6 The Government’s conclusions
Based on the summary of facts and discussion in Chapters 1-5, the Government gives an account in Chapter 6 of ambitions and expectations for further development and follow-up of HSE in the petroleum activities.
6.1 Expectations regarding the HSE level
The petroleum activities are Norway’s largest industry measured by value creation and revenues for the State. At the same time, the petroleum activities are an industry with a potential for major accidents and with working environment challenges, which means that the HSE work and HSE standards must be subject to stringent requirements. Safety has an expiration date. The HSE situation in the petroleum activities must therefore always be a top priority. “Good enough“ is not enough when it comes to the safety and working environment level in this industry. The Government’s ambition is for the Norwegian petroleum activities to be a world leader within HSE. This ambition stands firm, and is a clear signal to the petroleum industry that it must work hard to continuously improve safety through all phases of activity. The vision of being a world leader, requires the industry to have a preventive and long-term approach to HSE. It presumes that the industry does not take a high safety level for granted, but works for constant improvement. A key requirement in the petroleum regulations is that the players continuously further develop and improve the level for health, safety and environment.
Over time, the HSE level in the petroleum activities has developed positively, and the authorities and parties in the industry agree that the safety level is high. In 2017, the major accident indicator was at a low level. However, the Norwegian petroleum activities have been characterised by changes, both in activity level, profitability and player landscape. There were multiple serious incidents and accidents in 2015 and 2016. In 2017, RNNP showed a negative development as regards psychosocial working environment and safety culture, and there was an increase in the number of serious injuries. To ensure sustainable development in the Norwegian petroleum activities, it is still a necessity to further develop the safety level, implement streamlining measures and reduce the cost level. The activities must have a long-term perspective with a focus on a high HSE level, resource management and value creation. The industry must safeguard all these considerations. The Petroleum Safety Authority shall follow up to ensure that the industry continues to further develop a high safety level in connection with streamlining measures.
6.2 Follow-up of responsibility
The companies are responsible for the HSE level in the petroleum activities. The authorities’ follow-up comes in addition to, and not as a replacement for, the companies’ own follow-up. The HSE regulations in the Norwegian petroleum activities stipulate stringent requirements for goal achievement, but allow freedom in choosing solutions. This gives the industry latitude that facilitates the development of new solutions for increased efficiency, and simultaneously a high HSE level. The adjustment that the petroleum industry has undergone in recent years shows that the industry itself also has considerable influence over the cost level in the petroleum activities. Both the responsibility for and key to continuous improvement of the HSE level and efficient operations therefore lie with the industry itself.
It is expected that the industry is capable of managing and adapting to changes in the petroleum activities while also taking responsibility for further developing and strengthening safety and the working environment. This responsibility also entails follow-up of the duty of care, both the operator’s follow-up of suppliers down in the chain and the licensees’ follow-up of the operator. The industry’s efforts within this area should be strengthened going forward.
The current HSE regime is contingent upon the parties in the industry facilitating cooperation and participation in the two-party and three-party arenas, and participation and multipartite cooperation must be highly prioritised in the industry. It is positive that the cooperation in the tripartite arenas is perceived as constructive and well-functioning. It is also positive and important that the industry is jointly taking responsibility for establishing and following up important improvement projects to reduce accident risk and improve the working environment, for example the chemicals project, gas leak projects, etc. The significance of the tripartite cooperation, however, depends on this having an impact on the two-party cooperation and the HSE work in the companies. The organisations in the tripartite cooperation must therefore take responsibility for ensuring discussions, exchange of experience and learning are communicated to and followed up among their members.
6.3 Regime for follow-up of health, safety and the environment
The regime for follow-up of health, safety and the environment in the petroleum activities was developed and designed with regard to follow-up of a complex and high-tech industry undergoing constant development. Generally, the authorities and parties consider the current HSE regime to be robust and well-functioning and believe it should be continued. The HSE regime is considered to have been very significant for the positive development and high safety level in the petroleum activities today. The established HSE regime will continue to be important, given the high risk potential and rapid technological development in the industry. At the same time, good use of the latitude in the regime presumes that the three parties have mutual trust and respect for each other’s roles and responsibilities. In recent years, it has been discussed whether the development, with changes in the player landscape, adjustments and streamlining requirements and pressure on the multipartite cooperation, could challenge the current HSE regime. Challenges and testing the limits for choosing solutions can lead to jeopardising the trust between the players and putting pressure on the HSE regime. The players in the industry must be aware of this.
The petroleum industry must emphasise the added value of the multipartite cooperation. This cooperation is an important pillar of the regime, and must be strengthened and further developed. The Government is pleased that the parties in the industry are aware of their responsibility and have implemented cooperative measures to get on a better track as regards multipartite cooperation, regulatory understanding, follow-up of major accident risk and working environment challenges, among other things.
The Petroleum Safety Authority must be a strong and clear authority and must assess its use of policy instruments in an active and visible manner. This applies to all phases of the petroleum activity, from awards and production to cessation and disposal. The development could indicate that there is a need for the Petroleum Safety Authority to be clearer in its use of sanctions in certain cases, and to verify that nonconformities and orders are followed up when necessary.
Through follow-up of the licensing system, the authorities jointly contribute to a high safety level on the Norwegian shelf. Decisions concerning the HSE regulations can have an impact on efficient operations, and decisions relating to awards and transfers can impact the safety level on the Norwegian shelf. The authorities must therefore ensure we have serious and competent players on the Norwegian shelf. The Petroleum Safety Authority and Ministry of Labour and Social Affairs’ practice of the award criteria as regards the HSE consideration should be reviewed at regular intervals, to ensure these considerations are safeguarded in a satisfactory manner. This way, experience from serious incidents and development trends in the industry can form a basis for potential adjustments of the award criteria and how they are practiced. Important purposes of the award criteria and how they are practiced include promoting good resource management and a high safety level.
6.4 Further development in the petroleum activities
The petroleum industry is constantly changing. After the oil price drop in 2014, major change and streamlining processes were implemented, and they are still ongoing. The change processes are rapid and complex, and it can be challenging to carry out comprehensive assessments of the HSE consequences that the changes might have. Good competence and capacity are preconditions for safe and prudent operations. The Government expects the industry, during times of change, adjustment and cuts, to ensure relevant and sufficient competence, through both recruitment and competence development. Going forward, the petroleum industry must also be very aware of changes in work content and working environment in connection with adjustments, and work to ensure companies focus on prevention and follow-up of potential health effects of such changes.
Knowledge and new technology are continuously being developed in the petroleum activities and new concepts and operation methods are aplied over time. Technology development is a requirement for increased safety and efficiency in the petroleum activities. Digitalisation is also a part of this picture. However, new technological and digital solutions can also bring new challenges. To make room for development and facilitate efficient operations, the requirement for continuous improvement must therefore be viewed in a longer perspective, and not in isolation in connection with individual cases. New technology that is significant for both efficiency and safety must be utilised. The industry must ensure that this is prioritised by the companies. The petroleum industry must ensure continuous improvement of the HSE level, also during times with major changes and streamlining requirements in the industry.
As follows from Chapter 4.6.2, a multipartite work group is working on issues concerning use of vessels on the shelf, and the overarching goal for this work is to arrive at a more unified perception of reality in the “multipurpose vessel issue”. In this connection, reference is also made to recommended decision no. 1101 (2016–2017), where the Storting asked the Government to assess possibilities for stipulating Norwegian wage and working conditions in Norwegian waters and on the Norwegian shelf. The assessment falls under the authority of the Minister of Trade and Industry, and will e.g. clarify the coastal state’s latitude in Norwegian waters and on the Norwegian shelf without conflicting with the flag state principle. It could be relevant to also consider this assessment in connection with the multipurpose vessel case. The Government will get back to the Storting concerning the matter in the appropriate manner when these processes have been finalised.
In their reports, both the Petroleum Safety Authority and Safetec paint a picture where an increasing share of the activity on the Norwegian continental shelf is being conducted from ships, see Chapter 4.6.2. A natural consequence of this development is that the safety authorities dedicate more attention to this part of the petroleum activities. The Government will therefore intensify supervision efforts vis-à-vis vessel activity on the continental shelf, within the framework of the Petroleum Act.
6.5 Knowledge and documentation
Continuous knowledge development and good documentation are necessary in connection with HSE in the petroleum activities, not least as a result of the technological development. Further development and follow-up of RNNP is an important measure in this context. Measures to increase the response rate and ensure the quality of RNNP’s questionnaire, as well as how the RNNP work can be organised and strengthened to ensure balanced and precise use of results and analyses, will be assessed further. The Ministry will follow this up in cooperation with the Petroleum Safety Authority and the industry.
In upcoming years, there will also be a need for investment in research and innovation within HSE in the petroleum sector. The need for more knowledge is supported by the Government’s long-term plan for research (Meld. St. 7 (2014–2015) Report to the Storting Long-term plan for research and higher education 2015–2024), where it emerges that the petroleum activities need new knowledge in order to maintain the high standards for health, safety and environment. Traditionally, research within HSE in the petroleum activities has been aimed at issues that have been important to the industry. It is also important to explore broader issues that may become relevant to the industry over the long-term. The Research Council of Norway has pointed out a need for increased knowledge, e.g. on the significance of change processes and changed framework conditions for working environment and major accident risk, as well as special challenges related to petroleum activity in the northern areas.
During times of major adjustments and changes in the industry, it is crucial to generate a knowledge basis that is as relevant as possible. The Government expects basic and applied research that contributes to new competence, technology and innovations to prevent major accidents and improve health, safety and environment in the petroleum activities. In the future, knowledge and technology development must be a high priority in the industry, organisations and companies.