Questions have again arisen in recent weeks regarding the suitability of this evacuation equipment in connection with evacuations in bad weather.
This applies particularly to the placement of the lifeboats on the facilities and their ability to maneuver away from the facility after they are launched.
In an identical letter sent on 11 September to operating companies and shipowners with facilities on the Norwegian shelf, the PSA therefore asked for answers regarding how the companies handle this information in order to ensure that their own operations are prudent.
Based on a precautionary principle, we also asked the companies to describe potential compensatory measures they have planned until the facts have been clarified as regards liveboat propulsion. (Relevant article: PSA asks the industry for lifeboat answers)
There is a significant difference in the quality of the answers provided by the companies. Some companies provided a detailed description of compensatory measures that were already implemented to ensure that regulatory requirements relating to lifeboats are safeguarded.
The responses provided to the PSA by 19 of the companies are insufficient. Many of these companies have not answered the questions raised by the PSA at all, but have merely referred to the lifeboat project being conducted by the industry organization, OLF (the Norwegian Oil Industry Association).
Deadline for reply: 12 October
The Petroleum Safety Authority Norway has issued a direct order to the companies that have not provided satisfactory answers to our questions, requiring them to describe the consequences for their own activities. The evaluations must address all types of lifeboats (including conventional lowering lifeboats) and all facilities that are equipped with lifeboats as a means of evacuation. The deadline for reply is Friday, 12 October.
The PSA also has a need for some clarifications regarding the responses given by other operating companies and shipowners that will not receive a direct order. This relates to StatoilHydro, Shell, Total and Ocean Rig. We are in continuous dialogue with these companies to ensure that the requirement for prudent operations is observed. Other companies have replied that they do not have facilities with AoCs on the Norwegian shelf.
Praises the industry project
As a consequence of the response from the companies, all lifeboat owners that have petroleum activities on the Norwegian shelf were called in to a meeting in the Petroleum Safety Authority Norway on Monday, 1 October.
In this meeting, Director for Supervisory Activities Finn Carlsen emphasized that the operating companies and shipowners have an independent responsibility to ensure prudent operation of their own facilities.
This responsibility includes making individual and overall assessments of all factors that have an impact on safe evacuation at all times and under all weather conditions on their own facilities.
"It's great that the industry is cooperating through OLF to find good solutions that remove uncertainty linked to means of evacuation and the suitability of launch systems in the petroleum activities. However, this good work does not exempt the individual player from ensuring that it can document that its own activities are carried out prudently and in compliance with the regulations," Carlsen stated.
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About "prudent operations" and the "precautionary principle"
The HSE regulations for the petroleum activities are normative and contain functional requirements. This means that the regulations state the level of safety that must be achieved - but not how to achieve it. The lifeboats have always been encompassed by these functional requirements.
The Activities Regulations (Section 68, litera d) states that "The party responsible shall ensure that necessary actions are taken as quickly as possible in the event of situations of hazard and accident; so that personnel on the facility can be quickly and efficiently evacuated at all times."
An important part of the precautionary principle is that the individual operating company and/or shipowner must immediately implement necessary compensatory measures when, e.g. weaknesses on lifeboats are discovered.
The precautionary principle also entails that measures must be considered - and implemented if applicable - if there is uncertainty related to use of the lifeboats in certain wind and wave conditions.
The owners of the lifeboats - i.e. operating companies/shipowners - have the ultimate responsibility for ensuring that the equipment used is suitable for the intended purpose and complies with the regulatory requirements.