In recent years there has been increased attention surrounding chemical working environment in the petroleum activities. Inadequate practice for follow-up of risk has been identified, and work is ongoing to fill knowledge gaps in this area.
Much of the improvement work in the chemical area is taking place in connection with the industry’s joint project within the area (www.olf.no/kjemisk). In its action plan, the industry has committed itself vis-á-vis the government to achieve significant improvements.
The regulations for the petroleum activities connect health, safety and environmental aspects to the choice, use and disposal of chemicals, and sets requirements for the companies to have comprehensive chemical management.
The purpose of the audit was to verify that systems and the practice for following up the chemical working environment at Shell were in accordance with requirements. Another, objective was to assess whether relevant requirements and intentions in the regulations were followed up systematically.
The audit identified weaknesses in Shell’s systems for follow-up of chemical working environment as regards the regulatory requirements.
The PSA has identified three nonconformities from the regulations:
- Mapping and risk assessment of chemical exposure was inadequate and did not provide a sufficient basis for making decisions for improvement measures
- The duty to substitute chemicals based on health risk was not followed up sufficiently
- Requirements for HSE-related chemical information were not sufficiently safeguarded
Based on our discoveries during the audit, the PSA has issued Shell the following notification of order:
Pursuant to Section 18 of the Management Regulations relating to working environment analysis and Section 11 relating to basis for making decisions and decision criteria, as well as Section 36 of the Activities Regulations relating to chemical health hazard and Section 48, third subsection of the Technical and Operational Regulations, cf. Section 69 of the Framework Regulations relating to administrative decisions , Shell is ordered to:
Review its system for managing of chemical health hazard with the aim of improving the practice for mapping and risk assessments so there is a sufficient basis for making decisions for preventative measures.
The deadline for carrying out the order is set at 1 August 2011. We must be notified when the order has been complied with.
Order and notification of order
An order is a administrative decision made pursuant to the regulations.
Before the PSA makes an order, it usually issues a notification of order to the companies concerned.
A notification of order is neither a measure nor a warning of sanctions, but part of the PSA’s administrative process as specified in its established procedural rules.
The notification is merely a first step before an administrative decision is made.