WE Report

Audits



COSL Drilling Europe (CDE)

No person selected

Report No.

6062
COSL Onshore Rig Intake Verification Report

Type of audit

Rig Intake
COSL Drilling Europe (CDE)

Auditee/Customer

COSL Drilling Europe (CDE)
Wellesly

Date

2024/01/14

694 days ago

Findings

38
Number of findings

Status

Closed
Rig Intake


COSL Onshore Rig Intake Verification Report
Summary

As a part of the rig intake and preparations for the Toppand East Exploration well and Gnomoria Appraisal well, Wellesley petroleum (Wellesley) performed an onshore Verification of COSL Drilling Europe AS (CDE) on both HSE- and technical aspects.
The verification was held at CDE’s premises at Vestre Svanholmen 4, in Sandnes, 13-14th of December.

The review was held in a good atmosphere, the CDE participants were very open and willing to explain and share information.

The verification team identified two (2) non-conformances, zero (0) observations, three (3) improvement suggestions and 33 actions. None of the findings are considered critical for operation.

The verification team’s impression is that CDE is a rig company that has a well-functioning business management system. CDE is ISO 9001, 14001, ISO 45001 and 50014.
A separate competence review meeting will be scheduled closer to spud.

Findings

  • Non-Conformity

    Closed


    Closed


    Deadline was:

    NC-1. Lack of documentation regarding chemicals used on the rig. Measurement program is lacking information regarding water treatment chemicals, hydraulic fluids, and lubricants (Vaptreat, Jet-Lube Kopr-Kote, Jet-Lube Alco 73, Houghto-Safe NL1).

    Ensure that all required documentation as required in Aktivitetsforskriften §70 is in place.

    Synergi 313030 closed 08.02.24. Updated measurement program received.

  • Non-Conformity

    Closed


    Closed


    Deadline was:

    NC-2. A HAZID for pipe handling was performed in 2019.

    The Offshore Norge recommended guidelines for remote pipe handling operations, section 5. Handling procedures shall be established for all planned manual pipe handling operations marked ”M” in the matrix. These procedures must be based on risk analysis (HAZID). HAZID shall be repeated at least every 3 years and in relation to changes that will affect the pipe handling.

    Schedule a HAZID for pipe handling as soon as possible and latest before operation begins for Wellesley.

    Received: ÅKP -26.04.2024. Attached

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-1. Some of the references to NORSOK was not updated in Synergi. This should be corrected.

    Update references to NORSOK in Synergi.

    ÅKP. Info from CDE. Synergi 313035, Action cancelled as this will be done on next SPS

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-2. The RIT recommends preparing a L3 procedure for handling of drones that lands on the rig.

    Preparing a L3 procedure for handling of drones that lands on the rig.

    ÅKP. Info rom CDE. Synergi 313036, Action cancelled. Adressed in bridging document. Will not be made separat procedure for drone handling.
    ÅKP. Its only the reporting that is addressed in the bridging document. Not what the rig will do if a drone lands on the rig.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-3. Working environment requirements from 3rd party equipment should be included in CDE checklist.

    Include working environment requirements from 3rd party equipment in the CDE checklist.

    ÅKP. Info from CDE. Synergi 313037, New revised checklist DM#48514 sent document owner for approval. Reflecting Norsok Z15 and WEAC.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 1. CDE to send CDE presentation including updated org. chart.

    ÅKP. Received

  • Actions

    Closed


    Closed


    Deadline was:

    Action 2. Forward list of internal deviations.

    26.04.2024: KNH. Received. reg. A2 attached.

  • Actions

    Closed


    Closed


    Deadline was:

    AoC Exemptions

    Action 3. CDE to send information regarding compensating measures.

    ÅKP. Received

  • Actions

    Closed


    Closed


    Deadline was:

    Action 4. CDE to send a copy of a daily HSE rapport.

    10.01.2024 ÅKP. Received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 5. CDE to forward the 2024 QHSE Program

    07.03.2024: ÅKP- HSEQ Program Received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 6. CDE to forward Promoters 2024 QHSE Plan

    07.03.2024: ÅKP- HSEQ Plan is received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 7. Forward agenda for Bi-weekly HSE meeting and suggest time for meeting.

    21.03.2024 ÅKP. Agenda. Time is Wednesday at 10:30

  • Actions

    Closed


    Closed


    Deadline was:

    Action 8. CDE to forward plan for Operational and Organisational barrier monitoring.

    ÅKP. Info from CDE. There are ongoing project regarding barrier monitoring (ABS-project). I do not have status to send over regarding this. The project is comprehensive, and lead by technical dep.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 9. Inform RIT how the results from the QRA have been communicated to the Rig Personnel.

    ÅKP. Info from CDE. Communication through an activity in synergi 319078, ensuring implementaton. (status 3 of 4 actions closed).

  • Actions

    Closed


    Closed


    Deadline was:

    Action 10. CDE to forward a copy of the letter to Havtil regarding the last audit.

    17.01.2024:ÅKP – Received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 11. CDE to forward a Synergi report with open findings from audits.

    ÅKP. CDE will not send this.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 12. CDE to forward External Audit plan for 2024.

    ÅKP. Received 14.05.24

  • Actions

    Closed


    Closed


    Deadline was:

    Action 13. CDE to forward COPR internal audit plan for 2024.

    14.03.2024: ÅKP – Received, ref. synergi 309649

  • Actions

    Closed


    Closed


    Deadline was:

    Action 14. Plan for a joint audit of Subsea7 in January/February 2024.

    ÅKP: Decided on a Review of IOGP competence. Included in ARV Plan – Responsible Morten Laget

  • Actions

    Closed


    Closed


    Deadline was:

    Action 15. CDE to send a copy of the competence requirements

    ÅKP: Received competence matrix 14.05. IOGP level 1 and 2 not listed
    ÅKP: 22.08.2024. IOGP requirements and status still not received. Operation is completed.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 16. Schedule a competence review meeting close to spud.

    19.03.2024. ÅKP – A competence review meeting was held 19.03.2024

  • Actions

    Closed


    Closed


    Deadline was:

    Action 17. Risk Exposed Group matrix to be forwarded.

    ÅKP 14.05.24 RiskExposedGroup matrixes are stored in Equinor Sharepoint under QHSE/ Risikoutsattegrupper (RUG) 2019 (files til large for mail).
    ÅKP. Matrix down loaded to rig intake folder working environment.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 18. WEACs to be forwarded.

    14.05 Motatt

  • Actions

    Closed


    Closed


    Deadline was:

    Action 19. CDE to forward procedure for temporary equipment.

    ÅKP- 21.03.2024 -Received. However the procedure was last updated in 2017 and should be revised.
    ÅKP-17.07.2024 – Received. Procedure was updated 25.06.2024

  • Actions

    Closed


    Closed


    Deadline was:

    Action 20. A new safety representative should be elected from the service companies

    25.04.2024:ÅKP: Agreed to use existing VO’s. That is Halliburton Cementing. Wellesley is changing from Halliburton to SLB but Halliburton will also be on the rig.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 21. Forward list of safety delegates and status on courses.

    19.04.2024: ÅKP- Received list from CDE, but not confirmed by the Head Safety Delegate. Also, missing status on VO training (40 hours course). Will postpone the deadline. Overview of competence received: Sten Hugo Åkerøy, Alf terje Anthun, Jon Eirik Lofthus, ferderick Frafjord, Jonas Salvesen, Simon Knutshaug does not have the VO course.

    22.08.2024 ÅKP – All are booked on courses. operation is completed

  • Actions

    Closed


    Closed


    Deadline was:

    Action 22. How are recommendations from the EPA communicated to the rig personnel?

    ÅKP 14.05.24. Activity in synergi 319078 for implementaton. 3 of 4 actions closed.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 23. WE to send risk assessment of 3rd party chemicals, and all SDS to CDE QHSE Engineer.

    ÅKP. Risk Assessments and SDS sent to CDE QHSE Eng.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 24. Rename “COSLPromoter kjølemedium Log” or “DM#6003507 Kuldemedium log COSLPromoter” to match each other and avoid confusion.

    DM#6009657 renamed to “Kjølemedium/ Kuldemedium logg COSLPromoter”

  • Actions

    Closed


    Closed


    Deadline was:

    Action 25. Remove R-404A from rig and log if not in use.

    R404 is removed, ref DM6009657.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 26. Please forward the Synergi report for Contained rig and sustainability inspection carried out in May 2022.

    ÅKP: Report received.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 27. CDE to provide info on how to get NOV to improve performance with regards to NPT.

    ÅKP. Performance issues are adressed through Synergi. The specific NOV problems are in amongst other adressed in through synergi 278300, 251096:
    COSLPromoter have unfortunately had some issues with the subsea Equipment (BOP/POD). I have tried du describe what we have done after these NPT incidents to prevent this to happen again

  • Actions

    Closed


    Closed


    Deadline was:

    Action 28. Wellesley to set up a separate meeting with Enhanced drilling regarding RMR and to include CDE.

    Seperate project was set up with a dedicated COSL project manager to follow installation and preparedness of mud return line and moonpool work for RMR, as well as prepering platform.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 29 . CDE to provide latest result related to ESD test.

    ÅKP 14.05.2024. received

  • Actions

    Closed


    Closed


    Deadline was:

    Action 30. CDE to provide specification for the crane hook.

    Received 15.12.2024:ÅKP- Specifications is Norsafe K4 hook, see specifications attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 31. CDE to provide Wellesley with new helicopter certificate once obtained.

    Received 26.04.2024. Attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 32. CDE to provide pit overview.

    ÅKP. Received 14.05.24 Received, see attached.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 33. Wellesley to look into the best comms solution for both Toppand East and Gnomoria.

    Meeting with COSL and Equnior held. Not possible with Radiolink on location due to incompatability with equipment on Troll. No 4G in the area either.

    Best solution was to purchase two Starlink antennas and use VSat as back up. Starlink upgraded to 15 tb per month for both antennas and operating at full speed.



Additional Documentation


TOP-WLSLY-D-RA-0900-Onshore-Rig-intake-verification-report_rev.-01Signed.pdf, 309649-Annual-activity-plan-COSLPromoter-2024-Synergi-Life.pdf, EDOCS-399582-v6A-COSL_svar_pa_palegg_og_rapport_etter_tilsyn_ved_Styring_av_arbeidsmiljo_og_drif.pdf, 1036350907CDE-QHSE-Program-2024-1.pdf, EDOCS-244292-v63M-QHSE_Plan_COSLPromoter-1.xlsx, PSA-Audit-Synergi-case-303338.pdf, 240110-COSL-Daily-Risk-Picture-1.pdf, COSL-Daily-HSE-Report-09.01.2024-1.pdf, Bi-weekly-HSE-Meeting.png, EDOCS-5043246-v1-C__Rescue_Boat_Norsafe-K4-hook.pdf, L3-TEC-48514-Temporary-equipment.pdf, A2-COSLPromoter-NC-26.04.2024.pdf, Helicopter-deck-landing-certificate.pdf, EDOCS-280644-v6-HAZID_Red_zone_on_drill_floor_COSLPromoter.pdf, COSLPromoter-NC-26.04.2024.pdf, 319078-Update-of-COSLPromoter-QRA-and-EPA-Synergi-Life.pdf




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COSL Drilling Europe (CDE)

No person selected

Report No.

6062
COSL Onshore Rig Intake Verification Report

Type of audit

Rig Intake
COSL Drilling Europe (CDE)

Auditee/Customer

COSL Drilling Europe (CDE)
Wellesly

Date

2024/01/14

694 days ago

Findings

38
Number of findings

Status

Closed
Rig Intake


COSL Onshore Rig Intake Verification Report
Summary

As a part of the rig intake and preparations for the Toppand East Exploration well and Gnomoria Appraisal well, Wellesley petroleum (Wellesley) performed an onshore Verification of COSL Drilling Europe AS (CDE) on both HSE- and technical aspects.
The verification was held at CDE’s premises at Vestre Svanholmen 4, in Sandnes, 13-14th of December.

The review was held in a good atmosphere, the CDE participants were very open and willing to explain and share information.

The verification team identified two (2) non-conformances, zero (0) observations, three (3) improvement suggestions and 33 actions. None of the findings are considered critical for operation.

The verification team’s impression is that CDE is a rig company that has a well-functioning business management system. CDE is ISO 9001, 14001, ISO 45001 and 50014.
A separate competence review meeting will be scheduled closer to spud.

Findings

  • Non-Conformity

    Closed


    Closed


    Deadline was:

    NC-1. Lack of documentation regarding chemicals used on the rig. Measurement program is lacking information regarding water treatment chemicals, hydraulic fluids, and lubricants (Vaptreat, Jet-Lube Kopr-Kote, Jet-Lube Alco 73, Houghto-Safe NL1).

    Ensure that all required documentation as required in Aktivitetsforskriften §70 is in place.

    Synergi 313030 closed 08.02.24. Updated measurement program received.

  • Non-Conformity

    Closed


    Closed


    Deadline was:

    NC-2. A HAZID for pipe handling was performed in 2019.

    The Offshore Norge recommended guidelines for remote pipe handling operations, section 5. Handling procedures shall be established for all planned manual pipe handling operations marked ”M” in the matrix. These procedures must be based on risk analysis (HAZID). HAZID shall be repeated at least every 3 years and in relation to changes that will affect the pipe handling.

    Schedule a HAZID for pipe handling as soon as possible and latest before operation begins for Wellesley.

    Received: ÅKP -26.04.2024. Attached

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-1. Some of the references to NORSOK was not updated in Synergi. This should be corrected.

    Update references to NORSOK in Synergi.

    ÅKP. Info from CDE. Synergi 313035, Action cancelled as this will be done on next SPS

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-2. The RIT recommends preparing a L3 procedure for handling of drones that lands on the rig.

    Preparing a L3 procedure for handling of drones that lands on the rig.

    ÅKP. Info rom CDE. Synergi 313036, Action cancelled. Adressed in bridging document. Will not be made separat procedure for drone handling.
    ÅKP. Its only the reporting that is addressed in the bridging document. Not what the rig will do if a drone lands on the rig.

  • Improvement

    Closed


    Closed


    Deadline was:

    IMP-3. Working environment requirements from 3rd party equipment should be included in CDE checklist.

    Include working environment requirements from 3rd party equipment in the CDE checklist.

    ÅKP. Info from CDE. Synergi 313037, New revised checklist DM#48514 sent document owner for approval. Reflecting Norsok Z15 and WEAC.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 1. CDE to send CDE presentation including updated org. chart.

    ÅKP. Received

  • Actions

    Closed


    Closed


    Deadline was:

    Action 2. Forward list of internal deviations.

    26.04.2024: KNH. Received. reg. A2 attached.

  • Actions

    Closed


    Closed


    Deadline was:

    AoC Exemptions

    Action 3. CDE to send information regarding compensating measures.

    ÅKP. Received

  • Actions

    Closed


    Closed


    Deadline was:

    Action 4. CDE to send a copy of a daily HSE rapport.

    10.01.2024 ÅKP. Received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 5. CDE to forward the 2024 QHSE Program

    07.03.2024: ÅKP- HSEQ Program Received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 6. CDE to forward Promoters 2024 QHSE Plan

    07.03.2024: ÅKP- HSEQ Plan is received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 7. Forward agenda for Bi-weekly HSE meeting and suggest time for meeting.

    21.03.2024 ÅKP. Agenda. Time is Wednesday at 10:30

  • Actions

    Closed


    Closed


    Deadline was:

    Action 8. CDE to forward plan for Operational and Organisational barrier monitoring.

    ÅKP. Info from CDE. There are ongoing project regarding barrier monitoring (ABS-project). I do not have status to send over regarding this. The project is comprehensive, and lead by technical dep.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 9. Inform RIT how the results from the QRA have been communicated to the Rig Personnel.

    ÅKP. Info from CDE. Communication through an activity in synergi 319078, ensuring implementaton. (status 3 of 4 actions closed).

  • Actions

    Closed


    Closed


    Deadline was:

    Action 10. CDE to forward a copy of the letter to Havtil regarding the last audit.

    17.01.2024:ÅKP – Received and attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 11. CDE to forward a Synergi report with open findings from audits.

    ÅKP. CDE will not send this.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 12. CDE to forward External Audit plan for 2024.

    ÅKP. Received 14.05.24

  • Actions

    Closed


    Closed


    Deadline was:

    Action 13. CDE to forward COPR internal audit plan for 2024.

    14.03.2024: ÅKP – Received, ref. synergi 309649

  • Actions

    Closed


    Closed


    Deadline was:

    Action 14. Plan for a joint audit of Subsea7 in January/February 2024.

    ÅKP: Decided on a Review of IOGP competence. Included in ARV Plan – Responsible Morten Laget

  • Actions

    Closed


    Closed


    Deadline was:

    Action 15. CDE to send a copy of the competence requirements

    ÅKP: Received competence matrix 14.05. IOGP level 1 and 2 not listed
    ÅKP: 22.08.2024. IOGP requirements and status still not received. Operation is completed.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 16. Schedule a competence review meeting close to spud.

    19.03.2024. ÅKP – A competence review meeting was held 19.03.2024

  • Actions

    Closed


    Closed


    Deadline was:

    Action 17. Risk Exposed Group matrix to be forwarded.

    ÅKP 14.05.24 RiskExposedGroup matrixes are stored in Equinor Sharepoint under QHSE/ Risikoutsattegrupper (RUG) 2019 (files til large for mail).
    ÅKP. Matrix down loaded to rig intake folder working environment.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 18. WEACs to be forwarded.

    14.05 Motatt

  • Actions

    Closed


    Closed


    Deadline was:

    Action 19. CDE to forward procedure for temporary equipment.

    ÅKP- 21.03.2024 -Received. However the procedure was last updated in 2017 and should be revised.
    ÅKP-17.07.2024 – Received. Procedure was updated 25.06.2024

  • Actions

    Closed


    Closed


    Deadline was:

    Action 20. A new safety representative should be elected from the service companies

    25.04.2024:ÅKP: Agreed to use existing VO’s. That is Halliburton Cementing. Wellesley is changing from Halliburton to SLB but Halliburton will also be on the rig.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 21. Forward list of safety delegates and status on courses.

    19.04.2024: ÅKP- Received list from CDE, but not confirmed by the Head Safety Delegate. Also, missing status on VO training (40 hours course). Will postpone the deadline. Overview of competence received: Sten Hugo Åkerøy, Alf terje Anthun, Jon Eirik Lofthus, ferderick Frafjord, Jonas Salvesen, Simon Knutshaug does not have the VO course.

    22.08.2024 ÅKP – All are booked on courses. operation is completed

  • Actions

    Closed


    Closed


    Deadline was:

    Action 22. How are recommendations from the EPA communicated to the rig personnel?

    ÅKP 14.05.24. Activity in synergi 319078 for implementaton. 3 of 4 actions closed.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 23. WE to send risk assessment of 3rd party chemicals, and all SDS to CDE QHSE Engineer.

    ÅKP. Risk Assessments and SDS sent to CDE QHSE Eng.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 24. Rename “COSLPromoter kjølemedium Log” or “DM#6003507 Kuldemedium log COSLPromoter” to match each other and avoid confusion.

    DM#6009657 renamed to “Kjølemedium/ Kuldemedium logg COSLPromoter”

  • Actions

    Closed


    Closed


    Deadline was:

    Action 25. Remove R-404A from rig and log if not in use.

    R404 is removed, ref DM6009657.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 26. Please forward the Synergi report for Contained rig and sustainability inspection carried out in May 2022.

    ÅKP: Report received.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 27. CDE to provide info on how to get NOV to improve performance with regards to NPT.

    ÅKP. Performance issues are adressed through Synergi. The specific NOV problems are in amongst other adressed in through synergi 278300, 251096:
    COSLPromoter have unfortunately had some issues with the subsea Equipment (BOP/POD). I have tried du describe what we have done after these NPT incidents to prevent this to happen again

  • Actions

    Closed


    Closed


    Deadline was:

    Action 28. Wellesley to set up a separate meeting with Enhanced drilling regarding RMR and to include CDE.

    Seperate project was set up with a dedicated COSL project manager to follow installation and preparedness of mud return line and moonpool work for RMR, as well as prepering platform.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 29 . CDE to provide latest result related to ESD test.

    ÅKP 14.05.2024. received

  • Actions

    Closed


    Closed


    Deadline was:

    Action 30. CDE to provide specification for the crane hook.

    Received 15.12.2024:ÅKP- Specifications is Norsafe K4 hook, see specifications attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 31. CDE to provide Wellesley with new helicopter certificate once obtained.

    Received 26.04.2024. Attached

  • Actions

    Closed


    Closed


    Deadline was:

    Action 32. CDE to provide pit overview.

    ÅKP. Received 14.05.24 Received, see attached.

  • Actions

    Closed


    Closed


    Deadline was:

    Action 33. Wellesley to look into the best comms solution for both Toppand East and Gnomoria.

    Meeting with COSL and Equnior held. Not possible with Radiolink on location due to incompatability with equipment on Troll. No 4G in the area either.

    Best solution was to purchase two Starlink antennas and use VSat as back up. Starlink upgraded to 15 tb per month for both antennas and operating at full speed.



Additional Documentation


TOP-WLSLY-D-RA-0900-Onshore-Rig-intake-verification-report_rev.-01Signed.pdf, 309649-Annual-activity-plan-COSLPromoter-2024-Synergi-Life.pdf, EDOCS-399582-v6A-COSL_svar_pa_palegg_og_rapport_etter_tilsyn_ved_Styring_av_arbeidsmiljo_og_drif.pdf, 1036350907CDE-QHSE-Program-2024-1.pdf, EDOCS-244292-v63M-QHSE_Plan_COSLPromoter-1.xlsx, PSA-Audit-Synergi-case-303338.pdf, 240110-COSL-Daily-Risk-Picture-1.pdf, COSL-Daily-HSE-Report-09.01.2024-1.pdf, Bi-weekly-HSE-Meeting.png, EDOCS-5043246-v1-C__Rescue_Boat_Norsafe-K4-hook.pdf, L3-TEC-48514-Temporary-equipment.pdf, A2-COSLPromoter-NC-26.04.2024.pdf, Helicopter-deck-landing-certificate.pdf, EDOCS-280644-v6-HAZID_Red_zone_on_drill_floor_COSLPromoter.pdf, COSLPromoter-NC-26.04.2024.pdf, 319078-Update-of-COSLPromoter-QRA-and-EPA-Synergi-Life.pdf



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