Arctic Council Recommended Practices Prevention Project (RP3)

EPPR RP3 report – Summary from the Arctic Council review August 31
– Sept 28, 2012
As previously articulated, there needs to be a section that describes the methodology and interview
process and more importantly, a final section on findings and analysis (specifically based on the 4 key
topics). The objective for DNV was to develop recommended practices for oil spill prevention in the
Arctic, and we feel this has not been achieved.
The report as a whole does not tie together key findings of each initiative described in a way that is
helpful for the reader, rather, it is a synopsis of individual undertakings, investigations, tools and
research papers. The executive summary, while it was the only place which attempts to weave
common elements of each initiative together, does not reflect what has been described in the rest of
the document.
Five of the eight bulleted "findings" contained within the executive summary are standard elements
of a management system and should not be presented as separate issues (these included: hazard
identification, risk mitigation, implementing an HSE system, training and competency issues,
continuous improvement, and reporting). While there may be specific elements of a management
system which require greater scrutiny in the Arctic context (e.g. risk identification or training and
competence), EVERY element must be accounted for in an operator’s system.
Chapter 10 on management systems focuses on occupational health and safety rather than process
safety. As discussed in detail throughout the reports which precede this Chapter, and in various fora
of the Arctic Council, this approach to safety performance measurement has principally two shortcomings:
it places an inordinate amount of attention on “slip, trip, and fall” hazards, which may limit
awareness of other hazards and risks that need to be managed in order to protect the public
and the environment
it is one-dimensional and provides an incomplete and inaccurate account of the overall level
of safety of an activity, a facility or organization
Table 5-1: Some key statutes and regulations in Arctic waters
Faroe Islands
Statuation/regulation title
- Faroese Act on Safety at Sea
- Faroese Act on Hydrocarbon Activities
- Faroese Act on Preparedness
- Faroese Act on Protection of the Marine Environment
5.1 Arctic Countries´ regulatory regimes, key statutes and regulations
5.1.1 Faroe Islands (Denmark)
Faroese law regulates the maritime sector of the Faroe Islands. The principal legislation being the
Faroese Act on Safety at Sea. The Faroese Maritime Authority has contracts with some class
companies to carry out surveys on Faroese-registered ships.
Hydrocarbon and mineral resources and resource activities in the Faroese subsoil are regulated
domestically by the Faroe Islands. The Faroese Earth and Energy Directorate (Jarðfeingi) is the
regulatory authority. The principal statutes intended to prevent oil spills are the Faroese Act on
Hydrocarbon Activities (which regulates prospecting, exploration and exploitation of mineral
resources on the continental shelf of the Faroe Islands) and the Faroese Act on Protection of the
Marine Environment. This Act aims to prevent and reduce pollution of the marine environment from
ships, aircraft and floating and fixed platforms.
In regard to Ole Kristians email from 31. august 2012 where comment on the EPPR R3 report were
encouraged, Iceland announces that it is not providing any comments at this time.
Bestu kveðjur, Best regards
Gottskálk Friðgeirsson
Fagstjóri, Senior advisor
Svið umhverfisgæða, Department for environmental quality
Norwegian Petroleum Safety Authority (PSA)
5.1.5 Norway
Section 1, line 2: Earlier Norway had The Ministry of Labour and Social inclusion. Today we have The
Ministry of Labour
Section 1: Suggest that PSA is presented as in the PSA-web, and to keep the sentence describing the
six disciplines):
“The Petroleum Safety Authority Norway (PSA) is responsible for developing and enforcing
regulations which govern safety and working environment in the petroleum activities on the
Norwegian continental shelf and associated land facilities.
The regulations assume that the activities maintain prudent health, environmental and safety
standards. They are developed to be a good tool for the industry and for the authorities' supervision.
Therefore, the regulations contain a large degree of functional requirements where standards and
norms specify the regulations' level of prudence.
In this manner, the challenges that follow from continuous change processes in a complex industry are
Section 2, line 3: New regulations relating to health, safety and the environment in the Norwegian
petroleum activities on offshore and onshore facilities that are subject to the Petroleum Safety
Authority (PSA), entered into force 1 January 2011. For further information see PSA’s web.
The five main regulations areas are:
 Regulations relating to management and the duty to provide information in the petroleum
activities and at certain onshore facilities (The managements regulations)
 Regulations relating to conducting petroleum activities (The activities regulations)
 Regulations relating to design and outfitting of facilities, etc. in the petroleum activities (The
facilities regulations)
 Regulations relating to health, safety and the environment in the petroleum activities and at
certain onshore facilities (The framework regulations)
 Regulations relating to technical and operational matters at onshore facilities in the
petroleum activities etc. (Technical and operational regulations)
For more information see the PSA-web
7.1.2 Risk level in Norwegian petroleum activities
Line 1: Suggest to use this sentence from PSAs web: “The PSA has adopted a set of main priorities
where action will have the biggest impact and which call for special attention. These focus on
management, technical and operational barriers, preventing environmental harm and groups
particularly exposed to risk.” And keep the three bullet points as they are.
Existing experience, section 7.
Satellite technology is increasingly becoming an important operational tool in the Arctic. This
includes both the use of satellite imagery, particularly from radar satellites capable of collecting
images of the Earth’s surface independent of light and/or weather conditions, and non-imaging
satellite technology such as satellite-AIS and for communications. The high Arctic latitudes are
covered by every orbit of a polar orbiting satellite, and each orbit is accessible via the satellite
infrastructure located in the circumpolar Arctic. The main advantage of satellite monitoring
technology is hence the repetitive, large area coverage and the near real-time provision, i.e. within
30-60 minutes, of reliable information about ice conditions, oil spills, and vessels to the end-user.
During recent years new approaches for satellite data and information sharing has been
implemented by the satellite owners and service providers. This allows the users to coordinate their
monitoring requirements and to share the associated costs. As a consequence the effective costs per
user have come down to a very competitive level when compared to traditional means to provide
access to the required data and information. The integrated and co-ordinated use of satellites in
combination with traditional surveillance means like aircrafts and vessels is therefore recognized as a
totally cost-effective monitoring and surveillance system. The operational deployment of traditional
resources, such as vessels or aircraft, is done so based on a tactical use of satellite derived
information. This allows the established resources to be used more effectively by directing them
directly to a feature or target initially observed by the satellites.
Norway and Canada have led the implementation of satellite technology for operational monitoring
the Arctic, first with ice and oil spill services and are now integrating ship traffic monitoring purposes.
Today, other Arctic countries, including Denmark, Finland and Sweden, are regular users of satellitebased services for maritime purposes. In Europe, since 2006, the European Maritime Safety Agency
(EMSA) implemented a regular oil spill monitoring service based on a co-ordinated use of satellites
and traditional surveillance means. The European waters are covered on a daily basis by radar
satellites and oil spills that are detected are reported to EMSA within 30 minutes after the satellite
overpass. The implementation of satellite oil spill monitoring has had an impact on the number of
reported oil spills with EMSA reporting (EMSA Annual report 2011) an overall indication in the trend
of detections through a reduction from 1.38 spills per applied satellite image in 2009 to 0.71 spills in
In Norway there is a shared responsibility on coverage and mutual exchange of information from the
satellite-based monitoring service between the Norwegian Coastal Administration (NCA) and the
offshore oil industry. The NCA is responsible for the coastal waters while the offshore industry
performs a regular monitoring and surveillance of the offshore oil fields. The NCA also has a similar
agreement with EMSA for a shared responsibility of the Norwegian coastal waters.
The integration of operational satellite-based services with traditional monitoring operations has
resulted in an improved cost-effectiveness for oil spill detection, ship traffic monitoring and ice
applications. Satellite continuity will exist through future missions including the GMES Sentinels from
2013, the Canadian Radarsat program from 2016 and satellite-AIS missions.
R&D programs and activities focusing on stronger integration of satellite and other technologies are
being conducted by the Arctic countries and this will assure the availability of new and improved
services in the future. The GMES Sentinel satellites will implement a free and open data access, and it
is also expected that the data and pricing policies of the other relevant missions will become
modified towards a more GMES-like policy. This will assure the future availability of data and
information services for the service providers and end-users at even more favourable conditions than
today. It is therefore recommended that the Arctic Council takes a dedicated responsibility to
establish activities focusing on using satellite technologies for operational surveillance related to oil
spills, vessels and ice in the Arctic region. These activities should also b co-ordinated with initiatives
including the Norwegian Barents Watch , the EU Arctic Information Centre, and also provide input on
operational data requirements from the GMES Sentinels.
Page #
Section #
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General: ISO standards discussion dominate. Correlation to
American Petroleum Institute (API) Recommended Practices
(RP) and other countries arctic specific standards may be
useful. Example: API RP 2N Planning, Designing, and
Constructiong Structures and Pipelines for Arctic Conditions is
technically identical to ISO 19906 Arctic Offshore Structure.
General: Executive summary should be revised to describe
Arctic-wide recommendations for oil spill prevention or outline
next steps to distill this review into general guidance for best
practices. As written, the draft report presents the collective
building blocks (baseline) for this foundation but the next steps
for action are not clearly articulated.
It is assumed this is one of the objectives of the October 5-6
EPPR meeting.
General Comment: Consider presenting the Executive
Summary prior to the Introduction in consideration of the order
of informtion presented.
General Comment: The role of the Arctic Council and its
Working Groups are nicely described within; however, this
information is buried in the report. Consider presenting this
information in the Introduction.
Boxed information: Consider re-evaluating use of text within
boxes. What is purpose? Hard to read. They appear to be
distracting vice organizing.
Executive Summary: Currently, recommendations are scattered
throughout this section. It will be more reader-friendly to
summarize the recommendations in one paragraph. For
(1) Establishment of a R&D, experience, and multi-discipline
reference database for information sharing;
(2) Development of new EPPR website as a tool for
outreach and communication;
(3) Formulation of a goal-based rule when technology based
rules and regulations are not available;
(4) etc.
In definition of "best practices"; change "pollutants" to "oil".
This provides consistency with same definition on page 6.
Modify 3rd bullet to read: "Requiremenrts for training and
minimum competence to aid in development of best workforce
and personnel practices"
Note: This is in line with the discussion at section 9 Human
Resources and Competence
Modify 5th bullet to read: "Implementing robust hazard/risk
mitigating actions with strong accountibility over the hazard
registry status"
Note: This is in line with the discussion at section 10.4 Barrier
Add bullet to read: "Develop strong operations and
maintenance routines and checklists to aid in hazard mitigation
and barrier management"
Add bullet after bullet 4 to read: "Define minimum requirements
for a strong HSE system (e.g. HSE systems should include, at
a minimum, the following elements: Hazards Analyses;
Management of Change; Operating Procedures; Mechanical
Integrity of Critical Equipment; and Emergency Response and
Note: The PAME HSE project was to facilitate identification of
critical elements of an HSE system.
Add bullet to read: "Ensure oil and gas facilities and associated
equipment are adequately cerified for operations in subfreezing temperatures and potential interaction with sea ice"
Add bullet to read: "Incorporate leak detection and in-line
inspection systems for pipelines associated with oil and gas
Modify best practices definition by replacing the words
"completely eliminating" with "significantly reducing". . . Its not
possible to completely eliminate the potential for a accidental
Modify prevention systems to read as: Prescriptive hardware
and operational requirements for safe operations, . . .
This report is a good reference document. Accordingly,
recommend expanding Table 5-1.
Table 5-1: Russia row has a typo in the first bullet : "Law of
Environmental Protection"
Canada paragraph: typo is "hipping" should be "shipping"
Recommend rewriting this section to discuss the specific
legislation/regulations in Table 5-1 including deleting 1st
sentence: "The United States have not enacted specific
legislation or regulations for Arctic shipping that applies
requirements beyond generally accepted international rules
and standards."
This will align more with the other country paragraphs in this
Move 5.3.1 & 5.3.2 to under Section 6.1 as PAME is an Arctic
Council Working Group
Section 5.4 describes Canadian process; however, at 5.4.2 the
cited 30 CFR Part 254 is a U.S. regulation for Oil Spill
Response Requirements for Facilities Located Seaward of the
Coast Line. Does Canada cite this U.S. regulation for its
contingency planning or is this an incorrect citation?
In section title, add "U.S." in front of BSEE.
Bering Straits Port Access Study: recommend CAPT Adam
Shaw be referred to by position vice name.
Use: "Point of contact is the U.S. Coast Guard District 17 Chief
of Prevention."
Add statement at end of section stating: "Note: The U.S.
Bureau of Safety and Environmental Enforcement (BSEE)
enacted new regulations to implement the recommendations of
these studies. These regulatory changes are described at
section 7.3.1 of this report.
Incorporate new section and title as " U.S. BSEE" at
beginning of third paragraph under 7.3.1 (just prior to "The
Macondo well blowout ..."). Revise current BP to, etc.
Move reference footnotes at bottom of page to list of references
starting on page 85.
text box
lines 7-9 from
top of page
Delete "however, the vessel will most likely hit the bow or fore
part of the bottom structure first….navigational failure" - this
may not be accurate for example currents can push vessels
from any direction.
3rd line form
bottom of
after …" oil discharged to the sea" add ", securing the source"
2nd sentence
from bottom of Before "blowout" add "uncontrolled"
section 12
Text is cut off at bottom of text box.
Change 2nd bullet to read: "malfunction of equipment due to
lack of proper operation and/or maintenance".
Recommend providing additional background - somewhat
confusing as to what the source and purpose was of
questionnaire. Also add how many people completed it.
Recommend deleting Appendix IV.