerations cover obsolescence of equipment or changes to standards and requirements since 24 hardware was manufactured. Organisational aspects can also be important, as when a company loses expertise about the way to use relatively old equipment. A consent to extend producing life requires the operator to demonstrate that all risk factors have been assessed and the necessary steps taken so that operation remains acceptable. RESOURCES The PSA has devoted substantial resources to enhancing its grasp of conditions which influence safety on elderly offshore installations. Operator audits, surveys – either conducted or initiated by the PSA – and close follow-up of projects and processes in the industry have yielded a better overview of risk factors and the most important safety aspects. That in turn has laid the basis for developing regulations, standards and routines, and not least boosted awareness of the issues by the authorities and in the industry. “In addition to cooperating with management and unions, we’ve conducted and initiated a number of projects to clarify how regulators in other industries – including nuclear power and aviation – handle these questions,” reports Mr Ersdal. “Learning from these sectors has enhanced our knowledge. We’ve also collaborated closely and well for a number of years with regulators in other countries. “Involving the UK, the USA and the Netherlands in particular, this boosts experience transfer and contributes to equal treatment of producing life extensions across national boundaries.” He emphasises that the outcome of combining knowledge in this way exceeds what any one of these bodies could have achieved on their own. MAINTENANCE A fundamental requirement for a safe production extension is good maintenance throughout the time an installation has been on stream. Experience also shows that a focus on managing such work becomes even more important as an installation approaches middle age. According to a survey conducted by the PSA in 2010, maintenance on older installations increases in scope and takes longer than when they were young. Requirements for updating analyses and carrying out modifications also increase, while work on replacements becomes more extensive. This clearly confirms that more attention will need to be given to these issues by the industry as well as the regulator in 2011. Read more about ageing and production life extensions at www.psa.no/ageing. Combating the cold A lengthy freeze in 2009-10 hit a number of Norway’s land-based petroleum plants. Faulty design was the main reason for these problems, according to a PSA review. By ØYVIND MIDTTUN Many weeks of extreme cold allowed ice to build up in piping systems at various processing facilities last winter. But this went unnoticed until pipes were wholly or partly plugged or pressure had built up. The most serious incidents occurred at Kårstø north of Stavanger, Mongstad near Bergen and Nyhamna in mid-Norway. Icing at all these facilities cut or eliminated flaring capacity. This problem may have existed for a number of days before it was detected. Ice could also have reduced flare system capacity in earlier winters, but melted before being discovered. TESTING These experiences underline the importance of testing safety systems during cold spells, since most safety barriers in a process plant are passive in normal operation. As happened with the flare systems, these barriers could be weakened or demolished without anyone realising it. Tests are needed to establish that they remain intact. Temperatures offshore were not as low as on land last winter, and relatively few incidents related to icing problems were reported from NCS installations. But fresh incidents occurred at Kårstø and Nyhamna this December. They did not introduce any new factors, but underlined that the problem is not being adequately addressed. The PSA will therefore continue to devote attention to the icing problem in 2011 in order to check that operators and the industry in general have amended winter test routines for safety. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 25 3 PROMOTING The petroleum sector is a global industry, and knowledge of conditions in other comparable countries is therefore very useful, says Magne Ognedal (right). Together with special adviser Odd Bjerre Finnestad, he has worked for many years to promote closer collaboration between international safety regulators. 26 3 By ØYVIND MIDTTUN COORDINATED ACTION The risk of major accidents recognises no frontiers. Cross-border collaboration between government agencies can accordingly help to boost safety in the international petroleum industry. T hey may operate with different frameworks, regulations and cultures, but the 10 members of the International Regulator’s Forum (IRF) present a united front on reducing risk. This informal but nonetheless important body brings together agencies which regulate safety in the offshore oil and gas industry in various countries and provinces worldwide. The PSA has been a member since the forum was established in 1994. LIMITED Cooperation between safety regulators in the various countries was limited until the mid-1990s, explains PSA special adviser Odd Bjerre Finnestad. “We undoubtedly felt that each of us sat on our own little patch and concentrated on our own jurisdictions,” says the man responsible for the agency’s day-to-day contact with the IRF. “One result was that the authorities in the various countries developed varying types of regime and regulations, and had different approaches to supervision. “However, the industry – and to some extent the unions – had formed international organisations at an early stage to protect their interests. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 27 3 “A number of safety regulators found that these bodies could exert pressure on them by reporting that other countries imposed less onerous requirements for their operations.” Together with PSA director-general Magne Ognedal, Mr Finnestad has been an important driving force in developing the international collaboration. KICKED OFF A 1994 meeting held at the annual Offshore Technology Conference (OTC) in Houston, Texas, kicked off a closer collaboration over safety regulation. “In the space of an hour or so, the US, Canadian, British and Norwegian regulators agreed to set up an informal forum to discuss and exchange information,” explains Mr Finnestad. Other countries have subsequently joined, and the IRF’s membership is now drawn from nine countries. But the motive has remained unchanged. This is to keep each other updated and informed, share experience, compare regulatory methods and assess safety levels in the various member states. EXCHANGE The IRF facilitates the exchange of ideas and opinions on methods applied and principles for effective supervision of safety and the working environment. Swapping facts about regulatory activities and information on relevant technical issues, development of regulations and so forth is also part of its remit. Within the opportunities and constraints which apply in each country, this helps to promote mutual understanding among the members over the regulator’s role, use of instruments, regulatory methods, expertise development and relations between government and industry. IMPORTANT Mr Ognedal has followed the progress of the IRF closely since 1994, and believes it is important both as a meeting place and as an information channel. “The many discussions and debates conducted through the IRF have been informative and constructive, and have provided valuable insight into regulatory systems in other countries and current issues in regulation,” he says. “We’re part of a global industry, and being familiar with conditions in other comparable countries is accordingly very useful. “That applies to the meeting with the oil companies, in international contexts, and in relation to our duties in the Norwegian petroleum industry.” The annual meetings represent the core of the IRF collaboration. Every twothree years, the forum also stages an International Regulators’ Offshore Safety Conference. Open to all, the latter attracts civil servants from countries which have or are planning offshore oil and gas operations, and representatives from everyone involved in the industry. The most recent IRF conference took place in Vancouver, Canada, last autumn, at the end of a very hectic year for the IRF. Sea during 2009 and the helicopter crash off eastern Canada in the same year, with 17 fatalities. The biggest impact nevertheless came from the Deepwater Horizon incident on the Macondo prospect in the Gulf of Mexico on 20 April 2010. That disaster shook the world. Eleven people died, many more were injured and a major oil spill followed. It demonstrated the risk presented by oil operations with full clarity. All the IRF’s member countries had to re-prioritise their work in order to follow developments and decide whether changes were needed to their regulations and regulatory practice. ISSUES In the wake of Deepwater Horizon, the IRF has resolved to continue pursuing important issues such as safety culture and management, and assessing the functionality of blowout preventers (BOPs). The development of indicators to measure each member country’s HSE performance is also on the agenda. So are preparing the necessary acceptance criteria for company expertise and capacity, and last – but not least– the selection of the best standards and best practice. Responsibility for studying these matters has been divided up between the members, who will in turn approach the parties involved to find good solutions. ATTENTION Much attention was levelled at Australia’s West Atlas/Montara accident in the Timor IRF IN BRIEF The annual letter of allocation from the Ministry of Labour requires the PSA to maintain a good collaboration with petroleum regulators in other countries or regions. A central place in the global arena is occupied by the International Regulators’ Forum (IRF), which currently embraces Australia, Brazil, Canada, Mexico, the Netherlands, New Zealand, Norway, the UK and the USA. As an informal body, it has neither an elected leadership nor its own administrative staff. But that does not mean the IRF is without international influence. Over the years since its creation in 28 1994, it has established itself as a selfevident partner for other influential interest organisations. The forum currently comprises the heads of 10 independent safety regulators for the upstream offshore oil and gas industry. All have the authority to account for their country’s operational, technical, strategic and political conditions. In addition, they have full access to relevant information from their own country/province, which helps to ensure meaningful debate. Decisions which serve as guidance for the members are adopted unanimously at an annual plenary meeting. 3 GETTING TOGETHER Safety regulators from all over the world will be meeting in Stavanger this autumn to review follow-up activities in the wake of the Deepwater Horizon disaster. Odd Bjerre Finnestad (left) and Magne Ognedal in the PSA will be bidding delegates welcome this autumn to a major conference for international safety regulators in Stavanger. The IRF conference in Vancouver last autumn resolved to hold an extraordinary session during 2011 to update the industry on the status of work and the execution of IRF-initiated assignments. It has since been decided to stage this meeting in the Norwegian ”oil capital” from 4-5 October. TIES THAT BIND The PSA is an active participant in several international fora and activities. NORTH SEA The North Sea Offshore Authorities’ Forum (NSOAF) brings together all government agencies in this region with regulatory authority for offshore petroleum operations. Established in 1989, its goal has been to ensure a continuous improvement of HSE in the North Sea oil and gas industry. Many projects have been pursued by the NSOAF with the aim of reducing differences between formal national requirements for technical, operational and educational conditions. The members meet annually for a plenary meeting, where activities are summed up and new assignments initiated and discussed. RESEARCH Another multinational collaboration is the International Committee on Regulatory Research and Development (ICRARD), which was created in 1994. It provides an arena for information sharing and experience transfer in HSE research for the petroleum industry. The aim is to make research work known so that it does not necessarily need to be repeated elsewhere. CRANES AND LIFTING Together with regulators in other North Sea countries, the PSA has been an active participant in the Offshore Mechanical Handling Equipment Committee (OMHEC). This aims to improve safety in crane and lifting operations, and guidelines have been prepared for the industry through the committee in an effective manner. DIVING The PSA participates actively in the European Diving Technology Committee (EDTC). Common educational standards for divers are a visible result of this collaboration. COUNTRY TO COUNTRY Bilateral collaboration with other offshore regulators in northern Europe allows the PSA to contribute at a technical level to meeting the internationalisation of the industry. This involves the exchange of knowledge and experience in a number of areas. WORKING GROUP The Norwegian and British authorities have also collaborated through a special working group (SWG) on exchanging experience and strategy work. Meetings are held twice a year. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 29 STANDARD SOLUTIONS Getting to the bottom without sinking safety is a challenge. Greater standardisation could hold part of the answer. By THOR GUNNAR DAHLE More and more petroleum production equipment is being located on the seabed. Norway currently has about 75 installations visible on the surface, and roughly 300 positioned subsea. Good grounds exist for seeking underwater solutions, including the cost of installing concrete or steel support structures exposed to strong natural forces and in need of maintenance. In practice, surface facilities attached to the seabed cannot be used in water depths beyond 500 metres. MONITORING Reliable methods and equipment to monitor the condition of subsea facilities are essential for such solutions to function acceptably in terms of safety and economics. Seabed hardware also needs maintaining. Components and equipment packages must be replaceable or repairable. That calls for remote control or the use of mini-submarines. 30 SHARED The Norwegian players are praised by PSA principal engineer Trond Sundby for their willingness and ability to be open about development and experience. “A high degree of standardisation has a positive safety effect,” he believes. “In critical circumstances, where an fault needs to be swiftly rectified, this would simplify access to spare parts and help ensure that they are installed quickly and safely.” INTEGRATED Mr Sundby sees a need for even more integrated thinking in standardisation efforts, cutting across disciplines and areas of responsibility. “We must elevate analyses and assessments from the component level to a higher plane, so that function and robustness are assessed in a more integrated manner,” he maintains. “Each component may be high quality and satisfy the requirements. But that doesn’t necessarily mean the complex system of which this unit forms part will cope with the stresses involved and thereby perform its intended function.” Subsea facilities on the NCS have so far comprised wellheads, templates and manifolds. But development is continuing, with the first seabed separation and injection equipment now in place. Mr Sundby notes that subsea installations are becoming ever more complex, which calls for extensive control systems and instrumentation. “Such solutions are vulnerable and present new safety-related challenges, not least with regard to data transfer,” he says, and emphasises that the risk of acute discharges must be acceptable. EXPERTISE A more electronic future opens the way to new types of faults and problems, he believes, and will not least impose higher standards for personnel who install, operate and maintain such systems. “It’s positive that many good educational initiatives have been taken in the industry,” Mr Sundby says. “That shows attention is also being given to human factors in the hightech picture.” In addition to developing regulations and exercising supervision, the PSA’s contribution to this exciting trend consists partly of active involvement in standardisation work. Its role in this context is to make its knowledge and experience available and to clarify the regulatory requirements for equipment and methods. Averting unwanted contact The PSA is concerned that the many collisions between vessels and installations on the NCS could lead to major accidents. It has called for big improvements in ship operation. By ODD BJERRE FINNESTAD A dramatic impact hit the Norwegian headlines in the summer of 2009, when well stimulation vessel Big Orange XVIII ran into the Ekofisk 2/4 W platform at a speed of almost 10 knots. Extensive damage was caused, and the PSA’s investigation found that the incident, under slightly changed circumstances, could have developed into a major accident. But this event was by no means unique. Collisions have been occurring on the NCS ever since the oil industry arrived in Norway during the mid-1960s. In 1966, for instance, the Ocean Traveler rig almost sank after supply ship Smit Lloyd 8 holed one of its columns several times when discharging because of a strong current and high waves. REPORTED A total of 115 collisions between installations and visiting vessels with work on the field have been reported since 1982, and no less than 26 between 2001 and 2010. None of these incidents have caused loss of human life or personal injury, but the material damage has been extensive in some cases. NOT LEARNT The investigation of the Big Orange XVIII incident showed that important lessons had not been learnt after a similar event in June 2005, when supply ship Ocean Carrier hit a bridge on Ekofisk. Both cases involved inadequate routines for handing command of the ship from one officer to another. And although collisions occur for a variety of reasons, some key features recur. These incidents are often the result of poor organisation of work and responsibilities, deficient training of the personnel involved, or the failure of technical equipment. Facilities on the NCS are dimensioned to withstand collisions of a certain size, but a number of such incidents have involved impact energies above the design values. The PSA has got to grips with this issue, and believes that a significant improvement in vessel operation is needed along with better methods for assessing loads on installations and their strength. EDUCATION Paying greater attention to education and organisational aspects will also be important, along with a reduction in the technical failure rate. However, the PSA sees no need to amend the regulations. The trend is good for collisions between petroleum installations and vessels not working on the field, with a decline in the number of incidents. That partly reflects good monitoring. Two traffic management stations, one on the Ekofisk and the other at Sandsli outside Bergen, cover most of the NCS. Some fixed installations and mobile units are also responsible for keeping track of passing maritime traffic. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 31 BLACKOUT BOTHER Several cases of serious power failures on Norwegian offshore installations in 2010 boosted safety risks, and tougher supervision is planned in this area. By THOR GUNNAR DAHLE Some of the cases of lost power reported to the PSA in 2010 were total blackouts, which involved both main and emergency supplies dropping out. Losing the main electricity supply is not a serious threat to safety in itself, according to PSA principal engineer Eivind Sande. “The systems are designed to fail-safe if the power is cut off,” he notes. “But any unplanned irregularity in the production process increases risk, so such events must be avoided. “An extensive power failure usually halts production as well, so it causes a financial threat as well as enhancing risk. “In addition, loss of emergency power in an incident reduces opportunities for pursuing important response functions in a sufficiently robust manner - and must not happen.” TIME It can take time to get power generation and all the other systems up and running again. In one case last year, the installation was without power for almost two days. Secure electricity provision is essential for a facility to function, whether transmitted by cable from land or generated on-site. The main power supply is needed for the 32 many work processes on board as well as for lighting, heating, cooking, ventilation and sanitation. If it fails, emergency generation will also be required to keep key systems going – such as emergency lighting, communication and safety systems. That applies not least during an evacuation. DIFFICULT A power failure on an installation can make life difficult for the crew, Mr Sande points out – particularly by boosting the risk of injury when the necessary lighting for work and movement is lost. “If the incident lasts for a long time, heat will also be lost in workspaces and accommodation, indoor air quality will deteriorate and non-functioning toilets will pose problems. “In such conditions, it can be necessary to reduce staffing on the installation to a minimum.” The PSA intends to strengthen its supervision by implementing measures which persuade those responsible to deal with the challenges of safeguarding power supplies on installations, particularly with regard to emergency generation. The PSA registered a sharp increase in power failures on NCS installations during 2010. In one case, it took two days to restore normal working. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 33 4 By OLE-JOHAN FARET Success in the long term. The story of mechanical pipe handling confirms that innovation requires time, money, commitment – and courage. These regulatory requirements created a storm in the industry when they were introduced in the 1990s, but worker safety improved sharply. History also demonstrates that the industry must see the challenges, be innovative in finding good solutions and not least display the ability to adopt newly developed equipment. Mechanical pipe handling is now also taken for granted internationally. It represents a success story. The PSA is now working to achieve the same outcome for offshore lifeboats. Efforts to improve lifeboats offer several parallels with the fight over mechanical pipe handling. 34 4 Reviled requirements paid off The demand for mechanical pipe handling on offshore facilities aimed to get people off the drill floor – a dangerous place to be, with many accidents including serious injury and death. One of Norway’s most controversial offshore regulations was introduced in 1992. It called for remote handling of all tubulars less than 20 inches in diameter on the drill floor and in transit from the pipe racks. “It was clear to everyone that working conditions for people on the drill floor were unacceptable,” says Øyvind Tuntland, the PSA’s director for regulatory development. “Crews had to handle a lot of heavy equipment in motion both horizontally and vertically on uneven floors slippery with mud and other muck.” He was appointed head of the drilling section at the Norwegian Petroleum Directorate (NPD) at the same time as the disputed regulation appeared. “Joining the NPD in mid-1992 was like landing in the middle of a war. Formulated as mandatory, the regulation meant that all fixed installations and mobile units with drilling facilities had to be extensively modified. “Another major problem was the lack of standardised remote control solutions for the drill floor which met the new rules. This meant that systems had to be specially designed.” PROTOTYPES Many different prototypes installed in the first few years had not been adequately tested and failed in use. The disconsolate mood was reinforced by a slump in the petroleum industry during the early 1990s, with a poor rig market and low day rates. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 35 4 A number of complaints about the new requirements and the way they were applied by the NPD also winged their way to the ministry. None were accepted. “The main reason why the government’s view prevailed was that the extra costs for the industry could not outweigh the social benefit of adopting the regulation,” explains Mr Tuntland. “Heavy, physical and risky work on the drill floor, which had caused so many serious accidents, was no longer acceptable either offshore or by comparison with conditions in land-based industry.” The first formulation of the requirement for remotely operated handling appeared in the 1980s, but did not become mandatory until 1992. With hindsight, the process of making this demand compulsory was not ideal. During the public consultation, the industry dismissed it almost as a castle in the air while the NPD gave more weight to socio-economic considerations than to the financial impact for the companies. SHARP Discussions between the industry and the companies on one hand and the authorities on the other were accordingly conducted in fairly sharp tones. “We were roundly abused both on the phone and in meetings,” Mr Tuntland recalls. “And I remember being booed when giving a paper at a drilling conference. Tempers ran fairly high for a time.” After a few tough rounds, however, the climate between the industry and government improved. A two-year transitional period was part of the regulation, and the NPD took a pragmatic approach to applications for extensions to the deadline during the 1990s. It was necessary not least to gain adequate experience with the equipment and to ensure that pipes with both large and small diameters could be handled. The key job was to commit all operators and rig contractors to upgrade existing facilities. Where new installations or rigs were concerned, the rules were enforced more rigorously. STORY The demand for mechanical pipe handling was undoubtedly a success story for the Norwegian authorities, and for the 36 country’s petroleum industry. “Serious incidents, including ones with tragic outcomes, continue to occur during lifting operations on the drill floor,” Mr Tuntland concedes. “All the figures nevertheless show that this regulation gave safety a boost. A drill floor was perhaps the most dangerous workplace in Norway until its introduction.” It also gave part of the supplies industry a shot in the arm. Hitec, under the leadership of founder Jon Gjedebo, was among the first to develop technology for remote pipe handling. An industry worth billions of kroner thereby grew up in the wake of the regulatory requirement. Although specific demands for mechanical pipe handling have not been incorporated in the regulations of other countries, this technology also dominates the international scene. That is not only because safety improves, but also because experience shows that it reduces downtime and thereby makes drilling more efficient. “The whole world manufactures and uses such systems now, whatever the regulatory requirements,” acknowledges Mr Tuntland. “But Norway showed the way, and that the impossible was possible all the same.” Key figures in the lifeboat affair and the work on mechanical handling are Øyvind Tuntland (above right) Sigurd Robert Jacobsen (right) and Rune Solheim (far right). Long fight for secure evacuation 4 Efforts to enhance the safety of lifeboats on the NCS began in the mid-noughties and are still in full swing. Within a few years, it may be possible to say “Look to Norway” in this area as well. Extensive damage to the superstructure of one of the freefall lifeboats installed on the Veslefrikk B platform in the North Sea was exposed during testing in 2005. When the same happened shortly afterwards on the Kristin field in the Norwegian Sea, both the PSA and the industry understood that action had to be taken. “Lifeboats are your last chance of getting away in an emergency where every other means of evacuation fails,” says Rune Solheim. “That’s why it’s so important that they can do their job,” adds the PSA staffer, who has been closely following the lifeboat affair with colleague Sigurd Robert Jacobsen. The petroleum industry established a project which uncovered a number of weaknesses with existing freefall lifeboats. Similar problems have also been identified for davit-launched craft. This work thereby became relevant for everyone working in the petroleum activity on the NCS. MARITIME It quickly became clear that freefall and davit-launched lifeboat designs were based on maritime regulations. These had not been adequately modified for the special conditions in the offshore business on the NCS. Norwegian petroleum operations are also characterised by round-theclock activity, regardless of season and weather. “Our regulations include a functional requirement that it must be possible to evacuate personnel on installations to a safe area under all conditions,” Mr Jacobsen says. STRUCTURAL Weaknesses in both freefall and davit-lowered lifeboats, with associated launch gear, relate to structural strength of both hull and superstructure, G forces, propulsion and buoyancy/stability. “As a result, a large proportion of existing lifeboats and launching systems have significant weaknesses, and so fail to meet the demand for evacuation under all conditions,” says Mr Solheim. To compensate for this, a number of installations must reduce their staffing in bad weather – which can have consequences for safe and efficient operation. STANDARDS New industrial standards based on the latest findings have been developed for freefall lifeboats and launch systems. These must be revised as fresh questions are raised about their suitability, but nevertheless represent an important step in upgrading the stock of such craft. “Lifeboat owners – in other words, operators/rig contractors – have an overall responsibility to ensure that the equipment used is suitable for its purpose and complies with the regulations,” says Mr Jacobsen. Statoil is the primary operator on the NCS to have accepted the consequences of the latest information, launching a project to build new freefall lifeboats which meet the revised standard. “We haven’t observed a similar commitment among the other operators or rig contractors with freefall craft,” Mr Jacobsen reports. “They’ll be in our sights in the time to come.” Despite the weaknesses which have been identified, the PSA still regards freefall craft as the best available technology for lifeboat evacuation on the NCS. LAUNCHING A new standard for davit launching systems has been drawn up, but work on a corresponding norm for the actual lifeboats using such equipment has yet to start. Such lifeboats are common on mobile units which observe maritime regulations, but can also be found on fixed installations such as Veslefrikk A, Ekofisk, Ula and Valhall. One of the most serious weaknesses identified for davit launched craft is the risk of using them when significant wave heights are greater than five metres, Mr Solheim explains. PARALLELS The lifeboat affair has several parallels with the fight over mechanical pipe handling on the drill floor in the 1990s – the process takes many years, and new equipment must be developed, tested and adopted to comply with the regulations. “Achieving the same level of safety must be the goal, regardless of the type of installation/unity, the lifeboat model and when this was adopted,” Mr Jacobsen emphasises. “To prevent accidents during lifeboat evacuation, we consider it necessary to take action through the regulations and in other ways. “Norway has an expressed goal of being a world leader in HSE. Players on the NCS must accept that this also extends to the stock of lifeboats.” S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 37 REPETITION AT REFINERY The PSA was required to investigate two gas escapes at the Mongstad complex north of Bergen during 2010. It will be keeping a close eye on the plant this year. By ØYVIND MIDTTUN A leak occurred at the Mongstad refinery on 8 February, last year when workers insulating a liquefied petroleum gas (LPG) line drilled a hole in it and thereby released some 300 kilograms of gas. Although this volume was very small and the potential threat proved equally limited, the PSA’s investigation revealed non-conformances with the regulations. These related to inadequate risk assessment in the planning phase and a lack of expertise and understanding of the hazards involved. SECOND The refinery suffered a second leak on 12 September in connection with routine maintenance of a reactor used in producing petrol products. This incident involved escapes from two points – a thermowell on the actual reactor, and a heat exchanger which leaked as a result of overloading after shut-down and pressure reduction, Overall, large volumes of gas were released. The leak rate was put at 4.7 kilograms per second by investigators for both the PSA and operator Statoil. It took an hour to halt both escapes. The PSA’s investigation revealed two nonconformances from the regulations related to inadequate spare-part management and lack of expertise. LEARNING Audits have been conducted by the PSA with Statoil at Mongstad for several years, where the focus has been on learning from and following up incidents. This supervisory activity will continue in 2011. Maintenance is one of the areas in the spotlight this year, reports principal engineer Arne Johan Thorsen in the PSA’s process integrity discipline. “The Mongstad refinery has a relatively large maintenance backlog. A lot of good work is being done, but the high level of activity imposes strict requirements on its planning. “We want to take a closer look at this, partly with regard to risk assessment and expertise. ” Supervision of this maintenance planning will be conducted in collaboration with the Norwegian Climate and Pollution Agency (Klif ). GETTING TOGETHER A positive view is taken by the PSA of a special network which has been created for the small operators and licensees (SOL) on the NCS. Participation in this link-up should provide good opportunities for exchanging experience and learning across the companies. That relates to such areas as compliance with the regulations, industry challenges in general, and exploration activities in particular. 38 RIGHTS ALSO INVOLVE DUTIES A growing number of new companies want to operate exploration activities on the NCS. But not all are equally well prepared. By ØYVIND MIDTTUN Applications for an exploration drilling consent have twice been refused by the PSA in recent years because the operator concerned lacked the necessary knowledge and expertise. “Some of these new companies haven’t paid enough attention to the duties which accompany the rights they’ve acquired,” says PSA supervision coordinator Hilda Kjeldstad. “The regulations impose requirements for capacity, expertise and organisation.” The increase in companies seeking to become involved in the hunt for oil and gas on the NCS has escalated over the past decade, and the number of operators is expanding year by year. operators great flexibility in organising their operations. But some requirements are absolute. The operator must protect the safety of people, the environment and the material assets represented by vessels – including operating reliability. They are also responsible at all times for maintaining an effective emergency response to hazards and accidents which could mean fatalities, injuries, pollution or major material damage. The framework HSE regulations require operators to have an organisation in Norway which can stand on its own feet in ensuring that operations comply with the rules. MODEST Common denominators for many of the latter are that they have a relatively modest organisation, operate production licences in an early phase, and are pursuing or planning exploration drilling. Several of them aim to make their debut as an exploration operator during 2011. In addition, a number of companies with limited experience are making drilling preparations. “The operator is responsible for ensuring that work is done in an acceptable manner and in compliance with the applicable regulations,” says Ms Kjeldstad. “Players preparing to drill must be aware of their duties.” Norway’s petroleum regulations give DOCUMENTATION Requirements for documentation in the early phase are being extended from 2011 under section 26 of the framework regulations. This ensures that the PSA can follow up at a sufficiently early stage how the exploration operator organises itself, manages and plans activities until applying for consent to drill. Once an operator has decided to start planning such a well, the PSA must be notified of the date when this preparatory work is due to begin. The provision is directed primarily at new operators who are intending to spud their first exploration well. Operators with experience of and involve- ment in such drilling on the NCS provide the PSA with the necessary information through continuous follow-up of each company. PRIORITY New operators, particularly those applying for their first exploration drilling consent, will be followed up in 2011 through the PSA’s main priority of management and major accident risk. “Our experience in recent years emphasises the special importance of monitoring the planning of the first exploration well activity,” says Anne Vatten, one of the PSA’s directors of supervisory activities. Key considerations here are management of HSE in the preparatory phase and taking care of the operator’s compliance responsibility. In addition comes ensuring that the company in question has the capacity and expertise to take key decisions and to make assessments which ensure acceptable activity. “Players must demonstrate that they are capable of discharging their operator responsibilities, that they are familiar with the regulations and that they can comply with them,” Ms Vatten says. She emphasises that the partners in Norwegian production licences also have a duty to follow up the operator’s plans. Well incident under scrutiny A wireline operation on the Shell-operated Draugen field in the Norwegian Sea on 4 December 2010, which weakened safety barriers, is being investigated by the PSA. The incident in the temporarily shut-down production well, regarded as serious by the PSA, occurred while seeking to replace a gas lift valve. In order to access this device, the downhole safety valve had to be retrieved. But the latter got stuck as it was being pulled through the Xmas tree. That in turn prevented operation of the upper and lower master valve in the tree, which lowered safety barriers for the well. The PSA decided to investigate the incident on 7 December, but the work had not been completed when this issue went to press. The report will be published at www.psa.no. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 39 Supply side under stronger scrutiny The role of the contractor has become steadily clearer, not least to the PSA, over the four decades since Norway became a petroleum producer. By ANGELA EBBESEN Changes in roles and interfaces between players on both sides of the operator-contractor divide have emerged as the latter’s place in the industry expands. This has also demanded adaptability and innovation throughout the supplier chain, presenting challenges in identifying and managing safety and working environment risk – both that created by others and that generated by one’s own operations. “The PSA addresses both operators and contractors through our audits today,” explains Finn Carlsen, a PSA director for supervisory activities and involved in this role since 1994. “I think this contributes to all players in both these camps implementing processes for continuous improvement,” he maintains. ALL PLAYERS Although the operators have been central to government regulation since the Norwegian Petroleum Directorate was established in 1973, the regulations have always been directed at all players. Supervision and the framework for the industry have been developed in line with technological advances, risk understanding and practical experience. Kicking off in 1985 along with the new 40 Petroleum Activities Act, risk-based supervision was a result of lessons learnt from investigations, audits, and work on regulations after accidents on the NCS. It was still important 20 years ago to help enhance awareness and professionalism at the operators concerning their obligations under a functional and risk-based regulatory regime. “It was important for us to follow up the operator and its compliance responsibility, and to gather the threads from the regulations and audits,” says Mr Carlsen. “Our starting point was literally the operator’s role and duty to ensure that all contractors and sub-contractors complied with the regulations.” ing environment conditions, and conducted audits of both operators and development contractors. “We had long recognised that the operator played the key role in determining the terms for safety and the working environment in the industry,” explains Mr Carlsen. “That was exercised through contracts and the ownership of installations and equipment, and through established management systems. “We had to make strategic choices which ensured an integrated approach to supervising HSE through the players in the industry. The new aspect was that we, as the regulator, summed up our supervision and sent reports to both operators and contractors.” DIRECT Contractors became subject to direct supervision during the 1990s, with the initial focus mainly on management and follow-up of working environment conditions. New regulations on systematic working environment (SAM) follow-up were introduced in 1995, and became an important tool in the design process for new installations. The contractors played a key role here. With SAM, the PSA began to monitor physical, technical and organisational work CENTRAL Sigve Knudsen has played central roles in the regulation project and the systematic commitment to supervising contractors since joining the PSA from just such a company in the late 1990s. He became discipline leader for the working environment last summer. “It’s interesting to have been audited by the NPD, and then getting the opportunity to help develop strategies for the risk-based and integrated supervision of the whole hierarchy of responsible parties in the industry,” he says. Changes to the player picture, work processes, expertise and size have helped to alter the balance of power between participants. That applies to both operators and contractors. The latter have secured new and important roles with regard to planning and executing major projects – and thereby to managing risk. “When conducting audits directly with the contractors, we found that we were meeting the chief executive,” notes Mr Knudsen. “That gave us a channel right into the company. “It’s the top management which negotiates with the operators. Being in contact with the regulator has an effect when they talk with their own customers. I believe their understanding of their own role in the wider picture is changed and enhanced. “We must think in terms of integrated risk management and player follow-up. The composition of participants and the interfaces between them are factors which must contribute to the choice of supervision strategy.” AGENDA The Deepwater Horizon disaster in the US Gulf has made it clear to every player in the industry – including the suppliers – that nobody can avoid having major accidents high on their agenda. Management and major accident risk has already been a top priority at the PSA for several years. “I think the gas blowout on Snorre A in 2004 contributed to a new awareness, not least among drilling contractors, of their own role in managing and influencing risk,” says Mr Knudsen. “The investigation into the oil leak from Statfjord A in 2008 identified failures both at the operator and among the contractors involved. “We followed up with orders directed at all those concerned, in part to ensure an integrated review, an assessment and learning across the players. “It’s crucial that serious incidents with a major accident potential receive a broad and integrated follow-up both from those involved and from industry organisations and the authorities.” Maintenance has proved a contributory cause of major incidents in the petroleum industry and other sectors, and contractors play a key role in ensuring that such work is done in a way which avoids accidents. The PSA has accordingly followed up risk factors related to maintenance work in the industry for a number of years. ATTENTION A survey by the Sintef research foundation for the PSA found that maintenance contractors pay far more attention to incidents with a major accident potential than to less serious events. “We nevertheless receive constant feedback from contractors about operators who use lost-time injuries as criteria when awarding contracts,” says Mr Knudsen. “At the same time, the employees argue that many contractors still pay most attention to individual and minor injuries in their safety work.” He says that contractors often claim to have difficulties influencing frame conditions which could affect the risk of serious accidents. “They have an important point when they identify long-term contracts with operators as essential for collaboration and for efficient learning and improvement over time. “This was also confirmed for us through another study on the significance of frame conditions for HSE work, again carried out by Sintef on our behalf last year.” Mr Carlsen emphasises that the PSA is constantly seeking dialogue and contact with industry segments and interest organisations for operators, contractors and their personnel. “These contacts influence our own understanding of the risk picture, and thereby our supervisory priorities. At the same time, we’re developing a greater degree of shared understanding between those involved.” Escape inquiry A gas leak on the Statoiloperated Gullfaks B platform in the North Sea this December is the subject of an investigation by the PSA. The outflow occurred during leak testing after maintenance work on a well, and involved gas trapped in the well between the downhole safety valve and the Xmas tree. Lasting about an hour, the incident involved an initial leak rate of 1.3 kilograms per second and released some 800 kilograms in all. Nobody was injured, but the leak created a serious condition on the installation. The PSA investigation had not been completed when this issue went to press. Its report will be posted to www.psa.no in due course. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 41 A CLOSE CALL DOWNHOLE Under slightly changed circumstances, a well control incident on the Statoil-operated Gullfaks C platform in the North Sea could have developed into a major accident. By ØYVIND MIDTTUN Problems had arisen with the same producer in December 2009 and March 2010 before the most serious incident occurred in the afternoon of 19 May 2010. Control of pressure in the C-6A well was suddenly lost, the mud column vanished, and the alarm was sounded. “This event was very serious,” emphasises PSA supervision coordinator Hanne Etterlid. “Under only slightly different circumstances, it could have turned into a major accident.” Work on restoring control over C-6A and re-establishing its downhole barriers lasted for more than two months. DEFICIENCIES The PSA’s investigation of the incident identified serious deficiencies in Statoil’s planning of the drilling and completion operation in this well. Management checks that activities were being conducted satisfactorily were also inadequate. These shortcomings related to key conditions such as risk management and change control, as well as experience transfer and the application of expertise. 42 Familiarity and compliance with the operator’s own governing documents as well as documentation of decisions taken were also found to fall short. These serious findings resulted in a far-reaching order to Statoil, including a requirement to review and assess processes related to well work on Gullfaks. “It’s important for us that all aspects of the order are assessed and dealt with, so that specific improvements result,” emphasises Ms Etterlid. “That includes Statoil achieving genuine learning and experience transfer, both on Gullfaks C and on other installations where necessary.” MEASURES The company was also required to establish why measures initiated after the serious gas leak on Snorre A in 2004 failed to have the desired effect on Gullfaks. “We take the view that the C incident could probably have been avoided if Statoil had learnt from earlier mistakes and drawn on available expertise in-house,” comments Ms Etterlid. “A key job for the company is accordingly to find out why it has failed to apply the lessons provided by earlier incidents.” The PSA has questioned whether Statoil is making sufficient effort to seek out and evaluate the underlying causes of the errors made. RELIEF The Gullfaks C incident has also helped to illustrate the challenges posed in complying with the regulatory requirement on drilling programmes for relief wells. According to the regulations, such plans are required for every well drilled on the NCS. The operator must keep them updated in line with reservoir changes and new technology or methods. The PSA intends to monitor the industry’s work both on relief wells and on overall strategies for emergency response to downhole problems. No grounds for well complacency Wells cannot be treated lightly. Every one of them needs to be cared for properly, or they can cause trouble. By THOR GUNNAR DAHLE Over 4 500 exploration and production wells have been drilled on the NCS to date. Names and goals may differ, but all share one feature – they are far more than a simple hole in the ground. Like fixed installations and other petroleum industry facilities, wells need to be maintained and monitored to prevent faults and incidents. The most critical components are valves, seals, tubular joints and similar equipment. External barriers – entrenchment in the geological formations – are also very important for safety. And corrosion and erosion present major challenges over time. CAUTION Although Norway has a good history for serious accidents caused by well leaks and failures, PSA principal engineer Arne Mikael Enoksen urges caution in resting on one’s laurels. “At the same time as their number is rising, wells on the NCS are getting older,” he points out. “The industry has an important job to do here. “Developing and adopting methods and equipment which can effectively monitor well condition and spot leaks and failures as early as possible is a demanding business.” He reports that an extensive PSA study of data from more than 400 selected wells in 2004 found that 18 per cent – a high proportion – faced challenges from leaks and barrier failure. “About the same time as this work was launched, we experienced the very serious blowout on Snorre A in the North Sea, when large volumes of gas flowed from the seabed just under the platform. “This incident demonstrated with full clarity the possible consequences of a well leak, and gave an extra boost to work on this issue.” EXTEND Confronted with the facts from the PSA’s review, the industry undertook in 2007 to extend the project by establishing an overview of and categorising well status. More than 1 700 wells have so far been subject to this evaluation, and the results obtained are also included in the PSA’s annual RNNP report. Mr Enoksen is pleased that the industry has established a special Well Integrity Forum (WIF), involving eight key production operators with the PSA as an observer. “This body holds regular meetings,” he notes. “An important job is the development of “stoplight” criteria – categorising possible well problems by character and seriousness, so that corrective measures can be applied in the right place and at the right time.” GUIDELINES At the WIF’s suggestion, the OLF has now prepared well integrity guidelines. These cover a wide range of important factors, such as education, experience transfer, barrier philosophy and stoplight criteria. “These guidelines should mean that the industry is now much better equipped to meet the challenge of ensuring that wells are intact at all times,” Mr Enoksen observes. MORE SECURELY HELD A mobile unit which fails to stay put when required presents a substantial risk. So systems for anchorhandling or positioning must be trustworthy. By THOR GUNNAR DAHLE Floating installations as well as rigs and ships are held in place with the aid of dynamic positioning or by mooring to the seabed. Any failure of such systems may have serious consequences. Drilling rigs or production floaters can have their connection with subsea equipment destroyed or damaged, with a potential loss of well control and the risk of a blowout. Losing position also poses the threat of a collision with other facilities, offering the possibility of a major accident as well as extensive material losses. FEW While the PSA registered a worrying increase in mooring-related incidents some years ago, its initiatives and industry action have reversed this trend and few such events were recorded in 2009-10. However, further improvements to mooring systems are still needed in order to reduce the risk contribution of incidents like this to an absolute minimum. Failure of winch brake systems has caused most of the undesirable incidents, and improvements are needed here on existing mobile units on the NCS. Certain of these vessels have also failed to adopt the best available solutions. New regulations impose tougher and more integrated requirements in this area. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 43 5 By ØYVIND MIDTTUN The PSA has manoeuvred the acknowledgement of compliance (AoC) onto the NCS with a firm hand. This scheme is now securely anchored as an important tool for monitoring mobile units. FLOATING A very ambitious approach was taken by the PSA in the late 1990s when it launched a trial with a process for advance approval of mobile units, better known today as the AoC. But the question was whether it would be possible to create a scheme which could clarify responsibility and make the consent process more efficient. At the same time, the PSA wanted the AoC to reduce bureaucracy, make roles clear and establish greater predictability. DISCUSSED A system of this kind had been discussed in various contexts, and the decision to establish it on a trial basis was accordingly welcomed. That applied particularly to the rig contractors, who had long been pressing for a more predictable system. Companies and unions played an active role in shaping and establishing the AoC. “Broad agreement prevails across the industry today that the aims have been met and that experience with the AoC is positive,” says special adviser Kjell-Gunnar Dørum at the PSA. He is more familiar than most with the scheme, having been present when the idea was launched, the trial period initiated and the AoC made mandatory. Over the 11 years that the system has been in place, he has also been involved with the bulk of AoC applications received by the PSA. The West Navigator drilling rig, then owned by Norway’s Smedvig, had the honour of being the AoC’s first guinea pig in 2000. 44 The AoC scheme is here to stay, say supervision coordinator Ingvill Hagesæther Foss (left) and special adviser Kjell-Gunnar Dørum. ON TRUST 5 Since then, applications for such recognition have flowed in at a steady pace, and a total of 42 units were covered by an AoC at 1 January 2011. It should be noted that the AoC does not represent an approval. RANGE The scheme was aimed at achieving a range of improvements, which included helping to describe the rig contractor’s responsibilities and their interface with the operator’s duties. An AoC was also intended to contribute to making contractors more responsible, and encouraging more direct contact between them and the PSA. In addition, it would boost efficiency for contractors, operators and government by underpinning both applications for and consideration of consents concerning units with AoCs. The system was furthermore intended to provide greater predictability for the contractors with regard to regulatory requirements and their own management. And it would facilitate the movement of mobile units between fields and operators on the NCS, and ultimately between countries in north-western Europe. PARTICIPATION The introduction of the AoC has contributed to greater participation by as well as better knowledge of the regulations among employees. At the same time, rig contractors have gained increased expertise about the units they own and their technical condition – which has also seen a general improvement. RESPONSIBILITY The rig contractors are responsible for ensuring that their organisation and management system as well as the technical condition of their units accord with the rules at all times. They also have a duty to measure compliance, and must be able to S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 45 5 document that the regulatory requirements have been met. This is checked by the authorities, in part through audits. “Trust is the key word here,” says PSA supervision coordinator Ingvill Hagesæther Foss. “When we’ve awarded an AoC, it means we rely on the contractor to live up to their responsibilities.” LONG TIME Everyone who has applied so far has eventually received an AoC, but the process has taken a long time in some cases. Normal consideration lasts three months, assuming that: • the application has the expected content and quality • the necessary compliance checks have been conducted in relation to the regulations • the necessary analyses and verifications have been performed • complete lists of non-conformances have been compiled, with reference dates and timetables for corrective action • employee participation has been genuine and is documented • the unit is available for inspection by the PSA. Longer consideration could mean the application is poorly based, the unit’s condition is unacceptable, or the operating organisation and management systems are deficient. “We’ve seen a number of examples in recent years where people have failed to understand the work involved in building up a company and introducing a new unit to the NCS,” says Ms Foss. Time-consuming processes mean increased use of resources for the PSA, and also impose additional costs on the AoC applicant. CHANGES The player picture on the NCS has changed significantly since the system was introduced, with more than 50 companies entering. Whether the AoC process might have helped a number of them to accept the demanding job of serving as an operator is a question that remains to be answered. Ms Foss merely notes that both operators and rig contractors are positive. “Contractors have both received and accepted more responsibility. They’ve had to roll up their sleeves. And we must suppose that this has led to safer operation.” Figures from the PSA’s RNNP process are positive. Results for mobile units have clearly improved in several areas during recent years, including major accidents, personal injuries and noise. “We hope this trend will continue,” Ms Foss comments. Requirement MANDATORY SINCE 2004 An AoC is a requirement which a mobile unit must fulfil before it can work in the petroleum sector on the NCS, and is mandatory today for vessels listed in a ship register. It serves as a statement from the PSA that the authorities are confident the unit can conduct petroleum operations within the framework of the regulations. Launched in 2000 as a voluntary arrangement for mobile drilling rigs on the NCS, the AoC became mandatory in 2004 and was expanded two years later to include various other types of units. These include flotels, vessels for production, storage and offloading or for drilling, production storage and offloading, and well intervention ships. AoC on the web: see www.psa.no/aoc 46 THREE ACKNOWLEDGED AoCs were awarded by the PSA in 2010 to three new mobile units: • Flotel Superior (flotel) • Island Constructor (well intervention vessel) • COSL Reval (flotel) The last of these was originally called Port Reval, and the AoC was given to COSL as the new operations organisation. In addition, COSL Rigmar – another flotel, earlier known as Port Rigmar – formally received a new AoC in connection with the change of name. LIFTING SAFETY Heavy objects which fall onto the drill floor – often with crew close by – represent an unacceptable risk. The PSA has called on everyone involved to make a collective effort to end such hazards. By OLE-JOHAN FARET A wide-ranging order was issued to Statoil by the agency in April 2010 after a serious lifting incident on the Heidrun field in the Norwegian Sea. Also referring to seven earlier cases when heavy drill floor equipment had dropped, it required the company to review and improve lifting gear and routines in all its drilling operations. But another incident occurred in late December, when a 23-tonne slip joint fell five metres to the deck on Njord A. Nobody was hurt, but the person in charge of the lift was close by. Statoil is operator of this Norwegian Sea platform, while drilling contractor KCA Deutag owns and uses the mechanical handling equipment. “This event could easily have had a tragic outcome,” says Sigurd Førsund, who heads the PSA team appointed to investigate the accident. Closely involved in the numerous mechanical handling incidents which have occurred on the NCS over many years, he is at a loss to explain why the industry fails to achieve noticeable improvements. “One reason has been a widespread attitude that ‘as drillers, we drill – we don’t do lifting’,” he suggests. “But the truth is that perhaps as much as 80 per cent of what happens on the drill floor relates to lifting. That makes it important to apply the appropriate expertise.” Mr Førsund emphasises that heavy equipment coming loose over the drill floor represents a problem which the whole industry must take seriously. There have also been a number of serious incidents in addition to those involving Statoil as operator, he adds. The seriousness of the position is underlined by statistics which show that nine out of 10 fatal accidents on the NCS since 1994 relate to lifting operations. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 47 Putting the facts in place The technical basis for managing activities in parts of the northern NCS was revised in 2010, with the PSA providing input on safety and the working environment in the petroleum sector. By OLE-JOHAN FARET An updated version of the integrated management plan for the Barents Sea and the Norwegian Sea off Lofoten (BHL) is due to be submitted in a White Paper before the end of March. Many government agencies and scientific teams have contributed updated mapping, research and monitoring data about the environment, resources, value creation, oil spill risks and the human impact on the ecosystem in these waters. The PSA has served on the risk group and the technical forum, two of three teams – the third being the monitoring group – set up to strengthen the knowledge base for the plan. These delivered a collective report last April to the Ministry of the Environment, which is coordinating the work. The PSA has also posted supporting technical papers to its own website. Among the agency’s technical contributions were descriptions of possible blowout scenarios, based on available knowledge and experience. This information related to the petroleum sector, the NCS in general, the BHL area in particular, accidents and the management of such mishaps. The blowout scenario for the BHL region was selected from a combination of flow rates, durations and oil properties which is unfavourable from an overall perspective. Following the Deepwater Horizon disaster last April, the risk group was asked to evaluate the technical conclusions drawn for the BHL plan in the light of this Gulf of Mexico incident. Extensive assessments made in the PSA’s jurisdiction included risk conditions related to acute discharges, and likely discharge scenarios in terms of rates, duration, volumes and so forth. Given what is known so far about the Gulf of Mexico incident, the PSA found no technical arguments to justify significant changes to the factual basis for the BHL management plan. Read more at www.psa.no/environment. RUNNING SECURELY The Kårstø gas processing plant near Stavanger – the largest facility of its kind in northern Europe – celebrated its 25th anniversary last year with praise for safe operation. 48 Kårstø – the town which never sleeps. SPOTLIGHT ON SPILLS The annual RNNP process pursued by the PSA was extended last year to include the risk for acute discharges of oil and industry-related chemicals to the sea. Aimed at measuring and improving HSE conditions in the petroleum sector, the RNNP serves as a key source of information for the PSA and the industry on risk trends in a number of areas. This process has previously focused primarily on major accidents, work accidents and selected working environment factors. In 2010, however, its measurements were further extended in order to cover developments in the risk of acute polluting spills on the NCS. The study utilised part of the existing data in the RNNP as well as information from the Environment Web database maintained by the Norwegian Climate and Pollution Agency (Klif ). Risk in this context is confined to frequencies and volumes of acute discharges, and no assessment has been made of actual or potential environmental harm. Presented last November, the RNNP report on acute discharges in 2001-2009 provides an important supplement to the factual basis for setting accident prevention priorities. The PSA aims to publish two RNNP studies “We’ve seen a marked decline in serious incidents at Kårstø since 2004,” reports Kjell Arild Anfinsen, the PSA’s supervision coordinator for land-based plants. “The difference in figures between the major development projects in 2005 and 2010 demonstrates that clearly, but the general trend over time has also been positive.” In his view, a crucial reason for this progress rests with operator Gassco – along with technical service provider Statoil, which is responsible for day-to-day work at the plant. They have understood that continuity and great attention to safety are essential for achieving improvements. “The organisation has frequently shown that it has a good attitude to HSE work,” notes Mr Anfinsen. “It doesn’t assume that good annually, with the regular report appearing as usual in the second half of April and results for acute discharges presented in the autumn. This separation of publication dates reflects the fact that Environment Web data first become available in May each year. Read more at www.psa.no/risk levels results today say anything about what’ll happen tomorrow.” Kårstø’s good safety progress has been confirmed by a number of awards, including the PSA’s HSE prize. This was presented to Vidar Bernt Sørensen, head of the plant’s HSE24 training programme, at the ONS 2010 oil show in Stavanger last August. S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 49 UNDER A COMMON CODE Norway’s petroleum sector operated until this year with separate regulations for offshore and land-based activities. A single regime has now been put in place. New HSE regulations for oil and gas operations under the PSA’s jurisdiction came into force on 1 January, unifying the rules for operations at sea and on land. With work on the change under way since 2004, its purpose has been to achieve a more integrated regulation of the Norwegian petroleum sector. The regulations with guidelines are available in Norwegian and English at www.psa.no. Assigned on emission role The PSA has been picked to serve as the safety regulator for carbon capture, transport and storage. At the request of the Ministry of Labour, the PSA has initiated work to identify any necessary changes to the HSE regulations for petroleum activities. These came into force on 1 January, and the possible amendments would extend them to include safety and the working environment related to carbon management. Norway has two large gas-fired power stations, at Kårstø north of Stavanger and Mongstad near Bergen. Both fall within the PSA’s jurisdiction. Plans have been drawn up for capturing, transporting and storing carbon emissions from these facilities, and a test centre for the necessary technology is being built at Mongstad. Changes proposed to the regulations will be the subject of a public consultation during the spring. CHANNEL FOR COMMUNICATION The petroleum industry is an international business involving many English speakers, so the PSA publishes the bulk of the material posted to its website in both Norwegian and English. That applies to all investigation reports, summaries of audit reports, articles about notifications of orders and orders, brief announcements of consents and AoCs, and circulars to the industry. Information is published on the PSA’s website after the company concerned has received the documentation. During 2010, materials published included: • 85 articles on consents (Norwegian and English) • 100 articles on audit results (Norwegian and English) • six articles on completed investigations (Norwegian and English) • 29 articles on notification of orders or orders issued by the PSA (Norwegian and English) • four articles on units which have received AoCs (Norwegian and English). Read more at www.psa.no/audit. 50 S A F E T Y - S TA T U S & S I G N A L S PSA 2010-2011 51 52