What yields the best effect?

Explanations have been pursued in a number of different ways, and findings so far are summarised below.

User surveys

The key instrument deployed by the PSA is system audits. When companies receive an audit report from the PSA, they have a responsibility to plan and implement measures which will correct any nonconformities identified by the audit.

While these reports therefore lead to action if nonconformities exist, they are not the only contributor to improvement measures. That emerges from the annual user surveys conducted by the PSA to gauge the effects of its work.

Between 42 and 54 per cent of respondents (both company contacts and safety delegates) to the 2022 poll accordingly report that notification of an audit and summary meetings lead to a very great/great extent to measures.

The PSA interprets this to mean that the companies make a big effort to prepare for audits, and that they begin improvement efforts immediately after being presented with the outlines of the audit findings at the summary meeting.

Where improvement points, identifying nonconformities, notice of orders and orders are concerned, responses from company contacts and from safety delegates deviated somewhat from each other in 2022.

Roughly 91-98 of the contacts considered that all these instruments led to a very great/great extent to measures, while delegates gave orders the highest score (91 per cent), followed by notice of orders (86 per cent), identification of nonconformities (80 per cent) and finally improvement points (55 per cent).

The PSA has also asked questions about other measures and activities, and found that many different activities contribute to improvement work in a company – including PSA checks of earlier nonconformities as well as follow-up or investigation of incidents.

Other issues covered include follow-up of projects before a plan for development and operation (PDO) and in the construction phase, consideration of applications for consent and acknowledgements of compliance (AoCs), serving as an observer in production licences, and holding annual status meetings and meetings on specific challenges.

All company contacts consider that follow-up of projects and consideration of consent applications lead to a very great/great extent to improvement efforts, followed by meetings on specific challenges and investigation of incidents, follow-up of incidents, pre-PDO follow-up of projects and annual status meetings.

AoCs and PSA participation as an observer in production licences is given a somewhat lower rating (66 and 67 per cent at a very great/great extent). Not all respondents will have an involvement in such activities, of course.

Safety delegates generally give a higher rating to all types of activities, but investigation and follow-up of incidents and checks of earlier nonconformities are considered to make the biggest contributions to improvement work.

In addition, the PSA pursues a number of activities directed at the industry as a whole. These include its annual main issue, results from the trends in risk level in the petroleum activity (RNNP) survey, and projects reports and technical articles on the website.

Other examples referenced in the 2022 survey are technical seminars staged by the PSA, its contributions to conferences and industry fora, and newsletters posted to the psa.no website.

Results from the poll show that company contacts rate the effect of all these measures relatively highly, with 82-98 per cent assessing them as making a very great/great contribution.

Safety delegates show a more diverse response, with the PSA’s main issue given a top rating by 89 per cent, followed by contributions to conferences and industry fora (83 per cent), RNNP results (78 per cent), project reports and technical articles (67 per cent), newsletters (63 per cent) and seminars (52 per cent).

A high proportion of the companies moreover consider that the PSA’s presence in itself contributes to a very great/extent to reducing the risk of major accidents (84 per cent in 2022). Where preventive working environment work is concerned, assessments have risen from 71 per cent in 2021 to 80 per cent in 2022.

The feeling at the companies that the PSA contributes to securing genuine employee participation has risen from 52 per cent in 2020 to 69 per cent in 2022, and the assessment of their confidence in the authority has been very high throughout the period.

Working meetings with petroleum industry players

Over several years, the PSA has invited in a small number of companies at a time to meetings in order to share experience of their own audits and of regulatory supervision.

Each company has presented examples of supervisory activities which have had an effect by leading to changes. They also reflect over why these activities in particular have been useful for their own improvement work.

These meetings have provided the PSA with valuable input as a supervisory agency, have contributed to information-sharing between the companies, and have largely dealt with supervision in the form of audits.

One conclusion is that improvement points, nonconformities and orders can all be effective, but that this depends on both the background and the company. Some reported that orders contributed to funds being allocated by senior management, so that necessary measures were actually taken, while others said that major changes were initiated on the basis of an improvement point.

Another finding is that audit reports have an effect beyond the facility or plant they apply to, and in some cases even beyond their subject. Most companies assess whether measures adopted to deal with nonconformities or orders also have wider internal relevance.

Since the audit reports are published on psa.no, companies also check those directed at others and consider whether the same observations could have been applied to their own facilities or plants.

In this way, the reports function additionally as guidance to and interpretation of the regulations, and provide a “measuring rod” which all the companies can use in their self-assessment.

Participants in the most recent of these meetings have particularly emphasised the work of following up and clearly signing off nonconformities identified earlier by the PSA. Since the latter began to question the results of such follow-up, virtually all the companies have taken extensive steps to check that all necessary measures have been implemented.

They also report better processes for signing off nonconformities, such as special “closure meetings” to ensure that the quality of the measures adopted is good.

The PSA always invites a representative of the industrial safety service to these working meetings, and these participants provide important information.

Safety delegates consider it positive that their service is always invited to contribute to audits and that the authorities take seriously issues which concern them. One delegate noted that this attention helped to give value to the work of the safety service.

Qualitative studies and evaluations

Over a four-year period, the PSA has commissioned various studies to identify the effects of its follow-up at company and industry level. These are summarised below.

2019: Effect of the PSA’s work on well control and chemical health hazards

In 2019, Menon Economics and DNV GL interviewed technical specialists, executives and  safety delegates about their work on well control and chemical health risks. The aim was to establish how significant the PSA’s overall commitment had been for these two issues.

A total of 102 respondents were interviewed, including 52 involved with well control and 50 concerned with chemical health risk. The unanimous perception was that the PSA’s work is important.

However, it was not the sole influence on improvement efforts at the companies but one of many different factors. The majority of respondents believed that amendments to regulations and standards had the biggest impact on change, along with the work done by the companies on safety and enhancing expertise.

While the same level of importance was not attributed to guidance from the PSA, most respondents nevertheless wanted more of it in the form of technical seminars and other forms of experience-sharing

This study also highlighted the preventive effect of the existence of a regulatory authority which can supervise the businesses. As one respondent commented: “If the PSA hadn’t been there, the level of safety on the Norwegian continental shelf [NCS] would have been lower.”

2020: Effect of the PSA’s work related to hydrocarbon leaks and lifting incidents

Safetec and Oslo Economics investigated in 2020 what effect the PSA’s activities have on improvement efforts at the companies which are aimed at preventing hydrocarbon leaks and lifting incidents on the NCS.

Again, respondents thought the PSA made a significant contribution to safety in Norway’s petroleum sector. Knowing that the authorities could intervene is an important factor in maintaining a concentration on safety at the companies and in the industry as a whole.

The effect was considered to be greatest for such work as developing regulations, audits and investigations, and rather less for various guidance activities, seminars and conferences. However, this study once again revealed a desire for more guidance and facilitation of cross-company learning.

2021: Effects of exercising strong administrative sanctions

Simonsen Vogt Wiig AS (SVW) was commissioned in 2021 to study and develop what was known about the effects of applying strong sanctions. It reviewed relevant legal sources and literature on the documented preventive effect of using such enforcement powers against companies breaching the regulations.

The review revealed that little relevant evidence or documentation existed which could give a clear basis for drawing conclusions in this area.

SVW therefore recommended that “the PSA should take into account that good effects from strong sanctions are generally regarded as plausible, but are only modestly supported by empirical evidence”.

The company also recommended that “the PSA should concentrate for the time being on conducting interview-based surveys in order to document the effects of its own supervisory activities. This is something it actually already does”.

2022: Effects of the PSA’s investigations

In 2022, DNV evaluated the effects of the PSA’s investigations on work by the companies with safety and the working environment. This assessment was based on inquiries pursued by both the PSA and the companies themselves into 10 serious incidents in 2019-21.

This study revealed that reports from both parties primarily identified the same underlying causes, and that measures were initiated as a rule on the basis of the internal company findings.

But it nevertheless found that the PSA investigations had an effect – not least by contributing to more efficient execution of measures, and by putting more weight behind their implementation.

The fact that the PSA’s conclusions were regarded as independent of company assessments was also seen as positive. That provides reassurance for society, in the industry and among employees that an objective investigation has been conducted.

Moreover, DNV notes that the PSA’s investigations contribute to greater attention being paid to compliance with procedures and improved understanding of the regulations.

What do the studies show to have the greatest effect?

In summary, the various studies support a conclusion that the various instruments used and measures implemented by the PSA has a real effect on work at the companies with health, safety and the environment (HSE).

The fact that a regulatory authority exists to supervise the industry probably has an impact in itself. Moreover, amendments to the regulations carry a big weight but can only be applied when such changes are required.

Another conclusion to be drawn from the studies is that audits and investigations directed at individual companies have greater effect than information and guidance. Nevertheless, survey respondents generally express a desire for more of the latter.

Audits and investigations lead to changes not only on the facilities or at the plants concerned but also in the rest of the company and at other enterprises. Publishing audits reports on the web (largely in Norwegian only) is highly significant and can also be viewed as part of experience-sharing.

Part of the effect of audits and investigations probably lies in the boost which the PSA’s attention gives to getting measures implemented, even though the challenges were already known in the relevant company.

The PSA can also help to turn attention to an issue which has not previously had high priority with management. Specifically, the studies and working meetings show that the authority’s concern with taking action over identified nonconformities has led to major improvements in this area at the companies.

This article is taken from PSA's annual report for 2022. The full report (in Norwegian only) can be read here.