Compliance Tools

The Board assesses and establishes an operation’s state of compliance with legislation and authorizations through compliance monitoring, audits and inspections.

Compliance Monitoring

Compliance monitoring includes both active monitoring through, audits and inspections and passive monitoring through review of various reports submitted by the operator. The Board also reviews the following:

  • Reporting and Investigation of Incidents
  • Reporting of Injury/Illness Statistics
  • Complaints

Each Operator is required to monitor its own state of compliance by sampling, testing equipment, monitoring working environments, reporting incidents such as spills or worker accidents, monitoring production rates and the performance of measurement equipment and depletion schemes, identifying opportunities to improve recovery by drilling infill wells or by adapting new technology or methodology and reporting unusual incidents to demonstrate its continual compliance with statutory requirements. This information is reported to the Board either periodically, or within a specified, shorter timeframe when a significant non-compliance event occurs.

Audits and Safety Inspections

An audit is a systematic evaluation of all aspects of an operation to determine its overall compliance with regulatory requirements related to safety, environmental protection and resource management, and commitments made by the Operator in their application for an authorization. Audits include reviewing documentation and records, obtaining samples, interviews with personnel, verification of the quality of information reported to the C-NLOPB, inspection of equipment or other physical aspects of an operation, observation of operations, verification of qualifications and training of personnel.

An Inspection involves the physical presence of an Officer at an operation. An inspection focuses on the compliance of the facilities and equipment or on specific physical operations, which require a visit to an offshore facility. Inspections verify that operators are following applicable statutory requirements which include following their safety and environmental protection plans and may also verifying completion of investigation of audit corrective actions.

During a safety audit, C-NLOPB Safety Officers can raise a non-compliance against anything that does not conform to the Operator’s safety management policies and procedures or to legislative requirements. There are two types of non-compliances:

  • Observation – A statement of fact related to a non-compliance made during a safety audit or safety inspection and substantiated by objective evidence.
  • Finding – A conclusion substantiated by one or more observations, which highlights significant issues with the implementation of the Operator’s safety management policies and procedures, adherence to legislative requirements and/or any non-compliance that has significant implications for safety.

Following the issuance of an audit report, an Operator has fifteen working days to provide an action and timeframe that is acceptable to the C-NLOPB. The Operator must take action to address non-compliances within the agreed timeframe. Failure to comply within that timeframe could result in an order to comply or, depending on the seriousness, could constitute an offence under the Act.

Investigations

Operators normally investigate all incidents and submit a report to the Board (Reporting and Investigation of Incidents). However, the legislation also provides the ability for the C-NLOPB to conduct an investigation into any occurrence under its jurisdiction. Thus, where Board staff suspect a violation of the legislation or receives a report of an incident, the Chief Safety Officer or Chief Conservation Officer may initiate an investigation or request an Operator to conduct their own investigation. Investigations could also be initiated in the event that Board staff was not satisfied with an Operator’s investigation report.