NOU 2001: 21 Helicopter Safety on the Norwegian Continental Shelf

English summary, 21 June 2001.

The Committee for the Review of Helicopter Safety on the Norwegian Continental Shelf has in this review made it's recommendations regarding safety for helicopter traffic connected to petroleum activities on the Norwegian Continental Shelf. (21.06.2001)

June 21 st 2001

NOU 2001: 21 Helicopter Safety on the Norwegian Continental Shelf – Review 1: The organising of the public authorities' involvement

Summary in English

( Complete Norwegian version)

Mandate and approach

The Committee for the Review of Helicopter Safety on the Norwegian Continental Shelf was appointed by the Ministry of Transport and Communications 24 July 2000. The Committee was appointed to conduct the first of two reviews regarding helicopter traffic connected to petroleum activities on the Norwegian Continental Shelf. The mandate was to review the organising of the public authorities' involvement in this field. Based on an overview of all the laws and regulations as well as the public authorities and service providers, the Committee's scope has been to map and evaluate roles, tasks and responsibilities, how the supervision is carried out, indistinctness in laws and regulations etc.

The Committee had 10 meetings. In addition, the Committee had an excursion to the Civil Aviation Authority in the United Kingdom (UK CAA) and to Gullfaks C. In the United Kingdom the Committee also had two meetings with representatives from Shell Aircraft and British helicopter operators (Scotia and Bristow). Further, the Committee's leader and secretary met with the Dutch and Danish Civil Aviation Authorities, and at several occasions met for informal discussions. One meeting was held with an external reference group.

The Committee has had one secretary, plus some capacity from the Norwegian Civil Aviation Authority and SINTEF Industrial Management. The Committee's approach was based on distribution and individual review of relevant literature, Committee-discussions of roles/tasks/responsibilities and laws/regulations from the public authorities', helicopter operators' and oil operators' point of view. Additionally, the approach was based on an analysis of problem areas viewed from the phases of an offshore helicopter flight. In light of identified problems, the Committee has discussed potential improvements and made the recommendations.

Problems

The division of responsibilities between the public authorities is experienced as difficult to follow and creates confusion to the parties in this field. Problems are linked to the interface and overlap between the different authorities' responsibilities, tasks and laws/regulations, in addition to what is considered as the industry's own responsibility. This applies, in particular, to problems regarding offshore helidecks and other conditions near or on units that affect flight operations. It is the Committee's judgment that neither the Norwegian Petroleum Directorate, the Norwegian Civil Aviation Authority nor the Norwegian Maritime Directorate act as a driving force for promoting flight safety on the continental shelf. It is unclear to the parties involved which authority actually has the main responsibility as the central and active power to develop an follow up the regulations and systems that will make it safer to fly on the continental shelf. Probably, this is connected to the organising of supervision, for instance that the assisting authorities do not use the same amount of resources as they would had the responsibility been clearly stated. Historically, the Civil Aviation Authority has been too passive when it comes to regulating and supervising helicopter traffic on the continental shelf, neither has the Petroleum Directorate given this area sufficient priority. For these reasons the level of services, and thus safety, has to a great extent been handed over to the helicopter operators themselves in cooperation with the oil companies.

It is the Committee's opinion that neither the Norwegian Civil Aviation Authority, the Norwegian Petroleum Directorate nor the Norwegian Maritime Directorate act as a driving force for promoting safety in relation to helicopter safety on the continental shelf. As time has passed, these circumstances have led to inadequate and unclear minimum requirements and lack of common standards in some areas. For example, inadequacies in requirements for equipment, training and weather observations offshore has led to considerable differences in the quality of weather observations. One of the consequences is that the helicopter pilots often get inaccurate information and unreliable weather reports. This is, in the Committee's opinion, not satisfactory. The relationship between the Norwegian Air Traffic and Airport Management, the Norwegian Civil Aviation Authority, the Norwegian Petroleum Directorate and the Norwegian Meteorological Institute is unclear and the different authorities have no common understanding of their own responsibilities.

Generally, there is a need for better cooperation and coordination between the different parties within the helicopter activities on the Norwegian Continental Shelf. Simultaneously, there is a need for a more proactive risk based method of supervision.

The Committee's recommendations

  1. Division of responsibilities between the Norwegian Petroleum Directorate, the Norwegian Civil Aviation Authority and the Norwegian Maritime Directorate:
    The Committee recommends that the Norwegian Civil Authority is given extended authority in this field and thereby gets the main responsibility for fixed and mobile offshore units, cf. the Petroleum Act's definitions, on the Norwegian Continental Shelf. The Committee recommends that the existing agreement on assistance between the Norwegian Petroleum Directorate and the Norwegian Civil Aviation Authority is revised in order to change and clearly define the division of tasks and responsibilities, including the responsibility for coordination, for both the relevant authorities and other parties. The Committee is also requesting the relevant ministries to consider the consequence the above mentioned solution will have for Regulatory supervisory activities with the safety etc. in the petroleum activities on the Norwegian Continental Shelf (cf. Royal Decree 28 June 1985 no. 3388) and other relevant laws and regulations. It is essential that changes of the responsibilities are reflected in both agreements and rules (laws and regulations), in addition to the mentioned Royal Decree.
  2. The cooperation between the Norwegian Civil Aviation Authority and the Norwegian Maritime Directorate regarding mobile offshore units registered in Norway:
    The Committee recommends that an agreement between the Norwegian Civil Aviation Authority and the Norwegian Maritime Directorate is drafted, stating how the cooperation is to be implemented in the cases where the Norwegian Civil Aviation Authority is acting as an assisting authority. The agreement must clearly describe tasks and responsibilities of each party.
  3. Supervision of helidecks on board ships:
    The Committee recommends that a closer review is undertaken whether it is possible for Norway to regulate helidecks with appurtenant support functions on board ships taking part in petroleum activities on the Norwegian Continental Shelf. This depends on whether it is possible or desirable for Norway to regulate this in relation to international regulations. Furthermore, the Committee recommends that the Norwegian Civil Aviation Authority pay closer attention to helidecks on board ships on the Norwegian Continental Shelf. It is important that the authorities are conscious of the operational limitations and that procedures are made from case to case in cooperation with the helicopter operator.
  4. Councils, committees etc. in relation to promoting flight safety:
    The Committee recommends that a liaison committee for helicopter operations on the Norwegian Continental Shelf is appointed. Further, the Committee recommends that the Norwegian Civil Aviation Authority, through the Director General, is responsible for the establishment and management of the liaison committee, in addition to being responsible for following up recommendations and initiatives. It is essential that good follow-up routines are made. It is recommended that the liaison committee is constituted as soon as possible, as continuous focus and cooperation regarding flight safety issues on the Norwegian Continental Shelf are required. Risk and trend analysis, standardisation, research and development would be important tasks for the liaison committee.
  5. The Norwegian Meteorological Institute's role regarding meteorological services for aviation:
    The Committee recommends that better routines are made for the cooperation between the industry, the Norwegian Meteorological Institute and the Norwegian Air Traffic and Airport Management regarding establishment and extent of the meteorological services. The adopting of regulations on meteorology for aviation (BSL MET) should accelerate and include the meteorological services for aviation on the continental shelf. Further, the Committee recommends that clear minimum requirements regarding equipment, training etc. are stated and that such requirements are included in the mentioned regulations (BSL MET) being drafted by the Norwegian Civil Aviation Authority.
  6. Flying inspectors:
    The Committee recommends that a flying inspectors arrangement comes in effect as soon as possible and that the Norwegian Civil Aviation Authority establishes routines avoiding legal capacity-issues for the inspectors.
  7. Development of the relationship between the Norwegian Air Traffic and Airport Management and the armed forces:
    The Committee recommends that a close cooperation between the armed forces and the Norwegian Air Traffic and Airport Management is maintained in the future. In this context, the Committee refers to the developments under consideration on Haltenbanken and Ekofisk.
  8. Technical condition monitoring systems:
    The Committee recommends that the Norwegian Civil Aviation Authority requires use of technical condition monitoring systems (HUMS) for helicopter operations on the continental shelf. Simultaneously, the Committee urges the Civil Aviation Authority to a greater extent of proactivity regarding implementation of this and similar systems having possible crucial effect on flight safety.
  9. Risk based supervision, analysis of trends, coordination of risk analysis:
    The Committee emphasises the importance of a proactive risk based method of supervision focusing on helicopter transport and recommends initiatives to coordinate risk analysis made by the oil industry and helicopter companies. Relevant authorities should, in cooperation with the oil industry and the helicopter companies, establish a liaison committee for the exchange of information of risks and trends of the helicopter operations on the Norwegian Continental Shelf, cf. the suggested liaison committee for helicopter operations on the Norwegian Continental Shelf. Simultaneously, the Committee recommends that the Norwegian Civil Aviation Authority executes internal changes of the organisation that implies establishment of a well functioning proactive risk based supervision. The phrase "secure transport" in the Regulations relating to safety in the petroleum activities, cf. Royal Decree 27 June 1997, should be clearly defined and the conditions for fulfilling the requirement must be described.
  10. Work environment of helicopter crew:
    The Committee recommends that the supervision of work environment of helicopter crews is considered assigned to the Directorate of Labour Inspection and that the supervision in practice is carried out with the assistance of the Norwegian Civil Aviation Authority.
  11. Work environment of helicopter passengers:
    The Committee recommends that the Ministry of Labour and Government Administration considers the Act 4 February 1977 no. 4 relating to worker protection and working environment etc. made applicable for helicopter passengers on the Norwegian Continental Shelf.
  12. Mandatory use of simulator for helicopter pilots:
    The Committee recommends that the Norwegian Civil Aviation Authority considers mandatory use of simulator training for the helicopter operations on the Norwegian Continental Shelf. Simultaneously, the Committee refers to the second part of the review which will include further consideration of this issue.
  13. Relation to industry standards:
    The Committee recommends that requirements for helidecks, training, seat configuration in helicopter, survival suits, life jackets etc. are standardised and that the relevant regulations include a reference to the adopted industry standards. The suggested liaison committee for helicopter operations on the Norwegian Continental Shelf is a natural body to carry out standardisation work.
  14. The Norwegian Air Traffic and Airport Management as a public service provider; payment of costs for infrastructure:
    The Committee recommends that the principles for payment of fees, sharing of costs and contributions between public authorities and private parties are clearly defined and made more transparent by the Norwegian Air Traffic and Airport Management towards the oil industry.
  15. The Norwegian Air Traffic and Airport Management as an independent company:
    The Committee recommends that responsible authorities pay attention to possible unwanted consequences of the transformation of the Norwegian Air Traffic and Airport Management into an independent company and consequent demands for economical results. It is important to ensure that commercialising does not contribute to move focus from the Norwegian Air Traffic and Airport Management's core business: responsibility for flight safety and need for providing services and infrastructure in this context.
  16. International cooperation:
    The Committee recommends to formalise cooperation in a working group or committee between Norway, Denmark, the Netherlands and the United Kingdom. The group's tasks should be extended in relation to the work presently done in the Joint Aviation Authorities' Helicopter Sub-Committee. Today's work is limited to problems regarding operational conditions. Furthermore, the Committee recommends that cooperation is formalised with the United Kingdom in research and development as soon as possible, and that a sub-committee of the above recommended liaison committee is responsible for introducing and implementing the cooperation.


VEDLEGG