The legislation places the onus on operating oil companies to ensure the health and safety of all persons working in connection with petroleum activities in the Canada-Newfoundland and Labrador Offshore Area. Following authorization of the Operator’s activity, the Safety department staff monitors the implementation of the Operator’s Safety Management System. The Department reviews the following:
The Safety Department also monitors the daily operation reports and training exemptions submitted by the Operators.
The legislation requires that the Operator report all incidents to the C-NLOPB. The term Incident refers to any event that caused or, under slightly different circumstances, would likely have caused harm to personnel or the environment or an imminent threat to the safety of an installation, vessel or aircraft. It also includes any event that impairs the function of any equipment or system critical to the safety of personnel, the installation, vessel or aircraft or any event that impairs the function of equipment or system critical to the protection of the natural environment. The Guideline for the Reporting and Investigation of Incidents provides guidance to Operators on which Incidents are reportable to the Board.
In addition to specifying the reporting requirements, the Guidelines detail two types of notification to the C-NLOPB – an Immediate Verbal Notification and a Written Notification. The Guidelines specify which Incidents require an Immediate Verbal Notification. Operators direct all Immediate Verbal Notifications to the C-NLOPB Duty Officer at (709) 682-4426. For all Incidents, the Operator shall provide a written Written Notification to the Board and the Workplace Committee or Coordinator as soon as possible but no later than 24 hours after the Operator becomes aware of any Incident. The written notification may be submitted to the C-NLOPB by e-mail to firstname.lastname@example.org.
Operators shall investigate each Incident reported to the Board and submit a completed Incident Summary Report with all the required information to the C-NLOPB and the Workplace Committee or Coordinator as soon as possible, and in any event, no later than 21 days following an Incident, or 14 days following a Part III.1-defined Incident. For the purposes of submitting investigation reports, the Boards have prescribed the Incident Summary Report form, which can be used as either a full investigation report or as a supplement to an Operator’s own internal investigation report. For diving incidents, the Diving Incident Report form must also be completed.
Incident investigations should identify all failed or inadequate technical, human and/or organizational barriers or safeguards associated with the occurrence of an Incident and review the efficiency and effectiveness of the emergency response that occurs following an Incident. Incidents are an indication of the performance of a management system. Thus, it is important when an Incident occurs that the investigation goes beyond identifying failed barriers and determines the underlying root causes. By correcting the underlying root causes, Operators can prevent similar Incidents from occurring.
Each Incident Summary Report is reviewed by Safety Officers for completeness. This check includes a review of the identified root causes and actions taken to address the root causes, as well as the immediate causes. Various incidents are selected for further review by Safety Officers while on an installation for monitoring that corrective actions are being implemented and that the Operator’s incident investigation process is working effectively. Depending on the nature of the incident, the C-NLOPB may decide to conduct its own investigation. For additional information on the C-NLOPB investigation process, refer to Investigations.
The legislation requires that Operators submit injury/illness statistics to the C-NLOPB. Each quarter Operators are required to submit a Quarterly Statistics Report. This report contains a list of all major injuries, lost/restricted workday injuries, occupational illnesses, medical treatment injuries and first aid injuries along with exposure hours for each installation, vessel and aircraft operating in the Offshore Area. The Guideline for the Reporting and Investigation of Incidents provides guidance to Operators on the classification of injuries and illnesses and the format for reporting.
The Safety Department maintains a record of all incident and injury statistics for all Incidents dating back to 1986, the year that the C-NLOPB was formed. It is important to remember that these statistics are lagging indicators of a HSE management system. The lack of these statistics does not mean that a HSE management system is performing well. Operators should have leading indicators in place to measure that their HSE management systems are performing as intended.