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 Newfoundland and Labrador offshore area. Following authorization of the Operator’s activity, the Operations and Safety department staff monitors the implementation of the Operator’s Safety Management System. The Department reviews the following:
- Reporting and Investigation of Incidents
- Reporting of Injury Statistics
- Joint Occupational Health and Safety Committees
- Complaints
The Operations and Safety Department also monitors the daily operation reports and training exemptions submitted by the Operators.
Reporting and Investigation of Incidents
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 to other agencies, the Guidelines require two types of notification to the C-NLOPB – an Emergency Notification and a Written Notification. The Guidelines specify which Incidents require an Emergency Notification. Operators should direct all immediate or Emergency Notifications to the C-NLOPB Duty Officer at (709) 682-4426. For all Incidents, the Operator shall provide a written Incident Notification to the Board and the Offshore Joint Occupational Health and Safety Committee or Representative 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 incident@cnlopb.nl.ca.
Operators shall investigate each Incident reported to the Board and submit a completed Incident Investigation report will all the required information to the C-NLOPB and the Offshore Joint Occupational Health and Safety Committee or Representative as soon as possible, and in any event, no later than twenty-one days following an Incident. For the purposes of submitting investigation reports, the Boards have prescribed the Incident Investigation 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 other Incidents from occurring.
Each Incident Investigation 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 Operations and 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.
Reporting of Injury/Illness Statistics
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 Operations and 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.
Joint Occupational Health and Safety Committees
A Joint Occupational Health and Safety Committee is required on each offshore installation. This committee, which is made up of equal numbers of management and worker representatives has a duty to monitor the health, safety and welfare of the workers employed at the workplace. They are required to participate in workplace inspections, establish and promote health and safety educational programs for workers, receive complaints, make recommendations for improvement to the safety management system and to identify aspects of the workplace that may be unhealthy or unsafe. The Joint Occupational Health and Safety Committee must also be immediately notified of incidents in the workplaces and are expected to review incident investigation reports.
The requirements and authority of Offshore Joint Occupational Health and Safety Committees are defined in the Draft Newfoundland Offshore Area Petroleum OSH Regulations and the “Other Requirements Respecting Occupational Health and Safety” that are conditions of approval for each authorization. The guide on “Occupational Health and Safety Committees” from the Workplace Health, Safety and Compensation Commission of Newfoundland and Labrador provides further guidance on the duties of a committee.
The committee onboard an installation will normally meet at least once every three weeks. Minutes of each meeting are submitted to the C-NLOPB and reviewed by Safety Officers as evidence that committees are functioning effectively and are operating in compliance with the requirements.
While onboard an installation, Safety Officers meet with members of the Joint Occupational Health and Safety Committee. In addition, on an annual basis, the C-NLOPB holds a workshop with members of all offshore Joint Occupational Health and Safety Committees to share lessons learned, discuss suggestions for improving health and safety onboard the installations, discuss current issues and to provide feedback.
The Operations and Safety Department has a process in place to deal with all health and safety related complaints. Any person who has a complaint related to offshore petroleum operations may contact one of the Safety Officers by telephone, in writing or in person.
A Safety Officer will be assigned to assess each complaint, conduct a review of the facts surrounding the complaint, take or recommend action as necessary and will respond to the complainant once the review has been completed. Board staff will not divulge a complainant’s name without their permission unless required by law and will make every effort to maintain a complainant’s confidentiality. Complaints may be submitted anonymously; however, anonymous complaints are more difficult to investigate, as we are not able to have an ongoing dialogue with the complainant and will not be able to provide a response to an anonymous complainant once the review has been completed.