Rom for bransjestandard? (Need for an industrial standard?) About regulatory authority, HOFO,...

1

Rom for bransjestandard?(Need for an industrial standard?)

About regulatory authority, HOFO, industrial standards and safety

Solakonferansen 22.09.2015

Øivind Solberg, PhD Solberg Risk & Safety

2

BackgroundEASA in the process of introducing new

regulations for off shore helicopter operations (HOFO)

Residing marked Pressure on cost reduction Increased competition

Safety implications?



3

The EASA (HOFO) regulationCommission Regulation

(EU) No 965/2012



4

The EASA rulemaking process The Terms of Reference (ToR) Regulatory Impact Assessment (RIA) Rule making Task (RMT) NPA Notice of Proposed Amendment CRD EASA Comment-Response Document Opinion and draft Commission

Regulation From EASA to the EU Commission for

decisionSolakonferansen 22.09.2015


5

EASA Notice of Proposed Amendment (NPA) 2013-10

Summary of the regulatory issuesThe safety risks may increase due to uneven

implementation of Commission Regulation (EU) 965/2012Leading to an uneven playing field in relation to

helicopter operations to offshore destinations. The following items need to be considered to ensure a

safe level playing field with proportionate common European requirements: Common definitions for offshore operations, offshore

location, and hostile environment; Helideck landing and take-off PC-2 procedures; and Harmonised requirements and means of oversight

(specific approval). Solakonferansen 22.09.2015


6

Main risk factors (listed in NPA)Single-load-path structure designFailure of components or systems due to fatigue risk Hostile environmentInsufficient authority oversightLack of contact with helicopters as they are outside radarInsufficient human operational performance Improper use of automatic flight control systems by crew Insufficient/lack of procedures for offshore approaches Insufficient offshore related trainingMid air collisionControlled flight into the sea



7

Draft Commission Regulation 965/2012

SPA.HOFO.105 Approval for helicopter offshore operations

(a) Prior to engaging in operations under this Subpart, a specific approval by the competent authority shall have been issued to the operator.

(b) To obtain such approval, the operator shall submit an application to the competent authority as specified in SPA.GEN.105, and shall demonstrate compliance with the requirements of this Subpart.

(c) The operator shall, prior to performing operations from a Member State other than the Member State that issued the approval under (a), inform the competent authorities in both Member States of the intended operation.




8

The next steps in the legislative procedure

Opinion 4/2015 contains proposed changes to European Union regulations

It is addressed to the European Commission, which uses it as a technical basis in order to prepare a legislative proposal

Commission vote scheduled for October 2015 The Decision containing the related

Acceptable Means of Compliance (AMC) and Guidance Material (GM) will be published by the Agency


9

The future?



7

10

Implications on safety?



11

Regulatory implications?Regulatory bodies

Formal:EASANorwegian Civil Aviation AuthoritiesPetroleum Safety Authority Norway

Commercial:Norsk Olje og Gass (Guidelines 066)



12

Current situation

Standards (NoG, OGP, oil companies requirements)

Regulatory bodies EASA, CAAN, Ptil



13

Scenario A (given a HOFO implementation)

CAAN will only be informed of operationNoG 066 Guidelines will be the operating

standardNoG will in practise be the regulatory body,

not the CAANRegulatory oversight will be by the state

giving the SPA



14

Scenario A

Standards (NoG, OGP)

- Regulatory body EASA- Oversight SPA Member State



15

Scenario B (given a HOFO implementation)

CAAN informed of operationPetroleum Safety Authority Norway (Ptil) may

inflict requirements inside the 500 meter safety zone

Outside 500 meter zone, HOFONoG 066 Guidelines will be the operating

standardPtil and NoG will in practise be the

regulatory bodies, not the CAANSolakonferansen 22.09.2015


16

Scenario B

Standards (NoG, OGP)

Regulatory body Ptil, EASA and Member State giving SPA



17

Scenario C Norwegian Continental Shelf (still) exempt

from EU regulation, will yield no change.Status Regulation(EC) 1008/2008 (on

common rules for the operation of air services in the Community)?

EEA Court of Justice ruling regarding the continued exemption of the Norwegian Continental Shelf

In case of NCS exemption the CAAN will continue to be the regulatory body



18

REGULATORY ISSUES (RISKS)

Commercial actors (NoG and oil companies) becoming, in practise, the regulatory body

Shared regulatory responsibility between Ptil and NoG

Unclear roles and responsibilities in regulating off-shore operations

Unclear role for CAAN in relation to offshore operations



19

REGULATORY ISSUES (RISKS)

Approving Member State not familiar with North Sea off shore operations

Insufficient basis for granting approvalApproved helicopter operator not sufficiently

skilled or equipped?



20

OTHER RISK FACTORSCAAN “sidelined”?Introducing “low cost” helicopter operatorsCost reduction focus in oil companies, may lead

to a reduction in standardsOil companies with own helicopter operations

(EU AOC, non commercial, hence not under subpart K)



21

Mitigating factorsNoG standard can still be enforced through

contractual requirementsPtil can enforce requirements in 500m zone

(in cooperation with CAAN)Samarbeidsforum for helikoptersikkerhet på

norsk kontinentalsokkel can still be operational and influential

Still an open issue regarding EU Regulation 1008/2008 regarding an exemption for the Norwegian continental shelf



22

What about the CAAN?CR 965/2012 ARO.GEN 300 (d)

Without prejudice to the competences of the Member States and to their obligations as set out in ARO.RAMP, the scope of the oversight of activities performed in the territory of a Member State by persons or organisations established or residing in another Member State shall be determined on the basis of the safety priorities, as well as of past oversight activities.



23

What about the CAAN?CR 965/2012 ARO.GEN 300 (d)

Where the activity of a person or organisation involves more than one Member State or the Agency, the competent authority responsible for the oversight under (a) may agree to have oversight tasks performed by the competent authority(ies) of the Member State(s) where the activity takes place or by the Agency.



24

Given the proposed version of CR 965/2012

EASA CR 965/2012 Annex IV, SPA Subpart kNorwegian Oil and Gas recommended

guidelines for flights to off shore installationsOGP - Air transportation - Recommended

practices for contracted air operationsOil companies – different internal

requirementsHelicopter operators manuals and handbooks



25

Enhancing safety



Available technology

Regulatory opening

HSS (I, II, III)

Norwegian Offshore Safety

BoardSamarbeidsforum

NoG requirements

#066

Contractual requirement

s

Operator Implementat

ion

Monitoring by the Common

Audit

26

GOING FORWARDNorwegian offshore safety boardNoG standardsThe safety studiesThe Common audit



27

An analogy –working with issues on risk and safety



http://www.google.no/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCPOVprDQiMgCFYX_LAod83wA0A&url=http://www.fxstreet.com/education/learning-center/unit-4/chapter-4/record-keeping/&psig=AFQjCNFQKiXA_IdMOO6cI8VqrqoqCyOtZQ&ust=1442941899077039

http://www.google.no/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRxqFQoTCKv_jtjQiMgCFYzXLAodGWsPzw&url=http://www.offshoreenergytoday.com/nigeria-at-least-four-killed-in-offshore-helicopter-accident/&psig=AFQjCNHHGGTX_bx5KhjA_lp9gvBZLKY0SA&ust=1442942170410714

28

Thank you



Rom for bransjestandard? (Need for an industrial standard?) About regulatory authority, HOFO,...

Documents

Transcript of Rom for bransjestandard? (Need for an industrial standard?) About regulatory authority, HOFO,...