• The audit was conducted from 21 to 28 January 2025
  • A notification of order was sent to Beerenberg on 26 June 2025
  • The order was issued on 11 July 2025

Objective

The objective of the audit was to verify that the company’s follow-up of incidents complies with regulatory requirements.

The audit focused on the company’s follow-up and learning in response to the order made and non-conformities identified in the wake of Havtil’s investigation of an incident at Mongstad on 18 January 2023, in which a person was injured following a fall from scaffolding.

During the audit, we wanted to monitor the company’s provision of competence, training and drills among its own employees and contract workers who perform work at height.

Result

Follow-up of non-conformities

During the audit, we verified how Beerenberg has addressed certain previously identified non-conformities and orders.

We found that the following non-conformities/orders had not been addressed in line with the company’s feedback of 23 June 2023/116: 3

  • Non-conformity concerning a failure to organise the work in such a way that the probability of errors which can lead to hazards or accidents is reduced, with reference to Chapter 9.3.1 of the investigation report dated 23 June 2023, our journal entry 2023/116.
  • Non-conformity concerning Beerenberg’s failure to ensure adequate maintenance and checks of scaffolding, with reference to Chapter 9.3.2 of the investigation report dated 23 June 2023, our journal entry 2023/116.
  • Non-conformity concerning the fact that self-rescue, fall rescue and rescue at height are not planned and prepared for or described in the emergency response plan, with reference to Chapter 9.3.5 of the investigation report dated 23 June 2023, our journal entry 2023/116.
  • Non-conformity concerning a failure to systematically conduct emergency response drills and training for Beerenberg’s personnel, with reference to Chapter 9.3.6 of the investigation report dated 23 June 2023, our journal entry 2023/116.

A brief note about the regulations

The Guideline to the Technical and Operational Regulations Section 46 concerning the organisation of work refers to the Regulations concerning the Performance of Work Chapter 17 as the recommended standard for work at height.

It follows from the Framework Regulations section 24 concerning the use of recognised standards that, if using a standard recommended in the guideline of a regulatory provision, it can normally be assumed that the regulatory requirements are met.

When using solutions other than those recommended in the guideline of a regulatory provision, the company must be able to document that the solution chosen meets the requirements in the regulations.

Combinations of sections of standards should be avoided, unless the party responsible can document that an HSE level corresponding to that specified in the regulations is achieved.

The Regulations concerning the Performance of Work, section 17-7 on the dimensioning of scaffolding and guard rails, and the Norwegian Labour Inspection Authority’s comments on this provision provide guidelines for how the scaffolding contractor is to address the mixing of scaffolding components when dimensioning scaffolding.

The Norwegian Labour Inspection Authority's comments on section 17-7 refer to the fact that calculations must be made in respect of installation and use that diverges from the manufacturer’s installation instructions, and that such scaffolding should have the same strength and stability as specified in relevant NS-EN standards.

In section 17-8 on the assembly, use and dismantling of scaffolding, reference is made to the installation guidelines and written work instructions for the person who is to assemble, dismantle and use the scaffolding.

The Norwegian Labour Inspection Authority’s comments state that, in the event of divergence from the manufacturer’s installation instructions, a qualified person shall prepare a plan for the assembly, use and dismantling of the scaffolding in question.

Section 17-13 on the maintenance of scaffolding refers to all components having to be inspected and sorted every time they are used. Material and equipment in unsatisfactory condition shall be clearly marked or rendered unusable for scaffolding purposes. Damaged components shall be repaired before they are stored together with undamaged material.

The Norwegian Labour Inspection Authority’s comment on the provision states that the employer is responsible for establishing a system to monitor this.

With regard to requirements for scaffolding material produced after 2017, these are given in Chapter 4 of the Producer Responsibility Regulations, which states that scaffolding components must be certified by an accredited certification body.

A review of certificates from certification bodies for scaffolding components indicates that the manufacturer’s basis for certification of scaffolding components cannot be used as a basis for mixing scaffolding components and assembly instructions.

Non-conformities and improvement points

The audit identified regulatory non-conformities in the following areas:

  • Assembly, use and dismantling of scaffolding
  • Maintenance of scaffolding materials

Order

The audit identified serious breaches of the regulations. On this basis, we have issued Beerenberg with the following order:

  1. Pursuant to the Working Environment Act section 18-6 and the Framework Regulations section 69 concerning administrative decisions, with reference to the Technical and Operational Regulations section 46 concerning the organisation of work, Beerenberg Services AS is ordered to:

    - Prepare, implement and monitor a system for working with scaffolding when mixing scaffolding components from different manufacturers to ensure that the probability of errors which can lead to hazards or accidents is reduced, with reference to the non-conformity stated in audit report 2024/1773, non-conformity 5.1.1.

  2. Pursuant to the Working Environment Act section 18-6 and the Framework Regulations section 69 concerning administrative decisions, with reference to the Technical and Operational Regulations section 58 concerning maintenance, Beerenberg Services AS is ordered to:

    - Conduct a comprehensive and systematic review of routines for implementation and follow-up of the maintenance of scaffolding to ensure that material is maintained so as to safeguard its required functions in all phases of its service life, with reference to audit report 2024/1773, non-conformity 5.1.2.

    The deadline for complying with part 1 of the order is six months from the date of the order.

    The deadline for complying with part 2 of the order is three months from the date of the order.

    We are to be notified when the order has been carried out.