MIU, Alm.del - 2011-12 - Endeligt svar på spørgsmål 362: Spm. om ministeren vil fremsende den eksterne undersøgelse af samtlige Mærsks platforme, som Mærsk stillede i udsigt efter kritik af redegørelsen om olieudslip i Nordsøen, til miljøministeren

EXECUTIVE SUMMARY FRA LR SCANDPOWER LTD - INDEPENDENT OILIN WATER REVIEW, MAY 2012Hermed fremsendes Executive summary fra det review, der er udf0rt i maj2012 af LR Scandpower Ltd. (tidligere Lloyd's Register EMEA) pa alle vore off�shore installationer samt onshore.Rapporten bekrasfter i lighed med tidligere rapporter, at Maersk Oil har etable-ret procedurer, som sikrer overholdelse af de vilkar, der findes i vores udled-ningstilladelser for produktlonsenhederne.Rapporten bekraafter ligeledes, at Maersk Oil fortsaetter med at udvikle og for-bedre processerne og procedurerne for maling af OiW.I rapporten er der endvidere anbefalinger til yderligere forbedringer af proces-ser og procedurer. Disse anbefalinger vii blive gennemgaet og vurderet og Irelevant omfang implementeret, sammen med anbefalingerne fra Force's veri-

INTRODUCTIONFrom 12 to 19 May 2012, LR Scandpower conducted an independent review of theMaersk Oil Denmark’s Oil in Water (“OiW”) sampling and analysis processes andprocedures. This was a follow-up to the review conducted in October 2011 (reportdated 27 January 2012). As with previous assessments, this review was conductedonshore at the Esbjerg offices of Maersk Oil Denmark and offshore on all Maersk OilDenmark (DUC) platforms. The review identified a number of areas for potentialimprovement in Maersk Oil Denmark’s management of the OiW processes, but did notidentify any areas that were in breach of the OiW permits.

Scope and CriteriaThe scope of this OiW review included assessment of: a) outstanding items raised atthe previous review in November 2011; b) compliance with permit conditions; and c)identification of further opportunities for improvement. A further description of criteriaused to assess compliance with permit conditions and progress against outstandingactions is contained in the main report.The DECC Guidance Notes for Sampling and Analysis of Produced Water and OtherHydrocarbon Discharges provided the main source of assessment criteria, as they areconsidered to be best practice. These guidelines, although not mandatory, are referredto in the OiW permits and have been used as the basis in formulating OiW procedures.

COMMENDATIONSMaersk Oil Denmark has continued to build on the progress achieved in 2011with further refinement and implementation of the OiW managementprocesses.There is no evidence of non-compliance with permit conditions.Although it is not a mandated requirement, the DECC guidance notes havebeen taken into account in the establishment and implementation of the OiWprocedures. It is also recognised that these guidelines are referred to in theirOiW permits.OiW workshops have been established with the intent of knowledge andexperience sharing within the lab tech community, nurturing a culture ofconsultation and performance improvement.New pre-printed logbooks are used on all platforms to enhance datatraceability and transparency.Improvements have been made to the platform specific OiW procedures toachieve greater clarity.Consistent reporting lines have been established for the Lab Assistant andTechnicians.Overwhelmingly, OiW samples have been collected during the allotted timesacross all platforms.Independent reviews have been conducted by Force Technology and includedOiW data verification.With regard to limits of detection, Maersk Oil Denmark has introduced the useof two calibration curves for use on samples at the lower and higher ends ofthe concentration scale. Samples are now also analysed against verifiedstandards provided by the Technical Institute.Certified weights are used for calibration of the laboratory balances.A number of internal QC controls have been established in order to managethe quality of analysis.

RECOMMENDATIONSThe OiW Review produced 15 recommendations for continued improvement in MaerskOil Denmark’s management of OiW processes and permit compliance. There are eightnew recommendations amongst the 15 that have been indentified, meaning that sevenrecommendations (out of 23) from the previous reviews remain open.Note: expandedversions of these recommendations are contained in the full report and platformspecific documents, along with the associated findings.OiW Procedures1.Update the platform specific procedures to include the continuous OiWmonitoring arrangements.Update the OPM Part 2B procedure to include newly implemented calibrationactivities associated with the laboratory balances(new recommendation).In order to comply with the DECC method, Maersk Oil Denmark shoulddemonstrate that laboratory temperatures are accurately and preciselymeasured within a +/- 3�C tolerance. Update associated proceduresaccordingly.

Integrity of Data4.To reduce the risk of potential data anomalies, logbooks should only be usedto capture raw data; data from the spreadsheets should not be transferred tothe logbooks. The practice of retrospectively amending the spreadsheetswith an updated correlation factor should be discontinued(newrecommendation).

Verification of Processes5.A programme to raise OiW awareness of those in supervisory (to theLaboratory Technicians) roles must be established. To enable Supervisorsto engage more actively and skillfully within OiW QA/QC and verificationprocesses, they must have a firm understanding of the OiW processes andthe Laboratory Technicians’ overall roles and responsibilities.The scope of Maersk Oil Denmark’s internal HSE audits should be expandedto include the key expectations of the OiW processes.For data verification activities, it is important to be able to follow theprogression of data transfer. This includes data recorded in logbooks,spreadsheets, databases and reports. Reinforce the requirement to provideexplanatory comments whenever samples are not collected during allottedtimes or when sample concentrations exceed KPIs.

Competency Assurance10.The competency assurance processes should reflect the DECC method,which requires“all personnel conducting the analytical methods to be trainedto a level of competency allowing personnel to perform the analysis correctly,manage routine verification, calibration, documentation and quality controltest requirements without supervision”.In order to achieve this Maersk OilDenmark should:i.Clarify the OiW competency criteria (i.e. ‘skim, read, learn’)outlined within the training matrix. This should include definingdemonstrable competency expectations at each level(newrecommendation).Introduce a programme of refresher training to ensurecompliance with DECC guidance, which states that operatorsmust“determine at what frequency periodic assessment orretraining of personnel is required in order to maintain levels ofcompetency” (new recommendation).Ensure that Supervisors (who are now responsible for theoversight and review of the implementation of the OiWprocedures) are adequately equipped with the appropriate ‘tools.’These include: a firm awareness of the key sample collection andanalysis tasks, an understanding of the key requirements of theOiW permit, OiW KPIs and related audit findings and a processfor testing the competency of the Laboratory Assistants.Conduct OTJT verification utilising a specialist who is deemed tobe an OiW Technical Authority, enabling Maersk Oil Denmark toachieve the most effective, consistent and value adding OTJTverification. This should include competency verification ofcontracted personnel.

Culture and Climate11.In order to further promote and nurture a culture of compliance andperformance improvement, Maersk Oil Denmark should communicate thecriticality of the OiW permit, including the key prerequisites and requirements(new recommendation).Some Laboratory Assistants and Technicians perceived a conflict of interestand felt they could not retain a required degree of independence if theyworked within a production team. In the opinion of LR Scandpower, this is aperception rather than a reality. Efforts need to continue to bring theLaboratory Technicians into the body of the production team, whilst ensuringthat they maintain a critical degree of independence relating to OiWprocesses(new recommendation).