CHALLENGES FOR NEW

OPERATORS
- IN COMPLYING WITH PSAS REGULATIONS

Sonja D. Tinnesand, Acona AS

ACONA AS - ORGANISATION
CEO
Oddbjrn Kopperstad

Corporate Services

Finance

Mari Melbye

Njl Arne Vathne

Business Devt &

Contracts

HSE&Q

Stig Hetlevik

Rune B. Vik

Drilling and Well

Technology

HSE & Risk

Incident Coordination
Centre

Subsurface and Flow

Technology

Thorleif Totte Lager

Svein Olav Drangeid

Vidar Gade

Stig Hetlevik

BACKGROUND
Acona assists both large and small operators:
Coordination of applications for consent
Drilling Management projects

Essential to Acona:
Give advice to the operators based on understanding of PSAs
practice
The personnel in Drilling Management projects need to know
PSAs practice

This presentation shows the issues we emphasize

New operators clearly face challenges concerning
understanding and practice
PSAs enforcement as experienced through their evaluations of
new operators applying for consent to drill for the first time

LEARNING PSAS

ENFORCEMENT

PSA prioritise supervision of new operators starting up drilling

activities on the NCS for the first time
Part of their yearly supervision plan
Note that it is on the NCS for the first time

New operators should not underestimate PSAs requirements

Size, cost or time span of the operations have no significance

A consent from PSA reflects confidence in the operators ability

to perform activities in compliance with requirements
The operator has to convince PSA that the basis for confidence is valid
PSA can not be expected to be more lenient towards new operators or
to give them more time rather the contrary
Established operators may supply information and develop actions up
to start of drilling ativities new companies should not

LEARNING PSAS

ENFORCEMENT

Operator should consider withdrawal of an

application for consent to drill if
PSA gives signals that the application is not good enough
PSA stresses requirements / ask for explanations which the
company realises that they are not able to fulfill or revert to
in a satisfactory way

LEARNING

ORGANISATION AND

USE OF CONTRACTORS
All plans presented at pre-qualification have to be fulfilled
Requirements towards operators organisation are
comprehensive, especially the see-to-it-duty and follow up
Not a question of numbers only
Qualifications and experience are as important

Give attention to the planning phase and preparations for

drilling not only the result
Qualification and follow up of contractors
Implementation of own management system
Documented criteria for decision

Insufficient management, capacity and competence in the

planning phase were reasons behind the PSAs refusal of
Premier Oils application for consent, ref letter from PSA
25.06.2010

LEARNING

ORGANISATION AND

USE OF CONTRACTORS
To be pre-qualified 1 2 persons in drilling and 1 in
HSE department are considered sufficient
For planning and exectuion of a drilling operation
the organisation has to be strengthened and
extended, especially in drilling
This can be done in three ways
Employing necessary personnel in own organisation
Temporary placement of personnel from mother
organisation
Use of contractors for drilling managment

LEARNING

ORGANISATION AND

USE OF CONTRACTORS
Regardless of solution the number of personnel is
not suffcient
Experience / competence counts a lot

If the choice is placement or contractors, the

operators own organisation have to be strengthened
See-to-it-duty, management systems and follow up
These solutions may be considered a challenge, not a
strength for the organisation

LEARNING

ORGANISATION AND

USE OF CONTRACTORS
Building the organisation should be done as early as
possible in the preparation process preferably before
detail planning starts
To be able to qualify contractors

Deficiencies in own organisation cannot be solved

through use of contractors
on the contrary this will require more internal competence

Using other operators and their competence is regarded

likewise
under the regulations they are filling the role as contractor

PSA also considers the total competence of the license

group
In the letter to Premier Oil the limited experience of the license
is mentioned as part of the reason behind the refusal

LEARNING

ORGANISATION AND USE OF

CONTRACTORS
In letter of 18.06.2006 PSA states the expectations
towards the content of an application for consent to
drill, when using drilling management contractors:
Operators qualification of contractors management system
before start of activities. This should cover:
Results of the qualification (the management systems suitability
wrt the activities to be performed)
Description of any actions the operator has considered necessary
Follow up of these actions

The operators verification program towards contractor during

activities
The operators verification program towards own organisation
regarding planning of activities
The authorities of operator and contractor in handling of
deviations (incl follow up of AoC) and emergency preparedness
management

LEARNING MANAGEMENT

SYSTEMS

To comply with requirements for documentation the

management system is the main tool
Documenting processes, procedures and decisions necessary to
get approval for consent
A fully implemented management system have to be in place
when the planning of activities start
PSA will not accept management system being finalized the last
weeks before start of drilling activities operators should not
accept this from their contractors either
The operators actual use of systems is an issue; PSA expects to
see routines, documents and databases being used in the
planning phase
Operator can not use mother companys systems or documents
without these being implemented as part of the Norwegian
organisations system
All necessary documentation have to be updated and available
when the application for consent is submitted

THE

USE OF BEING PRE-QUALIFIED

Pre-qualification = to be approved as either licensee

or operator
Being entitled to apply for (part of) production
license and / or operatorship
Not entitled to anything else: all applications,
approvals etc necessary for an activity have to be
individually substantiated
Requirements for documentation can not be fulfilled in
advance they are directed towards specific activities

CHALLENGES - SUMMARISED
Foreign companies:
Understanding the Norwegian administrative practice
Understanding how to act in accordance with a functional
legislation
Understanding the see-to-it-duty

All companies:
Acknowledge the importance of management in the
planning phase
Implementation of good management systems adapted to
the activities

13

MAXIMISING
POTENTIAL

acona.com