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Notification of order following audit of groups at risk on Jotun A

Audit: During the period 13-22 October 2009, the Petroleum Safety Authority Norway (PSA) conducted an audit of ExxonMobil's (Esso's) and contractor Aak's identification and follow-up of groups potentially at risk on Jotun A. Based on our findings during the audit, we have issued a notification of order.

The audit was carried out by means of a start-up meeting on land on 13 October 2009 with Esso and Aak, as well as verifications on board Jotun A (photo) during the period 20-22 October 2009. We were assisted during the audit by ”Occupational Hygiene Solutions”.

Jotun A (source: ExxonMobil)

In connection with the audit, we identified three groups/tasks that are potentially at risk: Aak's rope access personnel and Esso's maintenance/process employees with tasks in tanks and in the turret area.

Upon arrival on Jotun, it became evident that Aak had hired insulators from Norisol, which thus also participated in the audit. No separate observations have been made for Norisol, but many of the observations linked to Aak also applied to Norisol. From Norisol, we have only had conversations with the personnel hired to work on Jotun A.

It emerged during conversations that the general atmosphere on Jotun was good, and that a good job is done of including Aak as a contractor. Aak places great emphasis on personal safety in the planning and execution of rope access work.

The companies had prepared well for the audit, and we were met with a good and open dialogue.

Background for the audit
This audit activity is part of the PSA's main priorities for 2009: Groups at risk.

This area has also been a main priority for the PSA in 2007 and 2008. In addition, this audit was also a follow-up of the working environment audit conducted in 2002.

Purpose of the audit
The purpose of the PSA's efforts in 2009 is that the PSA shall contribute to reducing the risk of injury and illness for groups that are particularly at risk by:

  • Following up to ensure that the companies further develop a comprehensive picture of the risk of illness and injury for groups of employees, and that new knowledge is actively used in a risk-based approach where efforts are aimed at groups where the need and effect are greatest.
  • Contributing to clarify connections between framework conditions and risk.
  • Following up to ensure that the players jointly develop framework conditions that contribute to ensuring high HSE standards for all groups.

Result of the audit
Since March 2009, Aak has carried out continuous work to remove insulation and re-insulation using rope access in the process area on Jotun A.

The audit activity identified that this group has a number of risk factors connected to their performance of work. The follow-up of the rope access technicians' working environment on Jotun A was very inadequate.

Two nonconformities emerged during the audit:

  • No systematic surveys and risk assessments have been performed of the working environment conditions for Aak employees.
  • No training has been provided in relevant working environment risk for Aak employees.

Work in tanks and in the turret, which is mainly performed by Esso employees, appeared to be well-organised with regard to reducing risk in the working environment.

The audit thus confirmed findings from previous audit activities in which we have seen that contractor employees as a group consistently have more risk factors in their working environment and higher exposure than operating company groups.

At the same time, the management elements that are intended to help ensure a satisfactory working environment are significantly weaker for contractor groups than for operating company groups.

In addition, we noted six areas with potential for improvement related to the following:

  • Systematic evaluation of protective gear, work equipment and tools
  • Follow-up of work-related diseases
  • Communication in noisy areas
  • Cooperation between Aak and Esso, including the company health services
  • Use of overtime on Jotun A
  • Use of the nurse's working environment competence

Based on our findings during the audit, we have issued the following notification of order to Esso:

Pursuant to the Management Regulations, Section 17 relating to analysis of the working environment, the Management Regulations, Section 3 and the Activities Regulations, Section 31 relating to arrangement of work, cf. the Framework Regulations, Section 5 relating to responsibility, first and second subsections, and Section 58 relating to individual decisions, ExxonMobil (Esso) is ordered to evaluate the systems intended to ensure follow-up of working environment conditions for contractors working on Esso Norge's facilities. Furthermore, Esso must, in cooperation with Aak, consider follow-up of the working environment for rope access technicians (cf. Items 5.1.1 – 5.1.2 of the report) and implement the necessary measures to ensure that working environment factors are followed up in accordance with the regulations.

The following elements must be included:

  • Surveys and risk assessments, as well as necessary facilitation of the working environment conditions for the rope access technicians – cf. Item 5.1.1 of the report.
  • Training within relevant working environment risk for rope access technicians – cf. Item 5.1.2 of the report

The deadline for complying with the order is set at 1 February 2010. The PSA must be notified when the order has been carried out.

We have asked Esso to submit any comments concerning the notification by 5 January 2010.

The report contains observations of factors where there is potential for improvements, and we have requested the company's analysis of these factors.

About “orders” vs. “notification of order":
An order is a administrative decision made pursuant to the regulations. Before we issue an order, we usually submit a "notification of order" to the companies involved.

A notification of order is neither a measure nor a warning of sanctions, but part of our administrative process in accordance with the established rules of procedure. The notification is just a first step before an administrative decision is made.

Journal 2009/982 (document in Norwegian)