Certification and Standards for Large OSV s

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1 Certification and Standards for Large OSV s A Report from the Subcommittee on Certification and Standards for Large OSV s To The National Offshore Safety Advisory Committee April 18, 2008 Washington, D.C.

2 1.0 Background This report is prepared in response to the NOSAC Task Statement Certification and Standards for Large OSV s which has a task title of Identification of Coast Guard vessel certification category and standards for large OSV s greater than 6,000 GRT (ITC). This task was accepted at the November 2007 meeting of the National Offshore Safety Advisory Committee (NOSAC). Since the inception of the offshore oil exploration and production industry the offshore supply vessel (OSV) has been the workhorse of the industry. From its humble beginnings as a converted shrimp trawler servicing the needs of platforms in just a few feet of water, within site of land, the OSV has become a multi-service vessel providing critical infrastructure support to approximately 30% of domestic energy production. Today s high volume production facilities are located in waters thousands of feet deep, almost 200 miles from shore. Keeping pace with the move to deeper waters and farther reaches the equipment and supplies that the OSV must carry to support these operations have gotten larger, heavier and grown in volume. The navigation bridges of these vessels are now ergonomically designed, with dynamic positioning (dp) systems commonplace. The crew quarters are significantly improved with better sea keeping improving the ride for the crew and persons carried in addition to the crew. Largely because of the quality of the mariners working on these vessels, the offshore workplace is statistically one of the safest places to work in America. Industry safety statistics indicates that using an OSHA standard for comparison the reportable injury rate on offshore workboats is about one-tenth that of the U.S. workforce as a whole. The primary factor is that a culture of safety has taken over in the workboat sector. This include implementation of Job Safety Analysis, identifying safety concerns before a job is done, or stop work authority, giving every mariner the power to stop an operation if he or she believes that it is unsafe. Even though our industry faces risks everyday, companies manage that risk and, as a result, working on an offshore vessel is statistically safer than almost any shore side job. OSV s were brought under inspection by the Coast Guard in the late 1970 s. In order to create an inspection regime Congress had to define an OSV. That definition stated an Offshore Supply Vessel (OSV) was a vessel between 15 and 500 U.S. Register Gross Tons, which regularly carries goods, supplies or equipment in support of exploration, exploitation or production of offshore mineral or energy resources. To facilitate offshore energy exploration and production Congress also exempted OSV s from certain tankship laws and authorized OSV s to transfer fuel and hazardous cargoes to offshore production and exploration facilities. Those exemptions are not impacted by this task and Page 2 of 13

3 remain in effect. Congress also facilitated exploration and production by allowing OSV s on short voyages to utilize the two-watch system. Those laws are also not impacted by this task and remain in effect. Nearly simultaneous the ratification of the international tonnage convention by the U.S., the Gulf of Mexico began experiencing its first expansion into waters too deep for a traditional fixed platform. At the time the move to conduct drilling and production in waters up to a few thousand feet deep was revolutionary. The revolution affected not only the design of floating deepwater production facilities with the advent of tension leg platforms it also necessitated the design and construction of deepwater vessels to support these operations. To support the move into deeper waters in the early 1990 s Congress amended the laws defining an OSV and removed the upper tonnage limit on OSV s by provided the Coast Guard the authority to create a new regulatory tonnage limit for OSV s based upon the International Tonnage Convention (ITC). In close cooperation with industry and based upon a careful consideration of the technological limits of offshore drilling in the early 1990 s the Coast Guard created an upper tonnage limitation on OSV s of 6,000 Gross Tons (ITC). The pace of technological change in the drilling industry has sped up just like every other industry. It took 18 years from 1978 to 1996 for the 500 GRT limitation on OSV s to become restrictive. It only took 12 years from 1996 to 2008 for the 6,000 GT ITC limitation to become restrictive. There is no legislative prohibition against OSV s of unlimited tonnage, only a regulatory limitation. Removing the regulatory tonnage limitation from OSV s will not affect its legislated exemptions from certain tankship or other legislative provisions while in support of offshore energy exploration, exploitation or production. Current standards for OSV s up to 6,000 GT ITC are contained in 46 CFR Subchapter L. By and large these regulations provide a satisfactory level of safety for an OSV of any tonnage. The Coast Guard has asked that industry develop reasonable and safety conscious standards for OSV s over 6,000 GT ITC. Accepting that current OSV regulations found in Subchapter L are adequate for vessels of less than 6,000 GT ITC, but may not provide the government with adequate assurances of safety for OSV s over 6,000 GT ITC the industry has prepared the following proposal. This proposal has carefully considered the existing domestic and international standards for safety, pollution prevention and mariner certification (SOLAS/MARPOL/STCW). The proposal will ensure that all offshore supply vessels over 6,000 GT ITC built in the United States will meet the highest international standards for vessel design, construction, pollution prevention and mariner certification. Page 3 of 13

4 2.0 Task Statement Deliverables The Task Statement requires the sub-committee to prepare a report to NOSAC, and if approved for NOSAC to forward to USCG. The deliverables, required by the Task Statement, include: Identify the certification category of vessel for OSV s greater than 6,000 GRT ITC. Recommend tonnage upper threshold if necessary. Recommend standards for the large OSV s. Recommend manning requirements for these large OSV s. 3.0 Research by the Subcommittee References: 46 CFR Subchapter F (Marine Engineering) 46 CFR Subchapter I (Cargo and Miscellaneous Vessels) 46 CFR Subchapter J (Electrical Engineering) 46 CFR Subchapter L (Offshore Supply Vessels) International Convention for the Safety of Life at Sea (SOLAS) for Cargo Ships International Convention for the Prevention of Pollution from Ships (MARPOL) MARPOL Annex 1 Resolution MEPC.141 MSC Resolution A.673 NVIC United States Code Title 46-Shipping US Supplement to ABS Rules for Steel Vessels for Vessels Certificated for International Voyages Standards for Training, Certification and Watchkeeping (STCW) 46 CFR Subchapter I, Part 10 - Licensing of Maritime Personnel, Part 12 - Certification of Seaman and Part 15 - Manning Requirements 46 U.S. Code Part F, Manning of Vessels Marine Safety Manual Volume 3, Marine Personnel NOSAC Task Statement Page 4 of 13

5 4.0 Findings of the Subcommittee The subcommittee met on multiple occasions over the past several months and discussed various alternatives to address each bullet in the task statement. Regarding the first task statement bullet Identify the certification category of vessel for OSV s greater than 6,000 GRT ITC the committee evaluated the option of using either Subchapter L or I. While Subchapter I is certainly available and could be used for large OSVs, it could not be used unless it was modified significantly to allow certain specific exemptions that would practically allow for OSV operations. Subchapter I as written will not allow for present day OSV operations. The original presentation to NOSAC approached the problem from this standpoint [Subchapter I revised], however when it was investigated in more depth, it was deemed more applicable to add another section to Subchapter L for OSVs Equal to or Greater Than 6000 GT [similar to what was done for liftboats] than to do a major rewrite of Subchapter I to incorporate OSV operational considerations. The NOSAC recommendations ensure that vessels of this size and class are designed and built in accordance with regulations suitable for safe and effective operation throughout the world. The second bulleted item, Recommend tonnage upper threshold if necessary was also evaluated and it was determined that adding an upper threshold would be inappropriate due to the unknown size of these future vessels. The approach was taken to require the vessel design and safety standards to be appropriate for the size vessel that is built. The third bulleted item, Recommend standards for the large OSV s was debated by the subcommittee and the outcome is listed in the recommendations which follow in section 5.1 of this document. It should be noted that these proposed new standards are considered to be more stringent than the requirements of Subchapter I due to the addition of design and safety requirements to these larger vessels. The last bulleted item, Recommend manning requirements for these large OSV s similarly was debated by the subcommittee and the outcome is addressed in Section 5.2 of this document. Page 5 of 13

6 5.0 Recommendations The task statement of this subcommittee specifically identified four different task items. Those four items are addressed in the following recommendations which have been divided into two different categories. Section 5.1 pertains strictly to the required changes to Subchapter L to address the design of these larger vessels and Section 5.2 addresses the manning needs of these larger vessels. 5.1 RECOMMENDED CHANGES TO SUBCHAPTER L Note to Reviewer: The recommendations following address changes to exiting Subchapter L and address additional requirements within Subchapter L to reflect elevated standards for OSVs Equal to or in Excess of 6000 GT. PLEASE NOTE that the composite of proposed recommendations below establishes a standard for design, construction and safety equal to Subchapter I standards Definitions Offshore Supply Vessel Is more than 15 but less than 500 gross tons (as measured under the Standard, Dual, or Simplified Measurement System under part 69, subpart C, D, or E, of this chapter) or is less than 6,000 gross tons any tonnage (as measured under the Convention Measurement System under part 69, subpart B, of this chapter); Persons Engaged in the Business of the Ship (PEBS) means an individual carried aboard an OSV and employed in the business of the vessel; who has contributed no consideration for carriage aboard and is paid for services aboard. Does not include the master or a member of the crew engaged in the business of the vessel. [Note that this wording is precisely in agreement with SOLAS.] International Voyage Wording of definition for International Voyage needs to be changed to International Voyage means a voyage from a country to which the present Convention applies to a port outside such country, or conversely. [Note that his wording is an exact replication of the definition of an International Voyage from the SOLAS regulations.] Note to Reviewer: Industry as a whole notes that the limitation of 36 Offshore Workers is a very serious limitation and problem for these vessels. It is recommended that the restriction to the number of Offshore Workers allowed to be carried be limited only by the stipulated USCG approved standard of accommodations and lifesaving equipment installed on the vessel. As well, it is suggested that a new category of Persons Engaged in the Business of the Ship be added, to delineate between a worker that is on the vessel for simple transit and one that is routinely engaged in the business of the ship, but not crew. Suggested new wording for this section is as follows: Page 6 of 13

7 Carriage of Offshore Workers & Persons Engaged in the Business of the Ship (a) (b) Offshore workers and/or Persons Engaged in the Business of the Ship may be carried aboard an OSV in compliance with this subchapter. The maximum number of Offshore Workers and/or Persons Engaged in the Business of the Ship authorized for carriage will be endorsed on the vessel s Certificate of Inspection; but in no case will the number of Offshore Workers and/or Persons Engaged in the Business of the Ship authorized for carriage exceed the number of berthing units and/or fixed seating, appropriate for the duration of the voyage (under Parts 127 and 133 of this subchapter). No more than 12 Offshore Workers may be carried aboard an OSV certificated under this subchapter when on an international voyage, as defined in Part , unless the vessel holds a valid passengership safety certificate issued in compliance with the International Convention for the Safety of Life at Sea, 1974, as amended. Note to Reviewer: Following are recommended additional regulations establishing higher design, construction and operating standards for >6000GT vessels. These additional regulations reflect the addition of a new Part 135 to cover these vessels. This was previously done with liftboats in Part 134, so the precedent is already set to do this. PART 135. ADDED PROVISIONS FOR OSV S EQUAL TO OR GREATER THAN 6000 GT Applicability This part, as well as parts 125 through 133 of this Subchapter, applies to each OSV equal to or greater than 6000 GT which flies the US Flag to which this Subchapter applies Design Requirements a) Each OSV equal to or greater than 6000 GT shall be required to obtain and maintain a class certificate as issued by a classification society which is approved for initial issuance or renewal of a Certificate of Inspection under the Alternate Compliance Program as outlined in subpart of this chapter for vessels certificated for international voyages. b) Each OSV equal to or greater than 6000 GT shall be required to obtain and maintain current all applicable certificates that are required by the International Convention for the Safety of Life at Sea [SOLAS] for Cargo Ships as issued by the US Flag authority or their designated representative. Page 7 of 13

8 c) Each OSV equal to or greater than 6000 GT shall be required to obtain and maintain current certification as required by the International Convention for the Prevention of Pollution from Ships (MARPOL), as amended. Note to Reviewer: It should be clearly understood that the above recommendation is that ALL applicable documents necessary for a vessel to operate Internationally must be obtained and maintained by this class of vessel. While not specifically addressed by the recommendation, reviewer should take particular note that the 2 following International Resolutions of particular importance must be obtained and maintained: (a) MARPOL Annex 1 Resolution MEPC.141 (54), adopted on 24 March, 2006, as applicable. This is the MARPOL Protected Fuel Tank amendment, which requires that EVERY fuel tank be double skinned in a vessel that carries more than 600m3 of fuel. Any OSV of this magnitude will carry in excess of 600m3 of fuel, so every fuel tank is required to be double skinned. This is in EXCESS of OPA 90 double skin requirement, which is for Cargo Fuel only. This is of particular importance to validate that the OSV exemption from OPA 90 should remain effective for Subchapter L vessels, and to assure that these larger OSVs, while not being OPA 90 compliant, will have even more double skin protection than OPA 90 requires. (b) MSC Resolution A.673 (16) as amended by MEPC.158 (55) and MSC.236 (82), and as implemented by NVIC This is the new NLS amendment as issued by IMO. These amendments are considered important in that these vessels will invariably carry NLS cargos. The eventual application of these requirements will be as determined by USCG in developing new policy or in expanding NVIC While the requirement for these vessels to conform to these resolutions is enforced by (c), it was felt that it should be emphasized to the reviewer that these recommendations had, in fact, considered this resolution as a condition of certification for these vessels _General Marine Engineering Requirements Marine engineering details. (a) All marine engineering details such as piping, valves, fittings, boilers, pressure vessels, etc., and their appurtenances installed on the vessel, shall be designed, constructed, and installed in accordance with the provisions of subchapter F (Marine Engineering) of this chapter _General Electrical Engineering Requirements Electrical engineering details. (a) All electrical engineering details and installations shall be designed and installed in accordance with subchapter J (Electrical Engineering) of this chapter. Page 8 of 13

9 _Inspection of Vessels Standards in inspection of hulls, boilers, and machinery. In the inspection of hulls, boilers, and machinery of vessels, the standards established by an authorized classification society respecting material and inspection of hulls, boilers, and machinery, and the certificate of classification referring thereto, except where otherwise provided for by the rules and regulations in this subchapter, subchapter E (Load Lines), subchapter F (Marine Engineering), subchapter J (Electrical Engineering), and subchapter W (Lifesaving Appliances and Arrangements) of this chapter, shall be accepted as standard by the inspectors Alternate compliance. (a) In place of compliance with other applicable provisions of this subchapter, the owner or operator of a vessel subject to plan review and inspection under this subchapter for initial issuance or renewal of a Certificate of Inspection may comply with the Alternate Compliance Program provisions of part 8 of this chapter. (b) For the purposes of this section, a list of authorized classification societies, including information for ordering copies of authorized classification society rules and supplements, is available from Commandant (G-MSE), 2100 Second St., SW., Washington, DC ; telephone (202) ; or fax (202) Authorized classification society rules and supplements are incorporated by reference into 46 CFR 8.110(b) Carriage of Offshore Workers and Persons Engaged in the Business of the Ship. (a) (b) Offshore Workers and/or Persons Engaged in the Business of the Ship may be carried aboard an OSV in compliance with this subchapter. The maximum number of Offshore Workers and/or Persons Engaged in the Business of the Ship authorized for carriage will be endorsed on the vessel s Certificate of Inspection; but in no case will the number of Offshore Workers and/or Persons Engaged in the Business of the Ship authorized for carriage exceed the number of berthing units and/or fixed seating, appropriate for the duration of the voyage (under Parts 127 and 133 of this subchapter) and SOLAS Chapter III as required for Cargo Ships. No more than 12 Offshore Workers may be carried aboard an OSV certificated under this subchapter when on an international voyage, as defined in Part , unless the vessel holds a valid passengership safety certificate issued in compliance with the International Convention for the Safety of Life at Sea, 1974, as amended Lifesaving Systems Page 9 of 13

10 Lifesaving appliances and arrangements must comply with part 133 of this subchapter and the provisions of the International Convention for the Safety of Life at Sea [SOLAS] Chapter III as required for Cargo Ships. Page 10 of 13

11 5.2 Recommended Manning Requirements Projected Manning OSV Over 6000 GT ITC Initial Manning Level: Two-Watch System (10) 1-Master 2-Licensed Mate 2-AB 1-Chief Engineer 2-Licensed Engineer 2- QMED/Tankerman Proven Automation Manning Level: Two-Watch System (8) 1-Master 2-Licensed Mate 2-AB 1-Chief Engineer 1-Licensed Engineer 1- QMED/Tankerman It is anticipated that under the twowatch system proposed neither the master nor chief engineer will Voyage Over 600 Miles (14) 1-Master 3-Licensed Mate 3-AB 1-Chief Engineer 3-Licensed Engineer 3-QMED/Tankermen Voyage Over 600 Miles (10) 1-Master 3-Licensed Mate 3-AB 1-Chief Engineer 1-Licensed Engineer 1-QMED/Tankermen normally stand watch, and will concentrate on vessel operations vice watch standing. However, this provides an additional person for high intensity operations, to address any fatigue issues that may arise or to stand in if one of the other officers is sick. This is a very conservative recommendation, as the typical twowatch system has the master standing a 12-hour watch each day. This recommendation is based upon Coast Guard indications of concern over the workload of officers on such large vessels. The level of manning on a vessel is highly subjective and generally left to the discretion of the OCMI that certificates the vessel. Sample manning scales are found in the Coast Guard Marine Safety Manual Volume Three. The sample manning scales are based upon the legal requirements for manning found in title 46 U.S. Code. *Variables At the discretion of the OCMI. Engine room and deck personnel may be reduced based upon the installation of automation and the implementation of a maintenance plan. Maintenance personnel can then be substituted for licensed engineers, QMED s and AB s. Reductions in crew based on automation follow a four-step process; conceptual approval, technical review & system testing, initial certification and final approval. The final approval and reduction of manning comes after 3000 hours of operation and a review of equipment performance records. Page 11 of 13

12 6.0 Closure The Certification and Standards for Large OSV s subcommittee of the National Offshore Safety Advisory Committee hereby submit this report in response to issues raised in the Task Statement. The sub-committee is of the opinion that this report constitutes completion of the assignment given to it by the NOSAC and adequately addresses the work and recommendations requested in the Task Statement. During its work, the sub-committee identified an additional issue related to these larger OSV s. The sub-committee recommends the NOSAC consider creating a separate subcommittee to evaluate the requirements for licensing the mariners that operate these larger vessels. Respectfully submitted this 18 th day of April, Ben Bordelon Chairman Page 12 of 13

13 7.0 Participants Bob Alario, Alario and Associates Ben Bordelon, Bollinger Shipyards, Inc. Rene Leonard, Bollinger Shipyards, Inc. Dave Hedgepeth, Chevron Gary Rook, Edison Chouest Offshore Richard Bourque, Edison Chouest Offshore Dan Koch, Guido Perla and Associates Carl Annessa, Hornbeck Offshore Dan Gaiennie, Hornbeck Offshore Charles Bedell, Murphy Oil Corporation Richard Block, National Mariners Association Ken Parris, Offshore Marine Safety Association Ken Wells, Offshore Marine Safety Association Nicki Candies, Otto Candies Grady Cable, Otto Candies Jim Whitely, Rigdon Marine Robert Clemons, Seacor Jerry Dardar, Superior Energy Services Steve Dick, Tidewater Mark Sales, Tidewater Jim Magill, United States Coast Guard Page 13 of 13

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