The PSA Norway has issued a notification of order to Rowan Drilling Norway AS (Rowan Drilling) following an audit of the Rowan Gorilla VI mobile drilling facility. The audit identified serious breaches of the regulations.
Between 24 September 2013 and 17 October 2013, the PSA carried out an audit of Rowan Drilling within the field of maintenance management and logistics (materials handling, cranes, lifting equipment and lifting operations) for the Rowan Gorilla VI mobile drilling facility.
The audit was performed as a start-up meeting at Rowan’s premises at Forus on 24 September 2013 and followed up with verifications on board Gorilla VI while the facility was on a yard stay at Keppel Verholme, Rotterdam.
Rowan Gorilla VI is a jack-up drilling facility, delivered from workshops in the USA in 2001. It is registered in the USA and follows American flag state rules. The facility has class certificates from the American Bureau of Shipping (ABS) and Det norske Veritas (DNV).
Rowan Gorilla VI received Acknowledgement of Compliance (AoC) from the PSA on 17 November 2009.
The facility drilled for only a short period on the Norwegian Continental Shelf, and left the shelf in 2010. The facility is now returning to drill wells for ConocoPhillips at Ekofisk.
The objective of the audit was to verify that Rowan has maintained the preconditions for granting an AoC during the period when the facility was on foreign continental shelves.
Non-conformities, improvement points and other comments/observations detected or made during audits relating to the AoC application for Rowan Gorilla VI, in the period 2007-2009, have previously been confirmed as closed and improved in accordance with Rowan’s own schedules. These were the preconditions for issuing an AoC.
The audit revealed that Rowan’s maintenance management system did not comply with regulatory requirements in respect of maintenance.
During the audit, many non-conformities and improvement points were found which had also been detected previously and described in the PSA’s audit reports for the processing of the AoC application. According to Rowan’s feedback after the audits, these findings were to have been closed and improved.
The PSA was also informed at the start-up meeting of 24 September 2013 that all safety-critical equipment and supporting systems had been identified, tagged and recorded in SAP. The audit revealed that this was not the case.
The facility was characterised by deficient maintenance, equipment was heavily corroded and safety-critical equipment was observed to be damaged. “In our audit report of 12 February 2008, we described defective risk/safety awareness among managers of the facility. The findings from this audit document that the same circumstances continue to prevail,” PSA said today.
New regulatory non-conformities were discovered in technical conditions, organisational aspects and the company’s management system.
During the audit in Rotterdam, the PSA detected a number of issues relating to both technical factors on Gorilla VI and managerial factors in Rowan Drilling’s organisation. These are issues that were also detected during the AoC process for Gorilla VI between 2007 and 2009 and which were previously confirmed as having been dealt with.
In addition, the audit revealed deficiencies in Rowan Drilling’s own follow-up. Rowan Drilling had not carried out audits or verifications of maintenance management in respect of the facility.
Staff involved in maintenance on board lacked training in and knowledge of use of the company’s maintenance management system, SAP and the management system for safe use of lifting equipment. Many of the staff were new employees.
“In the light of our audits and audit reports of 2007, 2008 and 2009, feedback on them from Rowan, and correspondence relating to the AoC application and the issuing of the AoC for Gorilla VI, the PSA takes a serious view of the findings of this latest audit,” the PSA said.
Based on the findings made during the audit, the PSA gives Rowan Drilling notice of the following order:
Pursuant to the Framework Regulations, section 69 concerning administrative decisions, with reference to the Management Regulations, section 6 concerning the management of health, safety and the environment, section 8 concerning internal requirements, section 21 concerning follow-up, and the Activities Regulations, chapter IX concerning maintenance, including classification, preparation of a maintenance programme and measurement of maintenance efficiency and chapter XVIII section 92 Lifting Operations, Rowan Drilling Norway AS is ordered to implement the following measures:
To review the management system and implement measures so that the company’s follow-up systems meet the intended needs in all parts of the organisation. The work shall include an investigation of why serious deficiencies in the maintenance management system and management system for using lifting equipment have not been identified and followed up.
To prepare a binding, time-delimited schedule for ensuring that, for all facilities within Rowan Drilling Norway AS’s area of responsibility, necessary maintenance and safe use of lifting equipment in accordance with regulatory requirements are planned and implemented. The schedule shall describe how this work is to be performed and followed up. This schedule is to be submitted to the PSA by 10 December 2013 along with the feedback on the audit report.
Before facilities which are not currently in operation on the Norwegian Continental Shelf are deployed on the Norwegian shelf, Rowan must ensure that they can be operated prudently; see the Activities Regulations, section 20 concerning start-up and operation of facilities, and refer to sections 5.1-5.3 of the report.
The deadline for complying with the order is set at 15 February 2014. We are to be notified when the order has been carried out.
Explanation of the terms “order” and “notification of order”
An order is an administrative decision made pursuant to the regulations. Before the PSA issues an order, the Authority generally sends a “notification of order” to the affected companies.
A notification of order is neither an instrument nor a notice of sanctions, but a step in the PSA’s case processing in which the PSA requests the party to assess the factual basis. The notification is only the first step before an administrative decision is made.
An order is a strongly preventive instrument which is legally binding on the recipient.
November 18, 2013