Internal requirements for updating WE MS procedures have recently been changed from every 2 years to «when needed». Some procedures have been in draft for quite some time (ref How WE Manage HSEQ in Well Projects and How WE Manage Chemicals Management). Module for Improvement Suggestions in WE Report can also be used for improvement suggestions.

It is unclear to the audit team how and where the process of updating procedures/internal requirements is documented.

23.12.2024: “How WE Control Documents and Registrations» section 3.1.3 “Revision Control”, was updated 15.05.24 to “5 years, or when needed”.
We have a document register, also linked as a quick link on our home page (internal site), that gives an overview of revision and date of alle prevailing procedures and tools. It is the QHSE & Sustainability Manager’s responsibility to secure that this register, and hence all procedures, are up to date. The register is followed up on regular basis. When a new update/revision of a procedure is ongoing, it is stored as “DRAFT”. So anyone having an update can put it in. Or they can suggest an update in WEReport.
10.01.2025: OK. Closed by DNO

According to WE-M-QHSE-MA-01 How WE Manage Well Expertise chapter 1.1, WE Management System is designed to be ISO 14001:2015 compliant. In the same document, it is stated in Table 7-1 and chapter 7.2.2. that company context, interested parties and environmental aspects shall be revised annually. Company context and stakeholder analysis are documented in WE-MQHSE-MA-01 and last updated in June 2021. Company context, interested parties and environmental aspects are all part of the agenda in the yearly Management Review, and the presentation from the meeting is also Minutes of Meeting (MoM) where actions are noted and members from the WE Management Team made responsible. The actions are checked in the next Management Review.

In the Management Review presentation/MoM, the conclusion of the review is not properly documented. Actions will be recorded only if updates to WE-M-QHSE-MA-01 How WE Manage Well Expertise are needed. The Management Review is neither recorded in WE Report.

23.12.24: Feedback to DNO – WE plan for the Management Review in Q1/March 2025. The Management reviews is documented in ppt presentations, and all actions agreed on have been listed there and followed up in the following Management Meetings. But we admit that the actions could have been followed up in a better way, i.e. in WEReport.
10.01.2025: OK. Closed by DNO
20.03.25: Actions from the Management Review added in WEReport

IMP-1: Records from chemical suppliers, rig etc. are stored in internal WE folders (SharePoint), and the full history of WE wells are available. However, as no retention time for records are described, there is a risk that records could be deleted unintentionally.

WE Environmental Reporting System (including records) is not made available to DNO, thus DNO is dependent that WE do the necessary QA of data. This could be improved by extracting a full report from CMS Portal and store on project SharePoint as part of End of Well reporting.
It is also recommended to agree and describe retention time for records of environmental data in project documentation.

23.12.24: Feedback to DNO – We are somewhat uncertain on the requirements on this issue regarding retention time. The Accounting Act says that primary documentation must be kept for 5 years. WE state in “How WE Manage Well Expertise” that we work according to prevailing regulations. The Accounting Act is listed as one of them.
To date, we have not deleted any data since the start of WE. The CMS Portal does only keep record of applied amounts of chemicals and operational accounting, and all information is provided in the annual report to NEA, so we are a little unsure of what DNO actually needs. Do you want access to all waste reports and section reports from drilling fluid and cement, etc.? If so, this can be provided for Falstaff and Kjøttkake (and coming wells) .
10.01.2025: Yes, DNO would like to have access to the detailed environmental records on waste, chemicals, fuel etc for Norma, Falstaff and upcoming wells. We suggest this is done for Falstaff as part of EoW reporting, and a separate folder with environmental records is uploaded to the project SharePoint site. If there are other suggestions on how the sharing of records can be done more effectively, we are happy to discuss this. Reference is also made to the Management Regulations §42 on retention of information, which states that the operator shall keep environmental data “as long as necessary”. Thus, it is important for DNO to have control of this data.
27.02.2025: Operational environmental documentation for Norma and Falstaff uploaded to DNO SP

IMP-2: A thorough process for identifying project Environmental Aspects and taking the outcome further into risk management and/or BAT assessments has newly been implemented in drilling projects. This has been successful, and DNO/WE has agreed that this is to be standard also for upcoming projects.

It is therefore recommended to include a description of the processes in future project HSE plans.

23.12.24: Feedback to DNO – Mapping environmental aspects will be secured in coming DNO projects
10.01.2025: OK. Closed by DNO

Procedure for How WE Manage Suppliers chapter 5.1 uses the term «Environmental Exposure».

It is recommended to clarify if this is related to external environment or working environment/occupational health.

23.12.24: Feedback to DNO – We will secure that a clarification on Environmental Exposure in How WE Manage Suppliers
10.01.2025: OK. Closed by DNO
24.02.2025: Fixed in Draft version no. 05 of the procedure.

A-1: Check access to WE Report for DNO (ARV, LL etc)

DNO/WE action

23.12.24: Feedback to DNO – As mentioned by Morten in the Audit, DNO should already have access to these modules in WEReport. DNO (Arild, Stein Arild?) need to check. If not, this can be provided.
10.01.2025: DNO has access to WEReport, but currently none of the environmental personnel has access. Could you please provide access for Grete and Valborg?
03.02.2025: Access granted

A-2: Meeting DNO/WE on reporting/ESG: What is DNO need, and what can WE
deliver? Include discussion on access to WE CMS.

DNO Action

23.12.24: Feedback to DNO – It is our understanding that DNO will not continue the work with Stepvise. In this process I guess DNO has done some evaluations on what they need. We are happy to have a meeting to discuss the potential for using WEReport/Corporate Footprinting.
10.01.2024: DNO is in the process of acquiring an environmental accounting system, and thus the need for a meeting with WE regarding access to the WE CMS will have to be evaluated according to the conclusion of this process.
24.02.2025: We have been told that DNO most probably will go for NEMS. We have not been invited to present our system…

A-3: Check how comment from NEA on yearly report 2023 for exploration drilling has been followed-up

23.12.24: Feedback to DNO – We have set a deadline for 15th January 2025.
24.02.25: “How WE Manage QHSE in Well Projects” updated to secure that we look into diesel usage an emissions as part of calculations in AfD by looking at historical data (special attention to type of operation and anchoring vs DP), and describing any deviations from the permit (increased emissions or decreased emissions) in the annual report to NEA. Information accepted by DNO – Action closed

A-4: It seems to be some double-reporting in WE Report/PIMS/Share Point – eg.
on ARV, Incidents and MOC. Go through the reporting routines together with
WE to see if there are unnecessary double-reporting that could be simplified.

DNO Action

23.12.24: It seems like the ARV module is not used by DNO, as WE has to document status on ARV findings in projects in a separate excel sheet in each project. Access should have been granted when access to the LL module was granted. Ref. A-1.
10.01.2025: DNO has discussed this internally, and concluded there is a need for the Excel sheet on SharePoint in order for DNO to ensure that ARV findings are closed out. It is also serving an archive purpose to ensure necessary ARV documentation is also stored in DNO PIMS.

Internal requirements for updating WE MS procedures have recently been changed from every 2 years to «when needed». Some procedures have been in draft for quite some time (ref How WE Manage HSEQ in Well Projects and How WE Manage Chemicals Management). Module for Improvement Suggestions in WE Report can also be used for improvement suggestions.

It is unclear to the audit team how and where the process of updating procedures/internal requirements is documented.

23.12.2024: “How WE Control Documents and Registrations» section 3.1.3 “Revision Control”, was updated 15.05.24 to “5 years, or when needed”.
We have a document register, also linked as a quick link on our home page (internal site), that gives an overview of revision and date of alle prevailing procedures and tools. It is the QHSE & Sustainability Manager’s responsibility to secure that this register, and hence all procedures, are up to date. The register is followed up on regular basis. When a new update/revision of a procedure is ongoing, it is stored as “DRAFT”. So anyone having an update can put it in. Or they can suggest an update in WEReport.
10.01.2025: OK. Closed by DNO

According to WE-M-QHSE-MA-01 How WE Manage Well Expertise chapter 1.1, WE Management System is designed to be ISO 14001:2015 compliant. In the same document, it is stated in Table 7-1 and chapter 7.2.2. that company context, interested parties and environmental aspects shall be revised annually. Company context and stakeholder analysis are documented in WE-MQHSE-MA-01 and last updated in June 2021. Company context, interested parties and environmental aspects are all part of the agenda in the yearly Management Review, and the presentation from the meeting is also Minutes of Meeting (MoM) where actions are noted and members from the WE Management Team made responsible. The actions are checked in the next Management Review.

In the Management Review presentation/MoM, the conclusion of the review is not properly documented. Actions will be recorded only if updates to WE-M-QHSE-MA-01 How WE Manage Well Expertise are needed. The Management Review is neither recorded in WE Report.

23.12.24: Feedback to DNO – WE plan for the Management Review in Q1/March 2025. The Management reviews is documented in ppt presentations, and all actions agreed on have been listed there and followed up in the following Management Meetings. But we admit that the actions could have been followed up in a better way, i.e. in WEReport.
10.01.2025: OK. Closed by DNO
20.03.25: Actions from the Management Review added in WEReport

IMP-1: Records from chemical suppliers, rig etc. are stored in internal WE folders (SharePoint), and the full history of WE wells are available. However, as no retention time for records are described, there is a risk that records could be deleted unintentionally.

WE Environmental Reporting System (including records) is not made available to DNO, thus DNO is dependent that WE do the necessary QA of data. This could be improved by extracting a full report from CMS Portal and store on project SharePoint as part of End of Well reporting.
It is also recommended to agree and describe retention time for records of environmental data in project documentation.

23.12.24: Feedback to DNO – We are somewhat uncertain on the requirements on this issue regarding retention time. The Accounting Act says that primary documentation must be kept for 5 years. WE state in “How WE Manage Well Expertise” that we work according to prevailing regulations. The Accounting Act is listed as one of them.
To date, we have not deleted any data since the start of WE. The CMS Portal does only keep record of applied amounts of chemicals and operational accounting, and all information is provided in the annual report to NEA, so we are a little unsure of what DNO actually needs. Do you want access to all waste reports and section reports from drilling fluid and cement, etc.? If so, this can be provided for Falstaff and Kjøttkake (and coming wells) .
10.01.2025: Yes, DNO would like to have access to the detailed environmental records on waste, chemicals, fuel etc for Norma, Falstaff and upcoming wells. We suggest this is done for Falstaff as part of EoW reporting, and a separate folder with environmental records is uploaded to the project SharePoint site. If there are other suggestions on how the sharing of records can be done more effectively, we are happy to discuss this. Reference is also made to the Management Regulations §42 on retention of information, which states that the operator shall keep environmental data “as long as necessary”. Thus, it is important for DNO to have control of this data.
27.02.2025: Operational environmental documentation for Norma and Falstaff uploaded to DNO SP

IMP-2: A thorough process for identifying project Environmental Aspects and taking the outcome further into risk management and/or BAT assessments has newly been implemented in drilling projects. This has been successful, and DNO/WE has agreed that this is to be standard also for upcoming projects.

It is therefore recommended to include a description of the processes in future project HSE plans.

23.12.24: Feedback to DNO – Mapping environmental aspects will be secured in coming DNO projects
10.01.2025: OK. Closed by DNO

Procedure for How WE Manage Suppliers chapter 5.1 uses the term «Environmental Exposure».

It is recommended to clarify if this is related to external environment or working environment/occupational health.

23.12.24: Feedback to DNO – We will secure that a clarification on Environmental Exposure in How WE Manage Suppliers
10.01.2025: OK. Closed by DNO
24.02.2025: Fixed in Draft version no. 05 of the procedure.

A-1: Check access to WE Report for DNO (ARV, LL etc)

DNO/WE action

23.12.24: Feedback to DNO – As mentioned by Morten in the Audit, DNO should already have access to these modules in WEReport. DNO (Arild, Stein Arild?) need to check. If not, this can be provided.
10.01.2025: DNO has access to WEReport, but currently none of the environmental personnel has access. Could you please provide access for Grete and Valborg?
03.02.2025: Access granted

A-2: Meeting DNO/WE on reporting/ESG: What is DNO need, and what can WE
deliver? Include discussion on access to WE CMS.

DNO Action

23.12.24: Feedback to DNO – It is our understanding that DNO will not continue the work with Stepvise. In this process I guess DNO has done some evaluations on what they need. We are happy to have a meeting to discuss the potential for using WEReport/Corporate Footprinting.
10.01.2024: DNO is in the process of acquiring an environmental accounting system, and thus the need for a meeting with WE regarding access to the WE CMS will have to be evaluated according to the conclusion of this process.
24.02.2025: We have been told that DNO most probably will go for NEMS. We have not been invited to present our system…

A-3: Check how comment from NEA on yearly report 2023 for exploration drilling has been followed-up

23.12.24: Feedback to DNO – We have set a deadline for 15th January 2025.
24.02.25: “How WE Manage QHSE in Well Projects” updated to secure that we look into diesel usage an emissions as part of calculations in AfD by looking at historical data (special attention to type of operation and anchoring vs DP), and describing any deviations from the permit (increased emissions or decreased emissions) in the annual report to NEA. Information accepted by DNO – Action closed

A-4: It seems to be some double-reporting in WE Report/PIMS/Share Point – eg.
on ARV, Incidents and MOC. Go through the reporting routines together with
WE to see if there are unnecessary double-reporting that could be simplified.

DNO Action

23.12.24: It seems like the ARV module is not used by DNO, as WE has to document status on ARV findings in projects in a separate excel sheet in each project. Access should have been granted when access to the LL module was granted. Ref. A-1.
10.01.2025: DNO has discussed this internally, and concluded there is a need for the Excel sheet on SharePoint in order for DNO to ensure that ARV findings are closed out. It is also serving an archive purpose to ensure necessary ARV documentation is also stored in DNO PIMS.