TMC’s wholly-owned subsidiary, NORI, welcomes the release of the ISA Compliance Assurance and Regulatory Management Unit (CARMU) Inspection report. We appreciate the ISA’s robust auditing and inspection process, specifically the continuous engagement we had with the regulator before, during and after our recent integrated collector system trials in the NORI-D contract area.
As part of CARMU’s comprehensive audit and inspection which took place between 23 June 2022 and 20 January 2023, CARMU attended a pre-planning meeting of experts and was given full access to both the Hidden Gem and the environmental monitoring vessel, conducting three thorough inspections of the vessels, equipment, policies and personnel. NORI is the first Contractor to be subject to the new ISA inspection and auditing process and we welcome the additional compliance and regulatory oversight as the industry moves towards exploitation.
Part of the audit report covers the minor, temporary overflow of seawater, sediment and nodules from the cyclone separator aboard the Hidden Gem, which CARMU added to the scope of the original inspection process. NORI agrees with the ISA’s preliminary assessment that was based on the data provided by NORI, that the overflow event did not cause — nor have the potential to cause — serious harm to the marine environment. NORI acknowledges CARMU’s observation and suggestion for improvement with regards to its risk management process and welcomes the ISA’s engagement of a third party to assess the event. We are confident the third party will confirm NORI’s and the ISA’s preliminary assessments and look forward to the final assessment when it is complete.
We appreciate CARMU’s two observations in the inspection report that were provided as areas of future improvement:
- NORI conducted a comprehensive pre-test risk assessment and did not consider seawater overflow from the deck as a major risk before the integrated collector test and still does not consider it a major risk. In retrospect, NORI could have included an exceedance of buffer capacity in the cyclone separator in NORI’s project risk register.
- We take on board CARMU’s suggestion to develop a gap document to visualize how the targets and objectives of our test have been achieved. It was always and remains NORI’s intent to report on test results against our commitments and we look forward to sharing this documentation with the ISA. Additionally, we look forward to sharing various lessons learned so that stakeholders can learn from our experience.
We thank the ISA for their thorough and detailed auditing and inspection process and look forward to working with the regulator to improve in these areas and ensure that our new industry operates to the highest standards. NORI would also like to thank our Sponsoring State, Nauru, for its continued support and for providing an observer for the duration of the integrated collection system test.