The HSE argued that Apache North Sea's reduced staffing of the production technicians' rota on the Beryl Bravo platform, which included using trainees, apprentices and assistants to cover some shifts, had the potential to increase fatigue among staff and reduced also its ability to carry out critical work.
The improvement notice, which was issued on 19 July, said that Apache had agreed in November 2017 that, as part of a change in the rota pattern, there should be four production technicians each, on day and night shifts, for routine platform operations. This would include an allowance for two control room operators (CROs) per shift, but with an allocation of five per shift to cover sickness/absence/rota breaks as reflected in the current production technicians' rota.
However, a scheduled inspection of the Beryl Bravo platform found that both day and night shifts had only three production technicians, including one CRO, which the HSE said was "significantly lower" than the arrangements that Apache had identified as required to "safely operate the plant, conduct routine operations and allow personnel to have sufficient rest periods/breaks".
The HSE said that the use of trainees, apprentices and assistants to cover some shifts, who were "not deemed to be fully competent" according to the operator's own competency management system, also could not "be considered to provide adequate cover".
The scheduled inspection of the platform, which sits in the Beryl oil field, 290 km north north-east of Aberdeen, also found that the reduced rostering of production technicians was not an isolated incident and had been ongoing since the start of 2018.
An Apache spokesperson said the improvement notice, which related to a period of reducing manning arrangements, was the result of "unforeseen circumstances".
The spokesperson said: "Where this occurred, activities were proactively reduced to manage workload, thereby ensuring completion of safety-critical activities and the safe operation of the asset.
"Further enhancements are being implemented and Apache will continue to communicate our progress to the HSE until the matter has been resolved."
Apache North Sea, a subsidiary of the US-based Apache Corporation, has until 14 September to comply with the notice.