Some of the procedures were dated back to 2017 (e.g. Waste Management Procedure, ref. /3/) and some contained contradicting information (e.g use of HMS Riskview, EcoOnline, SafeUse). ISO-9001:2015 states that the organisation shall ensure appropriate review and approval

Update old procedures

Implement 3 yearly of policy’s, manuals and procedures review. Update the specific procedure for Waste management

Identification of human rights. Human rights have had increased focus in the industry. The Transparency Act enters into force July next year.

This law entails that companies are required to identify and evaluate actual and potential negative consequences for fundamental human rights and working environment that the company has contributed to, included its subcontractors. Mitigating measures to reduce the negative consequences are also required to be established and in general, the company shall have knowledge about human rights in the industry they are operating in, the risk and how this is handled.
Human rights aspects are not a requirement yet, but a major focus area for operators.

Plan for risk assessment with regards ti human rights for EDR. (deadline to implement is July 2022 when the Transparency law is set to force).

Chemicals used on equipment. The operator is required to apply for usage and discharge of chemicals to the Norwegian Environment Agency (Miljødirektoratet). The application includes a list of all chemicals planned for the operation. Wellesley are dependent on input from suppliers. During the workshop visit, the verification team was made aware of grease used on the hose/wire. EDR informed that the grease has a “green” environmental category, and a revised application is therefore not necessary, but usage and discharge is required to be reported. HOCNFs are required for chemicals that will be discharged, e.g. grease on hoses, ref. the Activity regulation §62.

Better communication with Operator

The chemical does not obtain HOCNF and the equipment is only used after the 5 year maintenance. EDR has put the chemical on the substitution list.

Risk matrix for Environmental Aspects EDR has made a good overview over the environmental aspects. Each aspect is given a score, but the score is not related to a risk matrix, so it is difficult to determine what the score is based on. In the evaluation sheet for each aspect, the score is given and clearly marked with a colour based on the score. Green is “low environmental aspect” and yellow is “medium environmental aspect”. On the main page, score 1, “green colour” is defined as “less or no impact to the environment”, and Score 2, “yellow,” is defined as “moderate impact to the environment”. The verification team suggest aligning these definitions. Also, the Hazardous waste aspect is given a score 1, but “medium environmental aspect”.

Update the matrix

Update the method and the procedure Environmental aspects to clearly set criteria for significant environmental aspects.

Due dates for job specific risks. The verification team finds it very positive that a risk assessment for Hemispheres has been carried out. However, no deadline set was for closing the risks.

Update risk assessment

Due date has been added in the risk assessment for this project. Communicated to PM that the risk assessment shall always be filled in and followed up.

WEC Report for Q2. A meeting with the WEC is held quarterly, but the report form Q2 was not available on the HSE board in the workshop or in the office building. WEC meeting for Q3 was postponed due to vacation.

Print report to make it available for everyone

WEC meeting was held by the deputy in this case and the routine for posting the meeting reference at HSE boards was not followed. A new meeting Q# has now been held and MOM is posted on the HSE boards. Routine for communication of results after WEC has been communicated to all WEC members.

Name of work order system. Slide 13 states that “Fiicks” is used for work orders, but the flow chart on slide 24 illustrates that “Fiix” is used. “Fiix” is used in this report.

The correct name is Fiix and document has been updated.

Some of the procedures were dated back to 2017 (e.g. Waste Management Procedure, ref. /3/) and some contained contradicting information (e.g use of HMS Riskview, EcoOnline, SafeUse). ISO-9001:2015 states that the organisation shall ensure appropriate review and approval

Update old procedures

Implement 3 yearly of policy’s, manuals and procedures review. Update the specific procedure for Waste management

Identification of human rights. Human rights have had increased focus in the industry. The Transparency Act enters into force July next year.

This law entails that companies are required to identify and evaluate actual and potential negative consequences for fundamental human rights and working environment that the company has contributed to, included its subcontractors. Mitigating measures to reduce the negative consequences are also required to be established and in general, the company shall have knowledge about human rights in the industry they are operating in, the risk and how this is handled.
Human rights aspects are not a requirement yet, but a major focus area for operators.

Plan for risk assessment with regards ti human rights for EDR. (deadline to implement is July 2022 when the Transparency law is set to force).

Chemicals used on equipment. The operator is required to apply for usage and discharge of chemicals to the Norwegian Environment Agency (Miljødirektoratet). The application includes a list of all chemicals planned for the operation. Wellesley are dependent on input from suppliers. During the workshop visit, the verification team was made aware of grease used on the hose/wire. EDR informed that the grease has a “green” environmental category, and a revised application is therefore not necessary, but usage and discharge is required to be reported. HOCNFs are required for chemicals that will be discharged, e.g. grease on hoses, ref. the Activity regulation §62.

Better communication with Operator

The chemical does not obtain HOCNF and the equipment is only used after the 5 year maintenance. EDR has put the chemical on the substitution list.

Risk matrix for Environmental Aspects EDR has made a good overview over the environmental aspects. Each aspect is given a score, but the score is not related to a risk matrix, so it is difficult to determine what the score is based on. In the evaluation sheet for each aspect, the score is given and clearly marked with a colour based on the score. Green is “low environmental aspect” and yellow is “medium environmental aspect”. On the main page, score 1, “green colour” is defined as “less or no impact to the environment”, and Score 2, “yellow,” is defined as “moderate impact to the environment”. The verification team suggest aligning these definitions. Also, the Hazardous waste aspect is given a score 1, but “medium environmental aspect”.

Update the matrix

Update the method and the procedure Environmental aspects to clearly set criteria for significant environmental aspects.

Due dates for job specific risks. The verification team finds it very positive that a risk assessment for Hemispheres has been carried out. However, no deadline set was for closing the risks.

Update risk assessment

Due date has been added in the risk assessment for this project. Communicated to PM that the risk assessment shall always be filled in and followed up.

WEC Report for Q2. A meeting with the WEC is held quarterly, but the report form Q2 was not available on the HSE board in the workshop or in the office building. WEC meeting for Q3 was postponed due to vacation.

Print report to make it available for everyone

WEC meeting was held by the deputy in this case and the routine for posting the meeting reference at HSE boards was not followed. A new meeting Q# has now been held and MOM is posted on the HSE boards. Routine for communication of results after WEC has been communicated to all WEC members.

Name of work order system. Slide 13 states that “Fiicks” is used for work orders, but the flow chart on slide 24 illustrates that “Fiix” is used. “Fiix” is used in this report.

The correct name is Fiix and document has been updated.