The audit was carried out from 7 to 15 May 2025.

Objective

The objective of the audit was to monitor how the company complies with regulatory requirements for barrier management within the domains of electrical facilities, safety instrumented systems and technical safety.

Result

Since 2018, COSLPioneer has operated away from the Norwegian shelf. From September 2024, the facility was at a shipyard in Ølen in Rogaland for upgrades and maintenance prior to starting a new contract on the Norwegian shelf. The facility began drilling operations for Vår Energi in January 2025.

During the audit, serious regulatory breaches were detected concerning both technical and organisational factors, including non-compliance with procedures. Several non-conformities related to barriers. Some non-conformities were already known to the company, and a process to rectify them was under way. COSL did not have an overview of the total amount of outstanding work in sufficient detail to document adequate control. Among other things, there were challenges with equipment delivery times, personnel access and lack of space on board.

Over the past year, the shoreside organisation has grown due to more facilities in operation on the Norwegian shelf. There are still insufficient resources on land to follow up and gain a full overview of the technical condition, barrier weaknesses and work outstanding on the facility. In connection with the transition to its assignment on the Norwegian shelf, manning offshore has increased from two shifts to three, due to the switch from the British to the Norwegian rota scheme. Resources on board the facility are insufficient for handling work/projects that arise in addition to individuals’ daily tasks.

COSLPioneer was issued with an Acknowledgement of Compliance on 17 June 2011. We have been informed that many fire dampers on the facility have been weakened for a long time. The weaknesses have been known to some of the management of the land and offshore organisation since 2022 (with reference to non-conformity 5.1.1). It was planned to repair the fire dampers for the five-year classification in 2023. Given the long delivery lead time for the equipment, it was planned to repair the weaknesses while in operation. It was only in 2025 that compensatory measures and repairs to weakened fire dampers were implemented. 3

In the cementing unit, CO2 was used as a fixed gas extinguishing system. In 2015, the Norwegian Maritime Authority banned the use of carbon dioxide as a extinguishing system. It was not planned to change the extinguishing system until the next five-year classification in 2028. It is incumbent on COSL to comply with and maintain all factors described in the AoC application, regardless of mode of operation and location, prior to deployment of the facility on the Norwegian shelf. Continued use of an AoC is contingent on the basis, assumptions and other stated conditions in the AoC being followed up and maintained.

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

  • Non-conformity handling
  • Information and plan to correct non-conformities
  • Compliance with procedures
  • Barrier management
  • Maintenance
  • CO2 gas extinguishing system
  • Fire doors
  • Ignition source control
  • Overview of condition of barriers relating to emergency power, emergency lighting and ignition source control
  • Work in electrical facilities
  • Competence of electrical personnel with foreign training
  • Electrical facilities
  • Wrong colour U light
  • Documentation

We also observed one factor that we have chosen to categorise as an improvement point. This concerned:

  • Integrity of the drilling derrick during hydrocarbon blowout

Follow-up of non-conformities

During the audit, we also verified how COSL Drilling has addressed previously identified non-conformities.

We found that the following non-conformity had not been addressed in line with COSL Drilling's feedback to us of 5 August 2024:

  • Non-conformity concerning “Deficient follow-up of safety systems” from chapter 5.1.3 of the report following the audit of 8 May 2024; our journal entry 2024/461

Order

The audit identified serious breaches of the regulations. We have now issued COSL Drilling with the following order:

Pursuant to the Framework Regulations, section 69 concerning administrative decisions, COSL is ordered to:

  1. establish performance requirements as necessary to make the individual barriers on COSLPioneer effective. The individual barriers shall be measured against the new performance requirements. Any weaknesses shall be made known to relevant personnel and a schedule shall be prepared for rectification of any weaknesses. See the Management Regulations, section 5 concerning barriers, paragraphs 4, 5 and 6.

    The deadline for complying with item 1 of the order:  19 September 2025.

  2. prepare an overview of all outstanding work on safety systems and barriers on COSLPioneer, with reference to non-conformities 5.1.6 - 5.1.10 and 5.1.13. Based on the overview, a plan shall be prepared that contains information about how COSL intends to rectify these non-conformities within a reasonable time, with reference to non-conformity 5.1.2 on information and plans to rectify non-conformities. See the Management Regulations, section 22 concerning the handling of non-conformities.

    The deadline for complying with item 2 of the order:  30 June 2025.

  3. implement necessary measures to ensure that procedures in COSL are used to fulfil their intended function, with reference to non-conformity 5.1.3 concerning compliance with procedures. The effect of the measures must be documented, with reference to the Activities Regulations, section 24 concerning procedures, paragraph 2.

    The deadline for complying with item 3 of the order:
  • implement necessary measures: 30 June 2025.
  • measure the effect of the measures: 19 September 2025.

Havtil is to be notified when COSL considers that the order has been complied with.