Question
On board this facility one of the deck crew works night shift. He is alone during the night and his main roll would be to answer fire alarm calls and to relieve the engine control room operator and the radio operator for meal breaks as these persons are also alone during the night.
Over the last few months certain members of the senior management on board have been giving out long work lists to the night shift person expecting him to paint and wash down the outside of the facility during the night. I am a VO on board the vessel and it has also been brought to my attention that some of these jobs include working at heights in dark places while the person is alone.
Having looked at the activities regulations section 33 on organisation of work, would it be right to say that anything other than essential work should be carried out during the day?
Answer
The overriding principle of the activities regulations and section 33 is risk reduction, cf. the wording of the first paragraph of this section, "to reduce the probability of mistakes that can lead to hazard and accident situations".
This is also reflected in the third paragraph, saying that "work shall be planned such that as much work as possible is carried out during the daytime, and such that the employees are ensured the necessary rest and restitution", implying, among other things, that"night work shall be limited to tasks and functions necessary to maintain prudent activities", cf. the guidelines to section 33 (sixth paragraph). This is further elaborated in the interpretation "Night work" (use the link provided in the regulations).
Said interpretation is in Norwegian only, but what it says about section 33 third paragraph, is that the intention of the requirement is to prevent any consequences detrimental to the safety of the individual employee and the petroleum activities, and to reduce any health detrimental effects caused by night work. It also says that the "shall be limited to" tasks and functions that are mentioned above, may be activities necessary to maintain production and activities directly related to drilling and well operations.
Such tasks may also encompass maintenance activities that are necessary to restore physical barriers. Any preventive or corrective maintenance that is not directed at restoring functions that are critical to health, environment and safety, shall be planned done in daytime, cf. the activities regulations section 46 on classification.
Note also that section 33 must be seen or read in context with the framework regulations chapter IIon basic requirements for health, safety and the environment (including risk reduction, cf. above) and the management regulations sections 11 on basis for making decisions and decision criteria, section 12 on planning, section 14 on manning and competence and section 18 on working environment analysis.
As should be evident from the above, any work that is to be performed, be it during the day or during the night, comes under the requirements to planning, manning, competence, safety clearance, safety measures, monitoring and control etc., cf. also the activities regulations chapter VII on planning and execution and chapter VIII on working environment factors. In addition, night work comes under the limitations mentioned and elaborated above.
See also the framework regulations section section 43 on night work.