North Sea Offshore Authorities Forum

Transcription

1 North Sea Offshore Authorities Forum REPORT OF THE RESULTS OF THE 2001 / 2002 THEME AUDIT PROGRAMME State Supervision of M ines

2 NSOAF Multi National Theme Audit 2001 / 2002 Composite Report 1. Introduction 2. Management Summary 3. Common Findings 4. Areas of Concern 5. Conclusions Appendix 1 - Terms of reference for the NSOAF International Theme Audit Programme of Mobile Offshore Units rev 05 dated 06 Jun Explanation of Entries to the Table in Section 3 from HS(G)65 Successful Health & Safety Management. 3 - Internal Audit Evaluation of NSOAF Multi National Theme Audit Pro s and Con s 4- Draft Letter to the North Sea MODU Owners (or equivalent) References 1- HS(G)65 Successful Health & Safety Management 2 - Audit report from Netherlands & Germany 3 - Audit report from UK 4 - Audit report from Norway 5 - Audit report from Denmark 6 - Draft letter to MODU owners and associated trade bodies Feb 2003 Page 1 of 16

3 1. Introduction Appendix 1 outlines the terms of reference under which a series of national theme audits were conducted by four of the regulatory bodies of NSOAF for the year 2001/2002. The key themes selected for theses audits were lifting equipment and lifting operations, falling objects from heights and manual handling. Each national team conducted individual audits and submitted a separate report for consolidation into this composite report. The common standard and methodology for the audits was the UK publication by its Health & Safety Executive HS(G)65 Successful Health and Safety Management, reference 1. A common set of audit questions were developed jointly by the international team and the national teams for their parts of the programme then used these. 2. Management Summary The objectives set in the terms of reference were achieved. All the participating lead auditors were able to attend an initial planning meeting, jointly develop the audit question set and methodology, and attend a preliminary review meeting to analyse the findings and consider common areas of concern. All participants and their colleagues in each country are thanked for their positive and proactive co-operation to the audit programme. All teams followed the agreed format of onshore briefings and evidence gathering followed by offshore briefings and evidence gathering. Each separate audit was concluded by the team with a feedback / review session with relevant company personnel. Opportunities were taken at the review sessions to feedback both the positive and negative evidence of compliance with good safety management systems. In every case the teams reported company personnel at all levels had been co-operative and contributed positively to the audit process. The feedback sessions were well received by company staff who indicated they had been worthwhile with outcomes they would be able to action to improve their existing safety management systems. Good communications links were established between the participating lead auditors, which assisted setting up of the audit process, interchange of information between the teams during the process and the preliminary review meeting to analyse the results. (Continued.) Feb 2003 Page 2 of 16

4 A common format was agreed to obtain a consensus view of the evidence recorded against the following management activities and headings: - Policy statements Objectives & Goals /Themes Organisation Interfaces Communication Training Competence Assurance Procedures & Working Instructions Planning Operations Preventative Maintenance Routines Inspections Measuring Performance Audits Review The companies who participated in the audit programme were: - Ensco (Netherlands & Germany) Transocean Sedco Forex & Maersk Contractors (Denmark) Santa Fe & Diamond Drilling (UK) Saipem & Dolphin (Norway) 3. Common Findings Evidence obtained from the audits was considered at the review meetings and mapped on to the key elements as defined in reference 1. The level of marking is the overall impression from the audits. There were differences from company to company and from installation to installation at the individual entries. A negative finding would have resulted from several deficiencies on follow up / review and continuous improvement loops. (See Table Overleaf) Feb 2003 Page 3 of 16

5 Policy statements Objectives & Goals / Themes Organisation Interfaces Communication Training Competence Assurance Procedures & WI s Planning Operations Preventative Maintenance Routines Inspections Measuring Performance Audits Review Definitions of rating: ++ All controls in place and fully implemented + Acceptable, sufficient controls and implementation demonstrated but room for improvement - Essential level of controls or implementation in place, but improvement required. - - Not acceptable, essential controls missing or no implementation demonstrable 4. Areas of Concern During discussion and analysis of the common findings shown in tabular form in section 3 the audit team have identified the following as areas of concern: - 1. Policy Objectives and Goals, Interfaces: - Corporate safety policy is generally well understood by onshore staff particularly at senior Feb 2003 Page 4 of 16

6 level and this understanding diminishes as you pass down the company structure with the least level of understanding claimed by those who carry out the tasks offshore. There appears to be a discontinuity between the onshore and offshore in respect of corporate safety policy and its adherence. In addition the offshore work force claim they do not have as much involvement in or influence on corporate safety policy, as they believe they should. 2. Organisation:- Senior management have underestimated the time and resources required to perform supervisory duties. Levels of effective supervision for lifting operations were generally considered to be sub standard. 3. Competency Assurance:- Lack of regular or systematic verification of continuing competency of company staff, contractors and independent third parties persons. 4. Planning / Operations:- Where high turnover of staff particularly amongst deck crew and drilling staff occurred this was a problem that directly impacted on the effectiveness of management activities. 5. Planning:- Execution of effective risk assessments particularly in respect of lifting operations. This was emphasised in several instances by failures to consider inherently safer options for conducting lifting operations and associated tasks 6. Preventive Maintenance Routines:-Maintenance and routine inspections for lifting equipment were generally well defined with systematic schemes of maintenance in place. However evidence from staff offshore on several of the installations indicated the delivery, operation, effectiveness and commitment to these maintenance procedures comes second to the need to sustain drilling activities and other operational priorities. 7. Measuring Performance and Review :- There is a need for companies to be more pro-active to develop performance standards and for senior management to review these and ensure appropriate action is taken when delivered perfromance is unsatisfactory. 8. Audits:-It was evident that there is a greater need for more effective and regular auditing of activities by senior management or commitment by them to close out outstanding actions from previous internal safety audits and inspections that have been carried out. 5. Evaluation of the Audit The goal of the NSOAF audit was to carry out national theme audits referenced to a common basis prepared on the background of the HSE Feb 2003 Page 5 of 16

7 document Successful health and safety management. The individual results were to be communicated into the multinational work group for comparison and transfer of experience gained. In broad terms the goals have been achieved. All the planned national audits have been carried out, and joint meetings have provided the arena for exchange of national experience. The results clearly indicate that we do face common problems and that we to a large extent have been able to identify main areas of concern. It is considered that a further development of the multinational authority cooperation would be beneficial to all parties. The industry and the unions have their arenas for joining forces in their work for developing their industry, and the authorities have, through the cooperation within NSOAF, a similar tool for improving our work. Based on the experience gained from this audit, the following recommendations are made to improve the outcome of future NSOAF audits: The scope for the audits should be well defined and limited to a few main areas. The questionnaires should be adjusted according to the levels audited The audits should continue as national audits based on the common scope. The necessary resources should be allocated to the audit programs to provide for planning, execution, reporting and preparing the multinational summaries within a strict timeframe. 6. Conclusions The national teams were able to effect common theme audits in each of their countries. These provided valuable information to each regulator and feedback to the companies involved for areas that required improvement. A considerable degree of consistency in the positive and negative findings were found by the respective national teams indicating that major international companies operating in different parts of the North sea have similar strengths and similar weaknesses in their management systems. No findings were found in any of the audits of unacceptable management systems in place or of essential management systems missing. No evidence was observed to indicate that any of the companies audited had all the relevant controls in place and could not improve their management systems. It should be noted that the deficiencies that were observed by the audit teams had not been revealed under normal company audit procedures indicating a generic need for more effective and robust in-house systems to be put in place. Feb 2003 Page 6 of 16

8 The audit team have concluded that a letter be send out by the NSOAF committee signed by their respective heads to the MODU owners (or equivalent) working in the North Sea and their associated trade bodies. A draft letter is attached at appendix 4. The participants found the opportunity provided by this programme for indepth face-to-face discussion and analysis of the evidence / findings extremely valuable. The review meeting also enabled some detailed discussion of recent incidents / accidents on the selected topics that had been or were being investigated by the respective teams. This exchange was most informative and the main NSOAF working group should consider more formal means of regularising, facilitating and delivering such exchanges. Further themes which could be considered for future common audits by national teams include contracting out, third part equipment, role of the duty holders /companies safety management systems audits. Future NSOAF audits should be carried out taking into account the recommendations in Section 5. Feb 2003 Page 7 of 16

9 Appendix 1 Terms of Reference for the NSOAF International Theme Audit Programme of Mobile Offshore Units Introduction Ensuring the health and safety of personnel working on Mobile Offshore Units (MOUs) is vitally important and must be a common objective not withstanding the particular locus of operation in the whole North Sea area. This is a particularly challenging objective for the industry and national Regulators alike. MOUs are characterised by the potential worldwide areas of work; different rates and intensities of utilisation, a wide age range of the current fleet and thereby also a variety of technical solutions. This could result in the application of differing standards and safety levels across national sectors in the absence of a careful comparison of the approaches by the regulatory regimes of the different North Sea Offshore Authorities Forum (NSOAF) members. Current economic and operational pressures could exacerbate the situation. All NSOAF members have their own regulatory regimes based on national expectations, legal systems and individual national cultures, but they have common objectives. Indeed, we are increasingly confident that the various regulatory regimes are very similar in practice. Continuing to work together in addition to holding regular liaison meetings will not only strengthen ties and understanding, but will also bring greater consistency to regulatory practice and standard-setting across the whole of the North Sea area. This should bring both challenge and benefit to the industry. This document sets out the framework for conducting a theme audit programme by NSOAF members, which will assist in harmonising standards, and clarifying the common expectations of the separate Regulators responsible for the whole North Sea area. Objectives Each of four individual Regulators are to conduct at least one of the selected theme audits on a nominated operator in their sector of the North Sea. Germany will assist the Netherlands with its theme audit programme. To evaluate the outcomes of the individual theme audits and prepare a composite report on the overall audit programme. To obtain further evidence of consistency of approach by individual Regulators in the North Sea. To evaluate the benefits of further targeted international collaboration. Feb 2003 Page 8 of 16

10 Scope of work The scope of work will be to perform systematic theme audits of MOU owners (or equivalent) who normally have MOUs active in two or more NSOAF member national sectors. Three key themes have been selected for this programme. These are lifting equipment and lifting operations; falling objects including falling from heights and manual handling. A national team from the Regulatory authority in which the MOU is operating will perform each theme audit in its own sector. Companies selected to be auditees and Regulatory bodies to conduct audits are: Noble Drilling & Ensco (The Netherlands & Germany) Transocean Sedco Forex & Maersk (Denmark) Santa Fe & Diamond Drilling (UK) Saipem & Fred Olsen (Norway) The NSOAF MOU Working Group has nominated an audit team co-ordinator and assistant (UK and Norway respectively). They will co-ordinate the activities of the various national audit teams and provide a composite overview report of the total activity. Individual national audit teams will provide the co-ordinator and assistant with a summary report of the findings and recommendations of their individual activities. National audit teams will have their own specific responsibilities and structure, consisting of team leaders and members. National audit teams will be expected to perform planned activities at defined locations onshore and offshore in an efficient manner to reduce the need for repetitive visits at these locations. Audit teams shall base their pre-planning, execution and reporting on recognised audit standards and on experience fed back from previous audits undertaken for the NSOAF MOU Working Group. Wherever possible meetings and discussions to determine the audit strategy etc shall be coordinated to ensure efficient use of both human and economic resources. The audit co-ordinator will be responsible for ensuring the following milestones are adhered to: - 1. Submission of terms of reference for information to the main NSOAF meeting on 7 May National teams to complete theme audits in their own sectors by 31 October 2001 and submit findings to the audit co-ordinator by 30 November Audit co-ordinator and assistant to prepare a draft composite report for the NSOAF MOU Working Group by 15 February Feb 2003 Page 9 of 16

11 4. Final evaluation report to be presented to the main NSOAF meeting during May The NSOAF member countries responsible for national and or international duties will be expected to provide the necessary personnel and resources to fulfil these requirements. International Team Assignments and Responsibilities Co-ordinator: Country: UK Responsibilities To develop an overall audit strategy and plan To identify the tasks required for achieving the audit objectives To assign defined requirements and time required for each task To assist and facilitate discussions with nominated companies To advise the NSOAF MOU Working Group of any significant obstacles encountered and advise of any impact on the audit objectives and programme To issue the final audit report to the NSOAF MOU Working Group and the audited MOU owner (or equivalent) To issue a written evaluation report to NSOAF MOU Working Group Assistant Co-ordinator: Country: Norway Responsibilities To assist the team co-ordinator To identify and prepare a list of all required documentation and reference material To correlate audit tasks and facilitate transmission of completed audit reports to team co-ordinator. To co-ordinate the preparation of the draft audit report for audit team and audited companies review and discussions Audit Team Members: Countries: Denmark, Netherlands, Germany, Norway & UK Responsibilities To co-operate with and support the team co-ordinator and assistant coordinator To organise and lead the theme audits in their sectors To nominate appropriate personnel from their own authorities to conduct the audits. To prepare audit task questionnaires as appropriate To collate audit findings, conclusions and recommendations as requested by the assistant co-ordinator. To provide contributions to the draft audit report as requested by the assistant co-ordinator Feb 2003 Page 10 of 16

12 References & Standards The common standard for all the national audits shall be HS G (65) Successful Health and Safety Management. To ensure consistency the International audit team shall prepare and issue a list of reference documents and any other relevant standards for use by the National audit teams. Feb 2003 Page 11 of 16

13 Appendix 2 Explanation of the Entries to the Table in Section 3 from HSG65 Successful Health & Safety Management Comprehensive and detailed information is document in HS(G)65. For the purposes of the audits the following key elements concentrated on: - Policy statements Effective health and safety polices set a clear direction for the organisation to follow. Objectives & Goals /Themes - Establishment of clear and concise health and safety objectives for the organisation to achieve and their context with other business objectives. Organisation - Effective management structures and arrangements are in place for delivering the health and safety policy Interfaces With other organisation and individuals whose health and safety is effected by or impinges on the organisation Communication Effective communication about health and safety coming into the organisation, flowing through the organisation and going out from the organisation. Training Training helps people acquire the skills, knowledge and attitudes to make them competent in the health and safety aspects of their work. It includes formal off-the-job training, instruction to individuals and groups and on- the-job coaching and counselling. Competence Assurance If all employees are to make a maximum contribution to health and safety, there must be proper arrangements in place to ensure that they are competent. This means more than simply training them. Procedures & Working Instructions Provision of suitable procedures and instructions to enable employees to conduct operations safely. Planning Planning is essential for the implementation of health and safety polices. Adequate control of risks can only be achieved through co-ordinated action by all members of the organisation. Operations The functioning of the organisation s business and safety objectives in day to day to practical operation. Preventative Maintenance Routines The process and systems put in place to maintain associated hardware and software measures fit for purpose. Inspections Systematic inspection of premises, plant and equipment by management, supervisors, maintenance staff, safety representatives or other Feb 2003 Page 12 of 16

14 employees to ensure the continued effective operation of workplace precautions. Measuring Performance Performance is measurement against agreed standards to reveal where and when improvement is needed. Audits The structured process of collecting independent information on the efficiency, effectiveness and reliability of the total health and safety management system. Review The process of making judgements about the adequacy of performance and taking decisions about the nature and timing of actions necessary to remedy deficiencies Feb 2003 Page 13 of 16

15 Appendix 3 Internal evaluation of NSOAF Multi-National Theme Audit Pro s and Con s. PRO S CON S 1 Effective way to stimulate MOU contractors to improve their HSE Management System and realisation 1 Common Audit questionnaire may be too academic for lower levels within the audited organisation of hardware changes on Mobile Drilling Units 2 Authority staff audit experience 2 enhanced 3 On the job training of authority staff 3 No exchange of information amongst National Audit Teams during the audit period 4 Feed back of Main areas of concerns to stakeholders (Operators, IADC, and Unions) 5 Use of one agreed audit standard (HSG65, one questionnaire and common Terms of Reference 6 Less time and money consuming than previous NSOAF Multi-national audits 7 Audit questionnaires, statistical data on lifting operations, performance data and technical issues can be used for future National Theme inspections 8 Beneficial for inter-governmental networking 9 Good exchange of information regarding theme related incidents 10 In the previous two multi-national audits, only one drilling contractor in four sectors was audited; in this MNA, seven drilling contractors were audited. 11 Image improvement of governmental professionalism towards industry and sector organisations 12 Exchange of future strategy of supervision 13 Learning points from different approaches by the industry 4 It is more difficult to review and agree joint finings between National Audit Teams. Consequently it takes longer to produce the final report. A selection and comparison of safety critical areas at a more detailed level within the audit themes could have given information on common problem areas, and hence a common knowledge and ground for further harmonised regulation. Feb 2003 Page 14 of 16

16 Appendix 4 Draft letter for circulation to respective heads of MODU owners (or equivalent) and heads of respective trade bodies. Dear During 2001/2002 the regulatory bodies of NSOAFconducted a series of audits in respect of lifting equipment and operations, falling objects from heights and manual handling activities. The common standard and methodology used for the audits was the UK s publication HS (G) 65 Successful Health and safety management. The respective teams observed a considerable degree of consistency in the strengths and weaknesses of the management systems of the companies audited. A copy of the common findings and the main areas of concern are attached as annexes A and B respectively for information. No evidence was observed to indicate that any single company had all the relevant controls in place and could not improve their management systems. It was also noted that the deficiencies that were observed by the respective teams had not been revealed under normal company audit procedures indicating an industry generic need for more effective and robust in-house systems to be put in place. More detailed information and feedback can be obtained from your own regulatory body. We the undersigned would like to bring to your attention the common areas of concern and ask that you take positive steps to ensure they are addressed. Yours sincerely Signed by the lead representative for each NSOAF member. Feb 2003 Page 15 of 16