By Magne Ognedal, Petroleum Safety Authority Norway
Safety regulators in North Sea countries have pursued a fruitful collaboration for several decades through the North Sea Offshore Authorities Forum (NSOAF). Its members hold an annual working meeting where activities are summed up and new tasks are initiated and discussed. Most of the forum’s work is carried on through dedicated working groups. These are appointed to tackle particular challenges where the forum sees potential for enhanced efficiency if members coordinate their efforts and benefit from mutual experience and knowledge.
Many of the conditions addressed by the forum have related to mobile drilling units, which often move across continental shelf boundaries. Every such move unleashes a number of administrative, inspection and supervisory activities by the regulators in the countries concerned, as well as by the drilling contractors.
The latter protested vocally during the 1990s when they found that they were incurring costs in complying with the regulatory requirements of the various countries each time their units crossed continental shelf boundaries. A particular complaint was that the Norwegian regulations contained special requirements that allegedly made units much more expensive. Various studies were eventually carried out to identify why rig costs were demonstrably higher on the Norwegian continental shelf than for comparable activities in the British sector. One conclusion was that the cost differential could be broken down into three fairly equal components. One related to pay and conditions, which lies outside the control of the authorities. A second related to the exercise of regulatory control. The final component was attributable to errors in interpreting regulatory requirements and to “over-interpretation.”
The NSOAF got to grips with the second and last of these factors and initiated work to identify how the authorities could jointly help to reduce unnecessary costs while making official control and supervisory activities more efficient.
Close collaboration had already been established between the NSOAF and the IADC North Sea Chapter. Regular meetings between the two sides were instituted in the 1990s and were eventually conducted in association with sessions of the forum’s MoU working group. Norwegian contractor Smedvig Drilling (now Seadrill) offered to carry out a comparative study of Norwegian and British regulations and devoted substantial resources to producing a thorough and detailed report. This listed which requirements were the same between Norway and the UK, and which differed.
These observations formed the basis for specific efforts by the NSOAF’s working group to investigate the potential for harmonising requirements. For various reasons, full harmonisation could not be achieved. The variances were also minor. However, it became clear at an early stage that the differences related more to regulatory practice in the countries than to the technical content of the requirements.
On that basis, the NSOAF identified a need to improve mutual insight into and understanding of the approach taken by members in exercising regulatory control. A series of meetings was held, at which forum members briefed each other on how control was exercised.
Through a constructive collaboration with the IADC, three mutual audits were conducted in 1999-2003. Representatives from various NSOAF members planned and implemented thematic audits of selected drilling contractors with simultaneous assignments on several national continental shelves.
Not least as a result of the IADC’s active contribution to facilitating these audits, the regulators gained useful experience that increased their mutual understanding of differences and similarities in the exercise of regulatory control. IADC also made it clear that the drilling contractors saw substantial benefits in a coordinated audit of this kind.
IADC had already established a template for preparing an application for a safety case for drilling units on the UK continental shelf. Given the good experience of collaboration so far, the association undertook development of this template into a document as the basis for preparing an application that satisfied regulatory requirements in all the North Sea nations.
This proved a substantial job, which called for close cooperation between IADC and the MoU working group. The document that eventually took shape was structured with a common section, covering requirements identical to all the countries, and an appendix for each country listing specific national requirements. The primary contribution of the NSOAF members to this work was to quality-assure the respective appendices.
The first edition of the North-West Europe HSE Case Guidelines was introduced in 2002 and has subsequently been revised several times. In parallel with this work, NSOAF members have developed schemes to allow a regulator to take advantage of checks carried out in another country. As a result, the document developed by IADC represents an important contribution to more efficient case management, both by the regulators and by the companies, because unnecessary double work can be eliminated.
The NSOAF also aims to develop practical arrangements across North Sea boundaries that will permit efficient movement of offshore workers. One objective has been to encourage convergent training standards that can eliminate additional training when workers cross continental shelf borders.
IADC has made a very constructive contribution to these efforts through the development of a training standard. This encompasses the training requirements specified in the standards for training, certification and watchkeeping (STCW) set by the International Maritime Organisation (IMO), and the different national training objectives relating to petroleum activities in the North Sea.
Seen as a positive safety step, the IADC standard opens the way to more efficient movement of mobile drilling units in the North Sea area. Work is continuing to identify convergent quality assurance arrangements, underpinned by independent verification, to ensure that learning outcomes are met.
Collaboration in these areas shows that, despite their different interests, the authorities and the industry can jointly achieve good results to the benefit of both sides. This depends on them displaying a mutual understanding of and respect for each other’s responsibility and tasks. That is created, in turn, through close contact and dialogue. The regulators certainly believe that additional potential exists for achieving such collective gains in the future.
Magne Ognedal is director general of the Petroleum Safety Authority Norway.