Culture and Control : Regulation of Risk in the Norwegian Petroleum Industry
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AbstractThis thesis addresses the regulatory regime for health, safety and the (working) environment (HSE) in the Norwegian offshore petroleum industry. The thesis outlines the broader development and composition of this regime, but focuses particularly on the introduction of the concept of culture as part of the regulatory vocabulary and strategy. From 2002, the regulations have contained a provision requiring that the industry develop a good and ‘sound’ HSE culture. The thesis explores the causes and consequences of this regulatory innovation, and investigates how HSE culture has evolved as a conceptual device for framing and reframing socially embedded understandings of risk and its management within the regulatory and industrial context.
The thesis starts and ends with the assumption that regulatory regimes are highly complex and composite phenomena, both in themselves and in terms of the academic contexts available for understanding them. This complexity is taken into account through a relatively detailed review of some salient regime properties. It is based on qualitative case study methodology, including documentary studies, fieldwork, and interviews conducted at the Petroleum Safety Authority Norway. The perspective follows the anthropological credo of ‘taking the native’s point of view’, in trying to unveil how HSE culture entered into the pre-existing worldviews of a highly diversified but predominantly technocratic regulatory domain.
The regulatory practices and strategies reveal comprehensive, frequent, and multifaceted patterns of interaction between the authorities and the industry. The enforcement strategies are largely accommodative with a considerable degree of complicity between regulator and regulated. This is reflected in industrial responses to regulations and regulatory practices, but must be interpreted against the high level of interaction, the resources and economic and administrative capacities of the actors, and the high stakes implicated for corporations the in the face of possibly compromising their attractiveness as licence holders (or contractors). The employment of systems oriented and organizational approaches to the analysis and management of risk is clearly present also in the post hoc attributions of causes and responsibilities after accidents or serious near misses, and corporate rather than individual sanctions clearly appear as the preferred reaction from the authorities, and also from the prosecuting authorities.
The study of risk regulation regimes has focused on the development of so-called ‘enforced self-regulation’ and the accompanying concern with various risk management approaches. The theories and practices of risk management have gradually incorporated social and organizational perspectives, including also the role of ‘culture’. The interest in corporate cultures in the management of risk may be interpreted as derived from and extending these regulatory philosophies. The follow up of the culture provision is analyzed against this broader background. Although the new provision was launched with the optimistic hope of having added a ‘new dimension’ to those focusing on technology and management systems, organizational discontinuities caused a loss of momentum in the follow up process, and the ‘culture-project’ did not appear as fully integrated within the agency. The concept of HSE culture also set off a number of questions about risk management and became entangled in both substantial and conceptual confusions and controversies, including also the issue about the ‘enforcement’ of the provision.
These confusions and controversies must also be understood against the industrial practices and malpractices of risk management. Some serious accidents and near misses are analyzed, and in particular how they are reconstructed in post-event investigations, with ‘HSE-culture’ appearing as a somewhat ambiguous and inconsistent part of the explanatory repertoires. Both serious accidents and the ‘cultural turn’ served as triggers for the launch of large safety programs within the industry. Some of these programs are analyzed and discussed, in particular in terms of their underlying the risk management ideas. Many of the programs addressed the ‘sharp end’ of individual behaviour on the offshore facilities, arousing much debate and controversy, also among academic communities.
These partly disparate traces of cultural experiments and the broader regulatory and industrial context in which they traversed are analyzed against how the involved agency officials and managers reconstructed and interpreted them. The analysis tries to account for why ‘HSE culture’ gradually evaporated as a regulatory strategy, and outlines the emergent understanding of the comprehensiveness of culture as a concept as such.
Against this background, the position of culture as an academic concept (notably within anthropology and organisational studies) is analyzed and deconstructed. An attempt is made to reconstruct a multidimensional model of culture that both reflects the great diversity of usages, but also maps the cultural terrain in a distinct manner. It is also argued, however, that conceptualizations of culture, belonging as it does to the ‘commons’ within the conceptual landscape of social science, would effectively resist ‘colonializing’ attempts linked to specific theoretical approaches. Against this background, the regulatory encounters with ‘culture’ appeared as fairly reasonable, enlightened, and even ‘rational’. The final analysis draws together these discourses of regulation, risk management, and culture and discusses the conditions for how regulatory world views emerge within the regulatory domain and for how they can be understood. The thesis argues against some conventional approaches to the understanding of risk regimes and political bureaucracies more generally, in an attempt to revitalize the idea of such bureaucracies as fairly rational systems, institutionally framed and indigenously conceived for the purpose of pursuing the public interest.