1. OFFSHORE OPERATIONS COURSE
SECTION 3.
CERTIFICATION AND INSPECTION
Training to be FIRST
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SECTION 3
CERTIFICATION AND INSPECTION
TABLE OF CONTENTS CERTIFICATION
CHAPTER 1 INTRODUCTION 2
1.1 GENERAL INFORMATION. 2
CHAPTER 2 CERTIFICATION AUTHORITIES 3
2.1 PRINCIPAL CERTIFICATION AUTHORITIES 3
2.2 THE INTERNATIONAL MARITIME ORGANIZATION (IMO) 5
2.3 THE PURPOSE OF THE IMO 6
2.4 THE REASONS OF THE EXISTANCE OF THE IMO 6
2.5 IMPLEMENTATION OF THE IMO CONVENTIONS? 6
2.6 LIST OF MAIN CCONVETIONS, PROTOCOLS AND CODES AFFECTIING
THE MODU CERTIFICATION 7
2.7 CONSEQUENCES OF NON COMPLIANCE. 7
2.8 OVERVIEW OF CLASSIFICATION AND CERTIFICATION SYSTEM 8
CHAPTER 3 SURVEYS AND INSPECTIONS 15
3.1 INTRODUCTION 15
3.2 PERIODIC SURVEYS 15
3.3 FLAG ANNUAL SAFETY INSPECTIONS (ASI) 15
3.4 SURVEY PREPARATION. 17
3.5 COMMUNICATION WITH THE SURVEYOR 18
CHAPTER 4 THE CERTIFICATES AND SURVEYS 19
4.1 SPECIAL CERTIFICATES. 19
4.2 COUNTRY OF REGISTRY AND FLAG RELATED CERTIFICATES. 20
4.3 CLASS CERTIFICATES 41
4.4 COASTAL STATE ORGANISATION AND CERTIFICATES. 50
4.4.1 CANADA 50
4.4.2 DENMARK 51
4.4.3 NETHERLANDS 51
4.4.4 NORWAY 51
4.4.5 UNITED KINGDOM 53
4.4.6 UNITED STATES OF AMERICA 55
2. OFFSHORE OPERATIONS COURSE
SECTION 3.
CERTIFICATION AND INSPECTION
CHAPTER ! INTRODUCTION
Training to be FIRST
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CHAPTER 1 INTRODUCTION
1.1 GENERAL INFORMATION.
The intent of the section Certification is to give an overview of the complex
requirements to maintain proper certification procedures for Mobile Offshore Drilling
Units (MODU).
The information includes information from the Classification Society Regulations,
Government rules, International Conventions and for an extend from the various
certification guidance publications compiled with many hours of work by the
Transocean SedcoForex certification department. (In particular the Transocean
SedcoForex North Sea Region Certificate and Survey Guidelines)
The purpose of certification and inspection is:
1. To ensure compliance with
Classification Society Rules.
Flag State Requirements.
Coastal State Legislation
Company Standards
2. To maintain a safe and environmental friendly operation.
3. For the insurance company, certification provides the security that the
installation safety and construction is in accordance with acceptable standards.
The discussion on certification and inspection covers all types of MODU’s and
consequently is not rig specific. For the individual rig, consult the MOM guidelines
covering the regulations from various authorities as mentioned above. Use the
information of this course as a guideline and not as an instruction manual.
Class Societies and Government Organisations make constant changes that effect the
certification, surveys, and inspections. To prevent surprises maintain a file with the
latest editions of the rules, regulations, and guidelines.
It is the owner’s responsibility to apply for and maintain the appropriate certificates.
Apart from being very unprofessional, an expired certificate is costly, and in the
worse case stops operations. Follow up all year around on scheduled inspections and
maintenance of equipment instead of waiting until the last moment before the survey
is due.
The Company will have at any time minimum operating standards either on a
Corporate (worldwide) or on Region (Local) basis. Each region is responsible through
the Rig Manager and OIM for proper administration and maintaining valid
certification system for the individual rig operating in the region and districts.
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SECTION 3.
CERTIFICATION AND INSPECTION
CHAPTER 2 CERTIFICATION AUTHORITIES
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CHAPTER 2 CERTIFICATION AUTHORITIES
2.1 PRINCIPAL CERTIFICATION AUTHORITIES
The three major authorities that issue certificates for MODU’s are:
1 Coastal State Authorities.
The boundaries of the offshore areas are legislated by
international agreements. Each government enacts rules for the
offshore area under their jurisdiction.
The offshore area goes beyond the Territorial Sea, which is the
3 nautical mile zone. The government names the offshore area
as Continental Shelf (UK) or Offshore Continental Shelf
(USA). See fig 2.1 for some Continental Shelf designations.
When operating within the offshore area of a country, the
MODU owner has a legal obligation to comply with the rules
and regulations laid down by the government of that country.
Government authorities employ Classification Societies or their
own organisation to control approvals, issue certificates and to
perform inspections.
Fig. 2.1 Example of Offshore Continental Shelf designations.
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CHAPTER 2 CERTIFICATION AUTHORITIES
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2 Classification Society Authorities
The Class Societies are independent agents. The Classification
Societies establish standards and rules for the design,
construction, operation, maintenance, and inspection for vessels
and equipment. Vessels in this respect includes MODU’s
The vessels fall in categories such as cargo ships, oil carriers,
MODU’s etc. The Classification Society assigns the “Class” to
the Transocean SedCOForex MODU’s.
Classification Societies started their services to respond to the
demand from insurance companies and Government
Authorities to have an independent agent to supply information
on the reliability of a vessel. Today this service includes
floating structures.
The establishment of the Classification Societies tremendously
reduced the risk of poor design and catastrophic failure
The main function of the Class Societies did not change much
over the years, but nowadays includes many other tasks such as
design, inspection, recommendations, establish standards and
technical studies.
Because of their expertise and ability to remain independent of
the pressure from the industry, insurance companies,
government authorities, and international organisations use
their services
The Classification Society is not a regulatory body, but
Government Authorities can employ a Classification Society.
Regulatory bodies use Classification |Societies to implement
and control Government Rules and Regulations.
Classification is a non-mandatory process. However, to allow
an installation to engage freely in international operations, to
operate in certain areas, to obtain a contract and to obtain
insurance coverage Classification is required.
The Classification Societies issue one major certificate the
‘Certificate of Classification’. In addition, the Classification
Societies also issue reports certifying equipment and
machinery, anchors, chain, cranes, cargo handling equipment,
electrical equipment, diesel engines, generators, thrusters, etc.
The Classification Societies most used by the offshore drilling
industry are ABS (American Bureau of Shipping),.DNV (Det
Norske Veritas), Lloyd’s (Lloyd’s Register of Shipping), and
BV (Bureau Veritas)
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CHAPTER 2 CERTIFICATION AUTHORITIES
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3 The Country of Registry Authorities (the Flag State)
A MODU can only work freely in international operations if a
recognized maritime authority accepts the unit.
Acceptance of the MODU by a nation entitles the unit to fly the
flag of the nation, the so-called Flag State.
If the Flag State is a member of the International Maritime
Organization (IMO), the MODU receives legal protection
within the international seafarer’s community.
The “Certificate of Registry” (also called “Nationality
Certificate” or “Navigation License”) proofs the acceptance by
the Flag State.
To enter in the official register of a country the MODU has to
comply with that country national rules and regulations and
international conventions to which that country signed a
membership.
The certificates, licenses and other documents demonstrate
compliance with the international accepted standards. The
certificates remain valid by operating, maintaining, surveying
and inspecting the MODU in accordance with the conditions of
the IMO standards the certificates MODU.
The requirements include such items as design, construction,
stability, freeboard, watertight integrity, fire fighting and life
saving appliances, pollution prevention, radio installations,
manning certification and levels, navigation, normal and
emergency operations mooring and positioning systems levels
etc.
In most cases, the country of registry employs Class Societies
to execute the certification procedure.
2.2 THE INTERNATIONAL MARITIME ORGANIZATION
(IMO)
The IMO is a specialized agency of the United Nations.
The IMO was established by means of a Convention adopted under the
auspices of the United Nations.
It is an international body which members are seafaring countries. At
present there are 158 members.
The IMO was established in 1948. The original name was the Inter-
Governmental Maritime Consultative Organization (IMCO).
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2.3 THE PURPOSE OF THE IMO
The original purpose was to establish an international body to promote
the maritime safety.
The responsibility now is to improve the international shipping safety
and to prevent marine pollution.
Many International Conventions, Codes, Resolutions and
Recommendations have been adopted and enforced since the
establishment.
An important task is too to verify the proper implementation by each of
the members.
2.4 THE REASONS OF THE EXISTANCE OF THE IMO
With an international standard the international world of shipping is
ensured of at least a minimum safety standard.
The great advantage is that all countries agree and accept the safety and
pollution prevention standards as implemented on every vessel.
2.5 IMPLEMENTATION THE IMO CONVENTIONS?
The Governments implement the IMO Conventions NOT the IMO.
The IMO only adopts the Conventions. The IMO does not enforce laws.
Each government member of the IMO agrees to take the responsibility
to implement a Convention that has been adopted.
This means the Government legislates the Conventions and enforces the
Conventions as a law.
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2.6 LIST OF MAIN CCONVETIONS, PROTOCOLS AND
CODES AFFECTIING THE MODU CERTIFICATION
Safety of Life at Sea Convention of 1974. with subsequent amendments
(SOLAS).
IMO Code for Construction and Equipment of Mobile Offshore Drilling
Units, 1979 and 1989 and subsequent amendments.
International Convention of Load Lines (ILLC) 1966 and subsequent
amendments.
International Convention for the Prevention of Pollution from Ships,
1973 and protocol 1978 (MARPOL 73/78)
Convention on the International Regulations for Preventing of Collision
at sea 1972 (COLREG 1972) and subsequent amendments.
International Convention on Tonnage Measurement of Ships, 1969
Standards for Training Certification and Watch keeping, 1995
(STCW95)
2.7 CONSEQUENCES OF NON COMPLIANCE.
Failure to comply with the Classification Society or Government rules and regulations
will have serious consequences. An expired certificate or a survey that that fails the
standard of safety, design, construction, or operational matters is subject to penalties.
The minimum charge is operating with an ‘Improper Document’. In the worst case the
operation is stopped or the MODU is kept in port until the deficiencies are cleared.
Non-compliance with the Classification Society rules exposes the Class
Certificates to invalidity. Without valid Class Certificates, the vessel or
MODU becomes “UnSeaworthy” which is legally and contractual not an
acceptable position to continue to work.
Non-compliance with Government rules means the vessel or MODU
violates the Government law. This can be the law by Country of
Registry or by the Government of the Continental Shelf. The owner and
the OIM (Master) are open for civil or criminal prosecution. The
International Certificates, the OIM (Master) licenses and the Certificate
of Registry are all in jeopardy.
The importance of Certification and Inspection is obvious. To retain valid
certification, it is essential to maintain the related construction and equipment in good
condition trough out the period between two surveys and not just a short period before
the survey is due. Any deficiencies need immediate action.
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Under special circumstances, the Classification Society may accept to postpone
periodical surveys upon consideration in each separate case. To obtain postponement
the Rig Manager must apply in writing to the Classification Society in good time
before the expiration date of the certificate. The application must sstate
The reasons for post postponement.
The anticipated duration of the postponement.
The technical and operation actions to cover all safety isssues.
The ultimate person on board responsible to ensure that all certificates are valid and
renewal of the certificates is done in time is the Offshore Installation Manager (OIM)
or if applicable the Master.
2.8 OVERVIEW OF CLASSIFICATION AND
CERTIFICATION SYSTEM
The following Tables 1-6 are examples used by UK company certification
department to assist in the administration and understanding of the Classification
Controlled Certificates and The Flag State Certificates
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Table 1 Classification Society Certification
Range (months)
Item
Interval
(years)
Plus Minus
CERTIFICATES
Classification Certificate (Hull and / or Machinery) 5 0* 3†
Main Class / Functional Additional Class Surveys
Hull, machinery and equipment Renewal Survey 5 0* 3*
Hull, machinery and equipment Annual Survey 1 3 3
Hull, machinery and equipment Intermediate Survey 2½ 9‡
9‡
Annual audit of planned maintenance arrangements 1 3 3
Drilling Unit Renewal Survey 5 0* 3†
Drilling Unit Annual Survey 1 3 3
Additional Class Surveys (optional)
Drilling Equipment (e.g. DNV DRILL Class) Renewal Survey 5 0* 3†
Drilling Equipment (e.g. DNV DRILL Class) Annual Survey 1 3 3
Lifting Appliances (e.g. DNV CRANE Class) Renewal Survey 5 3 3
Lifting Appliances (e.g. DNV CRANE Class) Annual Survey 1 3 3
Dynamic Positioning System (e.g. DNV DYNPOS Class)
Periodical Survey
2½ 6 6
Positioning Mooring Equipment (e.g. DNV POSMOOR Class)
Renewal Survey
5 0* 3*
Positioning Mooring Equipment (e.g. DNV POSMOOR Class)
Intermediate Survey
2 ½ 9‡
9‡
Positioning Mooring Equipment (e.g. DNV POSMOOR Class)
Annual Survey
1 3 3
Unmanned Machinery Space(e.g. DNV E0 or ECO Class)
Renewal Survey
5 0* 3†
Unmanned Machinery Space(e.g. DNV E0 or ECO Class)
Annual Survey
1 3 3
Notes
* In exceptional cases (e.g. stuck on well or abnormal operating condition), the CS may accept to
extend the range by a maximum of three months.
†
Surveys for renewal may be commenced a maximum of 12 months before due date. If surveys
are completed more than 3 months before due date the next renewal will be due 5 years after that
completion date.
‡
Intermediate Surveys are normally to be carried out with the 2nd
or 3rd
annual survey following
Renewal Survey. Parts of the intermediate surveys, which are additional to the annual surveys,
may be carried out at or between the 2nd
or 3rd
annual survey.
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Bahamian Flag
Description Contact Validity
Certificate of Registry BMA N/A
Minimum Safe Manning Certificate BMA N/A
Radio License BMA/Tel N/A
Annual Nautical Inspection BMA 1 year
International Tonnage Certificate CS N/A
International Load Line Certificate CS 5 years
Renewal Survey for International Load Line Certificate CS 5 years
Annual Survey for International Load Line Certificate CS 1 year
IOPP Certificate CS 5 years
Renewal Survey for IOPP Certificate CS 5 years
Intermediate Survey for IOPP Certificate CS *
Annual Survey for IOPP Certificate CS 1 year
Alternative 1†
SOLAS Cargo Ship Safety Construction Certificate CS 5 years
Renewal Survey for SOLAS Cargo Ship Safety Construction
Certificate
CS 5 years
Mandatory Annual Survey for SOLAS Cargo Ship Safety
Construction Certificate
CS 1 year
SOLAS Cargo Ship Safety Equipment Certificate CS 2 years
Renewal Survey for SOLAS Cargo Ship Safety Equipment
Certificate
CS 2 years
Mandatory Annual Survey for SOLAS Cargo Ship Safety
Equipment Certificate
CS 1 year
SOLAS Cargo Ship Safety Radio Certificate CS 1 year
Renewal Survey for SOLAS Cargo Ship Safety Radio
Certificate
CS 1 year
Alternative 2†
MODU Code Certificate CS 5 years
Renewal Survey for MODU Code Certificate CS 5 years
Safety Equipment Survey for MODU Code Certificate CS 2 years
Annual Survey for MODU Code Certificate CS 1 year
Radio Installation Survey for MODU Code Certificate CS‡
1 year
Notes: * Carried out simultaneous with 2nd
or 3rd
Annual Survey
†
Owner has the option of choosing between following SOLAS
convention or MODU Code.
‡
Coastal States representing agency may carry out surveys of radio
installation
Table 2 Flag State Certificates Bahamas
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Liberian Flag
Description Contact Validity
Certificate of Registration LSI N/A
Minimum Safe Manning Certificate LSI N/A
Radio License LSI/Tel N/A
International Tonnage Certificate CS N/A
International Load Line Certificate CS 5 years
Renewal Survey for International Load Line Certificate CS 5 years
Annual Survey for International Load Line Certificate CS 1 year
IOPP Certificate CS 5 years
Renewal Survey for IOPP Certificate CS 5 years
Intermediate Survey for International Oil Pollution Prevention
Certificate
CS *
Annual Survey for IOPP Certificate CS 1 year
MODU Code Certificate CS 5 years
Renewal Survey for MODU Code Certificate CS 5 years
Safety Equipment Survey for MODU Code Certificate CS 2 years
Annual Survey for MODU Code Certificate CS 1 year
Radio Installation Survey for MODU Code Certificate CS†
1 year
Notes: * Carried out simultaneous with 2nd
or 3rd
Annual Survey
†
Coastal States representing agency may carry out surveys of radio
installation
Table 3 Flag State Certificates Liberia
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Norwegian Flag
Description Contact Validity
Nationality Certificate NR N/A
Minimum Safe Manning Certificate NMD N/A
Radio License Tel N/A
International Tonnage Certificate NMD N/A
International Load Line Certificate NMD 5 years
Renewal Survey for International Load Line Certificate NSC 5 years
Annual Survey for International Load Line Certificate NSC 1 year
IOPP Certificate NMD 5 years
Renewal Survey for IOPP Certificate NSC 5 years
Intermediate Survey for International Oil Pollution Prevention
Certificate
NSC *
Annual Survey for IOPP Certificate NSC 1 year
Certificate of Fitness NMD 5 years
Renewal Survey for Certificate of Fitness NSC 5 years
Annual Survey for Certificate of Fitness NSC 1 year
Safety Construction Certificate NMD 5 years
Renewal Survey for Safety Construction Certificate NSC 5 years
Annual Survey for Safety Construction Certificate NSC 1 year
Safety Equipment Certificate NMD 5 years
Renewal Survey for Safety Equipment Certificate NSC 5 years
Annual Survey for Safety Equipment Certificate NSC 1 year
Safety Radio Certificate NMD/Tel 1 year
Renewal Survey Safety Radio Certificate Tel†
1 year
4 Yearly Survey of Lifting Appliances ‡
4 years
Annual Survey of Lifting Appliances ‡
1 year
Notes: * Carried out simultaneous with 2nd
or 3rd
Annual Survey
†
Other authorised agencies, e.g. Coastal States representing agency,
may carry out surveys of radio installation
‡
Must be carried out be a “competent person” authorised by NMD.
May be NSC inspector, CS surveyor or authorised 3rd
party (e.g.
service company)
N.B. Compliance with Norwegian Flag requirements must be able to be
demonstrated through the Company’s documented management
systems (ref. Management System Manual).
Table 4 Flag State Certificates Norway
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Panamanian Flag
Description Contact Validity
Navigation License (Patente Reglamentaria de Navegaçion) PDMA N/A
Minimum Safe Manning Certificate PDMA N/A
Radio License PDMA N/A
Safety Certificate PC/OS 1 year
International Tonnage Certificate CS N/A
International Load Line Certificate CS 5 years
Renewal Survey for International Load Line Certificate CS 5 years
Annual Survey for International Load Line Certificate CS 1 year
IOPP Certificate CS 5 years
Renewal Survey for IOPP Certificate CS 5 years
Intermediate Survey for International Oil Pollution Prevention
Certificate
CS *
Annual Survey for IOPP Certificate CS 1 year
MODU Code Certificate CS 5 years
Renewal Survey for MODU Code Certificate CS 5 years
Safety Equipment Survey for MODU Code Certificate CS 2 years
Annual Survey for MODU Code Certificate CS 1 year
Intermediate Survey for MODU Code Certificate CS 2½
years*
Radio Installation Survey for MODU Code Certificate CS†
1 year
Notes:
* Carried out simultaneous with 2nd
or 3rd
Annual Survey
†
Coastal States representing agency may carry out surveys of radio installation
Table 5 Flag State Certificates Panama
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USA Flag
Description Contact Validity
Certificate of Registration USCG N/A
Minimum Safe Manning Certificate USCG N/A
Radio License USCG N/A
International Tonnage Certificate CS N/A
International Load Line Certificate CS 5 years
Renewal Survey for International Load Line Certificate CS 5 years
Annual Survey for International Load Line Certificate CS 1 year
IOPP Certificate CS 5 years
Renewal Survey for IOPP Certificate CS 5 years
Intermediate Survey for International Oil Pollution Prevention
Certificate
CS *
Annual Survey for IOPP Certificate CS 1 year
Certificate of Inspection USCG 2 years
Survey for Certificate of Inspection USCG 2 years
Annual Survey for Certificate of Inspection USCG 1 year
Alternative 1†
SOLAS Cargo Ship Safety Construction Certificate USCG 5 years
Renewal Survey for SOLAS Cargo Ship Safety Construction
Certificate
USCG 5 years
Mandatory Annual Survey for SOLAS Cargo Ship Safety
Construction Certificate
USCG 1 year
SOLAS Cargo Ship Safety Equipment Certificate USCG 2 years
Renewal Survey for SOLAS Cargo Ship Safety Equipment
Certificate
USCG 2 years
Mandatory Annual Survey for SOLAS Cargo Ship Safety
Equipment Certificate
USCG 1 year
Alternative 2†
MODU Code Certificate USCG 2 years
Renewal Survey for MODU Code Certificate USCG 2 years
Annual Survey for MODU Code Certificate USCG 1 year
Notes:
* Carried out simultaneous with 2nd
or 3rd
Annual Survey
†
Owner has the option of choosing between following SOLAS convention or
MODU Code. Additionally USCG may, upon request, inspect an installation
for compliance against IMO MODU Code requirements.
Table 6 Flag State Certificates USA
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CHAPTER 3 SURVEYS AND INSPECTIONS
3.1 INTRODUCTION
Although the ultimate person responsible to maintain valid certification on board at all
times is the OIM on board, the rig manager and the OIM are both responsible to
arrange the surveys in time and before expiration date of the certificate.
After the completion of the construction, competent and independent surveyors
conduct surveys.
The surveys are to ensure that the MODU continues to comply with the Regulatory,
International, and Class standards on safety, design, construction, and operational
matters. To maintain valid certificates the surveys must be completed in time and in
accordance with the schedules.
3.2 PERIODIC SURVEYS
In general all MODU`s are subject to periodical surveys of one of the following
categories:
Annual Survey
Intermediate Survey
Renewal Survey
Biannual, annual, quadrennial, every 5 years etc.
Non Periodic
Unexpected
After damage and repair
For modification and additions
Continuous. Scheduled progressive surveys over a period of time.
Special Surveys. Major surveys before renewal of a certificate for an
extended period.
3.3 FLAG ANNUAL SAFETY INSPECTIONS (ASI)
The Country of Registry will appoint an inspector (surveyor) to review the vessel’s
safety equipment, radiotelephony equipment, documentation and manning structure.
The surveyor carries out the inspections and surveys in order to confirm that the
safety and navigation equipment are adequate (approved types), that the required
documentation is held on board the vessel, and that the manning requirements are
maintained.
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Associated documents
• Safe Manning Certificate
• Manning Schedule (Showing the manning requirements)
NOTE:
As part of the Flag ASI, the surveyor will look for certain publications that are
required to be on board. However equivalents, such as where the rig methods of
tracking and sorting ‘personnel on board’ substitute for Crew Articles - can be
accepted.
E.g. publications normally required for MODU’s registered in Liberia are:
Combined Publication Folder (Maritime Law Regulations, notices and
requirements)
Liberian articles of agreement
Medical Log Book
Captains Medical Guide
Radio Regulations. ITU Blue Book
Accident Prevention Code
International Code of Signals (ICS) Guide to Helicopter Operations
(Published by the international Chamber of Shipping for ocean going
vessels. N/A to MODU’s).
The ICS should be kept on board at the Radio Room.
Navigation Charts and Publications- required for area of operations
only.
Flag Inspectors carrying out an ASI should be in possession of inspection pro-forma.
A report copy should be left on board for early information and rig action. The official
report will follow on inspector’s report to his head office.
Annual inspection - due one month either side of the anniversary date
E.g.
Liberia – No Certificate is issued the Annual Safety Inspection Report is maintained.
Bahamas – A term Certificate valid for 1 year is issued
US Coast Guard – A term certificate of 2 years is issued
NOTES: A person on board responsible for the maintenance of the machinery such
as a Chief Engineer may be allowed to perform a limited scope of surveys
on machinery.
Surveys based on a Maintenance System approved by a Classification
Society are acceptable as part of the survey system
Surveys on Condition Monitor system covered by the Classification
Society rules are acceptable as part of the surveys system
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3.4 SURVEY PREPARATION.
Every survey needs preparation. Surveyors carry out Annual, Continuous, and Special
Surveys. Because of the very high cost to execute a major survey, it is essential to
plan and clarify as soon as possible between the owner and the surveyor, the nature,
extend and procedures for each survey.
1) Before the start of any survey, obtain the most recent Survey Status
Report from the Classification Society or Regulatory Body. For
example, the Classification Society Report contents details the gauging
and specifies the area of the structure to pass through a close
examination
2) Settle the starting date. Schedule the time required from start to finish
the survey project..
3) Arrange the location. Agree whether or not the unit will be out of
service or continues to operate
4) Schedule operation tests such as a “black out “test with minimum
disruption to the operation.
5) Prepare an agreed schedule between the owner, operator, client operator,
and surveyor for inspections and tests.
6) If third party contractors are involved such as divers or NDT specialist
include these in the schedule and consultation.
7) Arrange helicopter and supply vessel transportation for equipment and
personnel.
8) Decide on the draft required to do the survey.
9) Agree on tank testing procedures
10) Verify what specific equipment needs disassembly for inspection.
11) Include some flexibility in the schedule. The scheduled dates may slip
because of operations problems or weather delays.
12) Assign a project engineer to co-ordinate major surveys such as an
Underwater Hull Inspection, Special Periodic Survey or a major
construction inspection.
13) Have the original certificates and copies available. Take a copy of the
history concerning old deficiencies and present deficiencies.
14) For safety equipment inspections have life saving and fire fighting
equipment servicing records available. Prepare operation tests
15) Prepare tanks for inspection in accordance with safety regulations for
entering confined spaces.
16) Be prepared to have fire and boat drill exercises.
17) In case of damage, have all records available. Be sure the surveyor
represents the Class and Flag authorities. If the damage is new, have the
statement available from the principal inspector that the MODU is
seaworthy and all certificates are still in force.
18) For a cargo gear Test Survey, certified weights and weight indicators are
required. It takes time to find and arrange the weights.
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Remote operated diving inspection vessels (ROV’s) are extensively used to inspect
the underwater part of the hull. Some additional notes for the Underwater Hull
Inspection in Lieu of Dry Docking (UWILDD):
Agree on method and extend of the under water cleaning.
Agree on diver and/or ROV deployment
Agree on system of video scanning and photography.
Set up means of communication between diver, surveyor, and video tape
operator.
Set up and agree on the under water position LOCation and
identification.
3.5 COMMUNICATION WITH THE SURVEYOR
For the extensive surveys, it is preferable to visit the surveyor in person
and hand over the written request and information about the intended
survey. Use the opportunity to have a preliminary discussion of the
program.
Maintain close communication with the surveyor. Keep him informed
by telephone, fax, or e-Mail on any changes. Confirm a few days before
the survey date which surveyor will perform the survey.
Arrange transportation. If possible, accompany him on the same flight.
If possible, arrange a single cabin. He will have to work long hours and
at odd times. Every surveyor appreciates if he can do his paper work in
private without disturbance
Meet the surveyor at arrival on board and set up a meeting to introduce
him to staff members of the crew and to discuss the programme
Update the programme with the surveyor twice a day.
In the course of a survey always the surveyor always find some minor
deficiencies. Take immediate action to correct the minor deficiency. It is
in the advantage of both parties to have as less as possible deficiencies
on the official final report.
A staff member or the project engineer should always escort the
surveyor. Never let him go around on himself. First of all, it is unsafe as
he is not familiar with the rig and secondly it is not courteous to let him
wander around and loose time.
If there is a disagreement on a deficiency, do not start an angry
argument. Try to solve the problem with the on board information that is
available. Ensure that there is no misunderstanding. If necessary, call the
shore base and the surveyor’s office to sort the problem out at an higher
level. There is always a solution.
It is good practice to join the meals and coffee time with the surveyor
and to discuss the progress in a relaxed atmosphere.
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CHAPTER 4 THE CERTIFICATES AND SURVEYS
4.1 SPECIAL CERTIFICATES.
1) (a) Master Carpenter or Builders Certificate
This is a simple certificate from the original builder .It is an important legal
document. It is the evidence that the unit shipyard building project. It indicates the
date and builder’s number. It also proves that she is not a modification of an older
unit.(Fig. 4.1)
The Builders Certificate is one of the prerequisites to apply for the Certificate of
Registry
The certificate is valid indefinitely.
Fig.4.1 Builders Certificate.
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4.2 COUNTRY OF REGISTRY AND FLAG RELATED
CERTIFICATES.
1) (a) Certificate of Registry (Fig. 4.2)
With the Certificate of Registry, the MODU enters officially in the country’s Register
of Vessels. It is the official identification of the MODU recognised by other countries.
Membership in the IMO is common to all Flag States used by Transocean
SedcoForex.
The Certificate of Registry states the unit’s name, nationality, the homeport, general
particulars, major dimensions, call sign, measured Gross and Net. Tonnage, owners,
and type of service.
On the question, “Why do we need a flag registration” the answer is that there are
several good reasons:
1) It provides protection and service from that country’s diplomatic offices
in accordance with the National Law and the International Agreements
to which the country is a signatory
2) Any financing depends on the availability of a registry to record
mortgages.
3) Almost all clients inquire about the flag in the drilling contract tenders.
It is included in the description of the MODU in the contract.
4) In legal situations, the MODU can refer to the law of the country.
5) It guarantees that the standards for the IMO and other International
Conventions are part of the certification.
The flag register is mainly for ocean going drilling units. Swamp barges and some
tenders do normally not register under a flag.
Associated documents, kept with the Certificate of Registry are:
The Master Carpenter or Builders Certificate
Annual Tonnage Tax Receipts. The Net Tonnage figure from Certificate
of Measurement determines the annual fee for payment to the flag
government. .
The International tonnage certificate, 1969 code. This is the official
Tonnage Measurement Certificate.
As a side note, ship and MODU Gross and Net Tonnage are not measures of weight,
but of space because the expression “ton” indicates 100ft³ or 2.83m³. For example if
the Gross Tonnage of a MODU is 4000 tons this does not mean that the MODU’s
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weight is 4000 tons, but that the units space is measured as 400,000 cubit or 11,320
cubic meters
To qualify for the Certificate of Registry the unit must comply with the International
and National Regulations of the country. Some of the International regulations,
conventions and protocols are MODU, International Load Line, IOPP and Cargo gear
certificates.
1) (b) Provisional Certificate of Registry
After the completion of a new built unit, the authorities often issue a Provisional
Certificate of Registry. This will also take place when any of the contents of the
certificate changes such as, tonnage, owner, name, homeport etc.
The Provisional Certificate of Registry only has a limited period of validity, normally
6 months. It is the owner’s responsibility to apply in time for an extension. If the
delivery of a permanent certificate is pending on some deficiencies or required
information, the owner must proceed to clear the items as soon as possible.
1) (c) Validity
Valid indefinitely, but only if periodic surveys are carried out to the satisfaction of the
existing national and international regulations.
The Permanent or Provisional Certificate of Registry is only valid in conjunction with
valid International and National certificates
The Government of the MODU’s flag has obligations to the rest of the world because
as a member of the IMO it signed the International Rules Protocols and Conventions.
Whenever any of the other MODU’s certificates on National or International
Regulations or Safety expire the Certificate of Registry becomes automatically
invalid. In addition to the obligations of the Government, the safety of the MODU and
the crew are in jeopardy. It is obvious that the Government has good reasons to take
stern action against the MODU. The owner and the person in charge on the MODU
are responsible to take all necessary action to prevent that any of the certificates
becomes invalid.
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Fig. 4.2 Certificate of Registry
NOTE:
1. A supplement is attached to the Classification Certificate to endorse the annual
surveys between the 5 year periods.
2. Appendixes for the unit in general and the drill plant are part of the
Classification Certificate. The appendixes must be kept on board as and should
upon request presented to the surveyor.
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1) (d) Country of Registry Annual Inspections
The Country of Registry will appoint an inspector to survey the MODU every year
on:
1) Certificate of Registry
2) Safety equipment
3) Radio equipment
4) Nautical equipment
5) Documentation
6) Manning structure
7) Load Line and Tonnage
8) IOPP
9) Cargo gear
10) MODU Code. (SOLAS)
11) Safe Manning Certificate and Manning Schedules.
The names of the certificates and documents is different for each Flag State but covers
the same surveys. (See Table 1-6 in Chapter 3)
2) (a) International Load Line Certificate (Fig. 4.3)
Fig: 4.3 The Intenational Load Line Certificate
NOTE:
The International Load Line Certificate is valid subject to the annual
survey endorsements.
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Before the nineteenth century, ships were loaded to whatever draft the owner wished.
Many lives and ships were lost at sea until a British law came into force that made it
mandatory for all ships under British flag to carry a mark on the hull (The Plimsoll
Mark) indicating the maximum allowed draft.
Other countries followed the example and the IMO adopted the International Load
Line Convention of 1966, which established an international agreement on minimum
freeboards for ships on international voyages.
On Behalf of the Flag State, the International Load Line Certificate is issued by the
Classification Society under the provisions of the International Load Line Convention
(b) Validity and Surveys
A Classification Society acting on behalf of the flag Government awards the
International Load Line Certificate after a successful inspection.
The certificate is valid for 5 years subject to annual inspections of the MODU’s
condition. The completion of the annual inspection must take place within one month
of the expiration date, but for the renewal of the five-year term all inspections must be
completed within three month of the expiring date.
The Classification Society surveyor carries out the annual survey. The surveyor
makes use of standard format, approved by the IMO. The class surveyor will endorse
the reverse side of the certificate after a satisfactory inspection.
The survey concentrates on the intact condition and sea keeping qualities of the
MODU such as:
The is watertight integrity.
Stability and stability records.
Hatchways and covers.
Watertight doors.
Tank vents, air pipes, and closing arrangements.
The load line and draft marks.
Scuppers and sanitary discharges.
Keep the initial Record of Conditions of Assignment with the certificate and of course
all annual reports and correspondence regarding the corrective actions on deficiencies.
The International Load Line Certificate becomes invalid upon its expiration date or
with any changes of the information on the certificate, i.e. flag, homeport, name,
dimensions etc.
The Treaty allows heavy fines or criminal charges against the person in charge (OIM
or Master) and/or the owner, for an invalid certificate or for a MODU with a draft
exceeding the maximum allowed draft as per load line markings.
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2) (c) Provisional Load Line Certificate
As for the Certificate of Registry, it is possible to apply for a Provisional Load Line
Certificate be issued, waiting for pending matters. In most cases, the provisional
certificate is only valid for 5 months. The owner is responsible to renew the certificate
in time and to solve the outstanding deficiencies as soon as possible.
2) (a) Ships Radio Station License (Fig.4.4)
The country of Registry controls the licensing of all radio stations on board of vessels
including MODU’s. The License describes the radio equipment on board. Radio
Station Licenses include aeronautical beacons. Any third party radio station
equipment falls under the responsibility of the assigned account (Owner)
Display the original Ship Radio Station Licence permanently in the Radio Room.
3) (b) Accounting
Electronic means nowadays control. Control the accounting That is the accounting
authority will extract the traffic information from land station computers and invoice
the rig management. This replaces the former regime where traffic ‘logs’ had to be
sent in by the Radio Operator. To control the radio traffic charges it is advisable to
maintain records of all the calls.
The accounting authority may assume responsibility for obtaining the
vessel’s Ship Station License also.
Note:
Normally – as in the case of Liberian Flagged vessels only one accounting authority is
permitted for a vessel.
3) (c) Validity
The Ship radio Station Licence is valid for 4 years
4) (a) Safety Radiotelephony Certificate
Note:
For non-propelled or propulsion assist MODU’s, the IMO MODU Code Safety
Certificate satisfies the RTC requirements.
For self-propelled vessels the radiotelephony Certificate will be issued by the Class
Society acting for the Flag State.
Under the provision of the IMO regulations, a Classification Society on behalf of the
flag Government issues the Safety Radiotelephony Certificate. Before delivery of the
certificate, an authorised service company must complete a satisfactory servicing and
inspection report.
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In some countries, like the US only a Government Official from the FCC Department
(Federal Communication Commission) executes the inspection and issue the
certificate. Still an authorised service company must inspect and service the
equipment.
4) (b) Report on Radio Installation MODU ( Fig.4.4)
A valid Annual ‘Ship Station Radio Equipment (GMDSS) report must be on board.
This is an inspection for Class who requires it to complete the MODU Code surveys
(See MODU Code). It can be, and usually is, carried out by a 3rd party, as the class
surveyor may not have the competence in Radio Equipment. Using a 3rd
party is
allowed under the MODU Code rules. The class surveyor will verify that a survey has
been carried out in accordance with IMO MODU requirements.
Survival craft radio equipment and emergency position indicating
equipment are included in the inspection.
The equipment inspected will vary according to whether the vessel is
self propelled or non self propelled, e.g. the radio direction finder, radio
telegraphy equipment is included for self propelled vessels.
Note:
To prevent surprises complete the radio installation inspection approximately one
month prior to attendance for the annual or renewal MODU safety Certificates survey.
This will ensure that the necessary report will be on board the unit and will give the
time, if necessary, to carry out any repairs or adjustment to the equipment. (This
allows time to clear the survey and no outstanding items are carried into the MODU’s
Code survey)
A radio technician from an authorized representative of the Flag
administration or the Coastal State, i.e. Marconi, Mackay, Caprock
carries out the inspection..
4) (c) Validity and Surveys
The Safety Radiotelephony Certificate is valid for 1 year. To renew the certificate
complete annual survey before the expiring date.
The surveyor inspects the equipment on frequencies, proper working, emergency
power, batteries, administration of the radio logbook, license of the operator,
antennas, safety protection of the equipment and emergency frequencies
4) (d) Radiotelegraphy (Exemption) Certificate
The rig should have a Radio Telegraphy Certificate - or exemption certificate if
applicable (self propelled vessels only).
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Fig.4.4 Examples of Radio Station License and Report on Radio Station Report
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5 (a) Register of Cargo Gear (Fig.4.5)
The Classification Society submits the Register of Cargo Gear. This booklet
summarises all the rules concerning the required tests and surveys for the “cargo
gear”. The term “Cargo Gear” relates to the cranes which are used for the transfer of
material, equipment or personnel between the unit and attending vessels or when at
the quay in harbor. (Offshore, these cranes are usually the ‘pedestal cranes’ port and
starboard or aft). It would not include any equipment specific, single purpose, cranes
such as the BOP bridge cranes ,lifeboat davits or small maintenance cranes.
Each lifting device in the Cargo Gear Register has its own certification record on the
main device and components such as wire rope and hooks. The wire rope certification
includes the manufacturer, type of wire, proof load certificate, and testing records in
accordance with the classification and IMO regulations.
The Class Surveyor performs the inspection and checks crane
maintenance records normally when on board for the other ‘annual
surveys’. This satisfies for flag (MODU Code) and class (Class Cargo
Gear).
Another option is available to the owner if he wishes not to have Class inspect for
MODU code requirement. This is possible by presentation to flag (via class) of an
inspection program carried out by a duly authorized person or organization acceptable
to the flag administration, i.e. Servtech, Sparrows. Note however that - If the rig is in
possession of a Cargo Gear Register (ABS) or a Register of Lifting Appliances
(DNV) a surveyor will need to attend and witness the inspection being performed on
board.
If the owner dispenses with the ABS Cargo Gear Register and
substitutes it with his own maintenance and inspection program, that
programme will become liable to audit against the MODU code. I.e. if
the programme of inspection and maintenance is not up to date or does
not meet it’s own requirement the MODU Code will be affected.
Outstanding items may be lodged against the MODU Code survey.
NOTE:
The on board inspection of slings and shackles inspection by third party is not part of
the cargo gear inspection under the MODU Code survey.
The survey will include:
Visual surveys of crane structure for deformity, excessive wear,
corrosion, damage or fractures.
Visual inspection and non-destructive testing of crane hooks for
deformity, excessive wear or fractures.
Visual external examination and operational tests of crane machinery,
including prime mover, clutch brakes, hoisting, slewing and luffing
machinery.
Visual inspection of wire rope including end attachments.
Functional test including hoisting, lowering, slewing, safety and limiting
devices, load, and boom angle / radius indicators.
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5 (b) Retest Survey of Cargo Gear
MODU and Class Society (ABS, DNV,) require this inspection and re-testing of cargo
gear as applicable. Inspection and proof load tests take place after the installation of
the new crane, and then every 5 years during anniversary month. Only use load cells
with authorised calibration certificates.
The survey includes the Safe Working Load Test on all blocks with test loads. The
preferable method is to swing the crane with certified weights.
Load tests are also required after any major alteration or repair. Note that a straight
replacement of a minor component does not fall into this category. I.e. the certificates
accompanying the component part will suffice. Test load example: ABS Crane
Certification and Survey. (Source)
SWL of assembled crane in tons:
Proof Test Load
Up to 20 tons 25% in excess of SWL
20 - 50 tons 5 tons in excess of SWL
Over 50 tons 10% in excess of SWL
A duly authorized person or organization acceptable to the flag administration
performs the tests, i.e.: OCS, Servtech, Sparrows. If the rig is in possession of a Cargo
Gear Register (ABS) or a Register of Lifting Appliances (DNV) a surveyor will also
need to be called on board to witness the test being performed.
Maintain all the old files on used wires and attachments. The surveyor will sign for
each renewal/replacement, but only if accompanied with proper documentation. Keep
all correspondence, data packs notes on inspections and any information important
enough to save in the Cargo Gear Register.
Never use any non-certified wires or other components on the official cargo gear. The
components include all end connections. The wire and the splice need to be certified.
Many catastrophic failures were the result of a non-certified splice, socket, hook or
shackle and even securing bolts.
File the items not classed in the Cargo Gear Register in the same booklet. Many
lifting and securing items fall under “equipment” or and other category that will need
periodic survey or testing. To name a few, elevators, slings, shackles, davits, pennant-
handling cranes, pad-eyes, chains. It is much easier to keep track of the lifting gear
items with all information in one Location.
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Fig. 4.5. Example of Register of Cargo Gear.
5 (c) Validity and Surveys
To meet the Classification and MODU Codes, the cargo gear is subject to annual and
5 year surveys. The annual survey period is three (3) months either side of the
anniversary date of the last ‘load test’ carried out.
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6) (a) IMO MODU Certificate. (Safety Construction and Equipment Certificate)
(Fig 4.6)
Of all the international conventions dealing with the maritime safety, the most
important is the International Convention for Safety of Life at Sea (SOLAS).
The sinking of the passenger vessel the “Titanic” with the loss of more than 1500
passengers and crew in 1912 led to the first version of the 1914 Conference in
London.
Membership in the International Maritime Organisation is common to all serious Flag
States. The conventions on Load Lines, Tonnage Measurement, Collision Prevention
Regulations, Safety of Life at Sea, Standards of Training, Certification and Watch
Standing and Oil Pollution Prevention Regulations are the basic international
standards.
The latest version of the SOLAS convention dates back to 1974 but Protocols and
Amendments continue to update the convention with new regulations.
Many of the IMO conventions like SOLAS and the 1966 Load Line convention are
developed and designed for ships. With the introduction of MODU’s the IMO
recognised the need to develop a collection of rules, which are appropriate for the
MODU design and operation. The result is the IMO-MODU Code, which is the
international standard for the offshore drilling industry. However, SOLAS, the Load
Line Convention and other resolutions are still part of the MODU code.
The purpose of the code is to recommend design criteria, construction and equipment
standards and other safety measures to minimise risk to the personnel on board and to
the environment.
The initial survey for the IMO MODU code should be such as to ensure that the
structure, equipment, fittings, arrangements, and material fully comply with the
applicable provisions of the code.
This certificate issued by the vessel’s Class Society on behalf of the Country of
Registry confirms that the minimum international standards for design criteria,
construction, equipment, and other safety related items are adequately satisfied. The
Country of Registry (Flag) is the regulatory body regarding this certificate. (Often
referred to as ‘the administration’ when discussing exemptions, clarifications, or
approvals).
An interim certificate indicates that the full term certificate is being processed. (No
outstanding conditions or corrections required). I.e. the interim is in place to allow
lead-time.
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Fig. 4.6 Example of the IMO MODU Safety Certificate
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Fig: 4.7 Example of attachment with Non-Conformances to the MODU Safety
Certificate.
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NOTES:
1) The MODU Code certificate emanates from the IMO MODU ‘Code’. At this time,
the 1979 MODU and the later updated1989 MODU codes are in place. Refer to the
code that is associated with the rigs YEAR of BUILD. I.e. the 89 code may require
something that the 79 does not – it follows that there should be no outstanding
recommendation issued on a 1979 rig that references a requirement in the1989 code.
Exceptions published in amendments with statement on grandfather periods explain
when a regulation becomes ‘in force’. A good example is the requirements for
GMDSS* which became effective for ‘all’ rigs in 1992 via the 1991 ‘amendments’.
(*Global Maritime Distress and Safety Systems)
2) An Appendix attached to the MODU Safety Certificate lists the accepted non –
conformances. (Fig.4.7)
3) Where outstanding requirements or corrective actions arise from an annual survey
the surveyor will remove the ‘full term’ certificate.. A short term or ‘conditional’
certificate replaces temporarily the full term’ certificate including the date to
correspond with the time allowed / agreed for corrections. (3 months only, normally a
second 3-month extension is not granted). This conditional cert is of limited validity
and the full term will return when corrections are completed.
The Coastal State may impose additional requirements relating to the regulation,
operation, and survey of the MODU but a Coastal State cannot violate the drilling
unit’s code. Examples are the UK, US and Norway.
The subjects to survey are:
Construction
Ventilation arrangement
Watertight integrity
Lifeboats and their equipment
Life rafts,
Portable Fire Extinguishers
Fire and Gas Detection
Personnel Elevators
Cranes
Radio equipment
Helidecks
Stability
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6 (b) Validity and Surveys
To renew the certificate, the Classification Society, acting for the Flag Administration
will carry out the initial survey, annual surveys, and periodic surveys.
Annual inspections are carried out during the 5-year life of the MODU Code
Certificate 3 months either side of the anniversary date.
Any non-compliance discovered during the annual survey must be attended to
immediately or within an agreed period.
An intermediate survey will be carried out within a twelve (12) month period,
beginning two (2) years after the commencement of the five (5) years cycle, and
replace the second annual survey. I.e. when dates coincide, the annual survey is made
to satisfy the requirements for an intermediate survey. Likewise, at the 5th
yr. the
annual survey will be absorbed in the certificate renewal survey.
Five Year Subject to satisfactory annual surveys, the MODU certificate is valid for 5
years.
These renewal surveys validate the 5yr full term ‘MODU Code Safety Construction
and Equipment certificate. When the certificate needs to be renewed, this survey
replaces the annual survey, and it must be completed by the end of the five-(5) year
cycle. If satisfactorily completed a five (5) months interim certificate will be issued,
pending issuance of the full term certificate.
The Class surveyor will endorse the reverse side of the certificate on completion of
the survey.
Failure to correct any non-compliance may result in withdrawal of the MODU
certificate.
Should special circumstance be applicable to non-compliance, it may be possible to
obtain an ‘exemption’ from the requirement by written application to the flag
administration. By satisfactorily demonstration that other methods match the
requirement, the flag administration issues an exemption either in letterform or
exemption certificate.
NOTES:
1) All deficiencies listed by the surveyor need immediate action. Maintain close
contact with the surveyor to update him on the progress or any problems that occur.
Set target dates and rule out any delays.
2) The annual and periodic surveys are very extensive inspections on all safety
equipment, structure, arrangements, fittings, maintenance, administration and
procedures The survey should be prepared ahead of the arrival of the surveyor. Inform
each department head on the planned survey and their role in the preparation for
equipment and operation tests. Use reports from previous inspections.
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7) (a) IMO International Oil Pollution Prevention (IOPP) Certificate (Fig. 4.8)
The first Convention with the prime objective of protecting the marine environment
dates back to 1954. A multilateral agreement between the Governments established
regulations to prevent pollution of the sea by oil discharged from ships. (The
International Convention of Pollution of the Sea by Oil 1954).
Conventions and protocols since the first multilateral agreements for ships (1954)
have modified and amended the regulations pertaining to marine pollution. The
meetings of 1973 and 1978 have modified and amended the existing text and
produced the regulations MARPOL 73/78 which came into force in 1983.
Relevant publications are:
MARPOL 73/78 and subsequent amendments
Annex 1 of 73/78
Guidelines for the implementation of Annex V of Marpol 73/78
(Plastics / food / waste / garbage etc.)
Amendments and International Conferences followed in 1992 and 1996.
The IOPP (International Oil Pollution Prevention) Certificate is issued by the vessel’s
Class Society on behalf of the Country of Registry.
Liberian flag MODU’s have received exemption from compliance with Regulation 16
of Annex I, MARPOL 73/78, based on them having sludge tanks of sufficient
capacity and drip drays/catchments where required. Additionally, a satisfactory means
of cleaning and a means for discharge to a barge or by container to a reception facility
is required.
The local or regional Class Office issues interim short-term certificates, pending
issuance of the full term certificate, which can only be issued by the Class Principal
Office. The interim certificate indicates that the full term certificate is being processed
(No outstanding conditions or corrections required). I.e. the interim is in place to
allow lead-time.
NOTE:
Where outstanding requirements or corrective actions arise from an annual survey the
surveyor will remove the ‘full term’ certificate. A short term or ‘conditional’
certificate replaces temporarily the’ full term’ certificate.
With the dates and the time allowed/agreed to complete the corrections. (3 months
only.), this conditional cert is of limited validity and the full term returns after
completion of the corrections.
NOTE:
Some earlier rig may have the so-called SUPPLEMENT
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Fig. 4.8 Example of International Oil Pollution Certificate
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As MODU’s come under ships “other than oil tankers’
a Supplement is issued with the
certificate. This document is required duly completed by the Class Authority. It must
be attached to the said IOPP certificate. In this situation, the IOPP certificate is not
valid without its ‘supplement’.
The supplement specifies vessel details with regard to catchments or equivalent
measures such as:
The collection and disposal of all oily waste from drip pans, tanks,
separators or any other facilities is most important to the validity of the
certificate.
This includes the pumping arrangements and the recording of such
movements in the OIL RECORD BOOK (e.g. as issued by the Liberian
Flag Administration). It is important to keep accurate records, as the
surveyor will check the Oil Record Book every time he visits the rig.
Normally valid for 5 years, the IOPP certificate is one of the documents
required to be in order before the vessel will be allowed to leave port.
(Invergordon / Rotterdam etc.)
7) (b) IMO- (IOPP) Validity, Annual, Intermediate and Renewal Surveys.
The IOPP certificate is valid for 5 years subject to satisfactory annual surveys.
Inspections and surveys are required to ensure that the vessel operates and is
maintaining oily waste and other waste disposal procedures, which it has implemented
to comply with international requirements.
For example, the Classification Society surveyor looks at:
Arrangements for the collection of oily waste, pumping facilities, sump
or tank capacities or tank capacities and connections.
Gauging and measurement of stored wastes.
System for back loading bulk or drums
International shore connections placement and condition, use of, (sizes
to be standard)
Oil Record Book, approved type, proper and current entries
Security against accidental discharge system operations, alarms,
procedures.
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Machinery bilges, bilge-pumping arrangements. (Thrusters being
machinery spaces are included - therefore procedures to avoid overboard
discharge).
Marpol also addresses other waste products such as plastics, general
garbage, and food wastes. Suitable arrangements for their proper
disposal are part of the requirement. (Wire rope - paint tins - scrap steel
to be included)
Annual inspection due 3 months either side of anniversary month.
An intermediate survey takes place within a twelve (12) month period, beginning
two (2) years after the commencement of the five (5) year cycle. The intermediate
will replace the annual survey where dates coincide.
The surveyor will endorse the reverse side of the full term certificate on satisfactory
survey. If outstanding requirements or corrective actions are issued then a
Conditional certificate will temporarily take the place of the full term Certificate. The
conditional will state the time limit for taking corrective actions. As in the MODU
code Certificate, this is normally 3 months depending on the type of deficiency.
Complete the deficiencies within the time limit ensure that the full term IOPP
Certificate return in good order. (The rig does not meet its international trading
compliance without a valid certificate).
Carry out the renewal survey at the end of the five-year period, when the certificate
needs to be renewed. It replaces the annual survey, and must be completed by the end
of the five-year cycle. Pending issuance of a full term certificate a five-month interim
certificate replaces temporarily the full term certificate.
The interim indicates satisfactory survey and allows lead-time for the
new full term certificate to arrive.
The Flag Government submits an Oil Record Book. Regulation 20 specifies the
records for entry in the Oil Record Book for discharge and movement of oil. It
includes accidental discharge or exceptional discharge. Always maintain accurate
records for discharge and move of oil.
Whenever an accident or a defect occurs, which substantially affects the integrity of
the MODU or the efficiency of the equipment covered under Annex I, the OIM and/or
owner shall report to the Flag Government or Classification Society the details of the
incident. The Flag Government or Classification Society will decide to inspect the
MODU and determine what action is required to maintain a valid certificate.
Immediate report any accidental discharge of a pollution substance to the Flag
Government and the local authorities.
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8 (a) Minimum Safe Manning Certificate (MSMC)
The Flag Government issues the Minimum Safe Manning Certificate for each rig
upon application by Transocean SedcoForex. The certificate is indefinitely and only
changes if the classification of the rig changes.
The MSMC should be clearly posted in the marine control room of the MODU
Always maintain the manning levels in accordance with the MSMC. The
Classification Society will verify the manning level on behalf of the Flag Government
during safety inspections. A Flag Government official may visit the MODU
unexpected to verify the proper manning level.
Fig. 4.9. Example of Minimum Manning Certificate
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4.3 CLASS CERTIFICATES
1 (a) Certification of Classification (Hull and Machinery) (Fig. 4.10)
Each Classification Society developed independent guidelines with standards and
rules for the design and construction of ships, MODU’s and structures.
The ‘Certificate of Classification’ often referred to as the ‘Main Class’ Certificate is
issued by the Class Society, i.e.: ABS, DNV under whose rules the vessel has been
built. The hull and machinery of a MODU built under these rules and regulations of a
Classification Society receive at the completion of the building project Certification
of Classification for two sections:
Certification of Classification for Hull.
Certification of Classification for Machinery
Both certificates are valid for 5 years subject to annual and special periodic surveys.
The Certificate shows that the rig has been designed and constructed to internationally
recognized standards, and is maintained and /or repaired according to her Class in the
rules.
IMPORTANT:
As of 1st
January 1996, the VALIDITY of the Class Certificate is subject to
COMPLETION of the Annual and Special surveys, i.e. ALL recommendations are to
be satisfactorily dealt, within the annual survey period. This may only carry over the
5th year ‘due date’ (such as when the rig is in major shipyard). However they must be
done and credited before a new Certificate of Classification is issued. The new
Certificate of Classification always back dates from the initial expiring date. The rig
cannot operate without an in date certificate and the above overrun only applies when
the rig is not operating i.e. completing its shipyard or similar.
It is very important to be pro-active before, during and after the surveys are carried
out.
E.g.
Before: -
To ensure proper work scope and that the survey items will be
available. Also ensure to have the proper rig people available to the
surveyor.
During: -
To ensure no misunderstandings arise, to ensure a full understanding of
the expected a corrective action. To minimize the amount of
outstanding recommendations that arise due to none correction or non-
explanation at survey time.
After:-
As it involves the validity of the certificate, it is most important to
ensure to close outstanding issues out properly in an agreed time.
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Recall that if a ‘Class’ certificate falls invalid then the flag certificates, which place
reliance on class conformity, will also become invalid. (See MODU Code) .
NOTE:
There is no 3 month window ‘after’ the due date for the 5th
year and that ALL
outstanding items have to be addressed before a NEW 5yr Certificate will be issued.
To classify the units symbols are uses
E.g. for an American Bureau of Shipping (ABS) classed rig.
A1 M PAS Column Stabilized Drilling unit.
Means that Class Surveyor(s) attended the unit during the build period and that
the rig without the symbol will not have been ‘under class attendance’ at build. Such
rigs will have been qualified for the class certificate by special survey
arrangements on a case-by-case basis.
A Means that the unit is accepted into class as fully satisfying the rule
requirements for such a vessel.
1 Means, unrestricted ocean service. (Regarding the hull construction and the
station keeping provisions). Some limitations may exist due to particular
issues e.g. capability to operate in ice areas.
M Means that the Mooring system is to the ‘owners’ specification and that ABS
have attended the testing. The ‘M’ symbol is not a requirement of class, it is
an owners request for class to include it. Inspection and inventory are subject
to owners choices with inventory and records subject to audit by ABS.
PAS Means:Thruster machinery for propulsion assist complies with the ABS rules.
Again the maltese cross signifies that the thrusters or machinery were
manufactuured, installed and tested to ABS satisfaction.
As can be seen it is important to understand the class ‘notations’ to know what is
required and to know what is inside (or outside) the remit of survey. Check your
notations and investigate what they concern. The Class Surveyor will usually be able
to explain - he must be able to provide the rule references when asked.
1 (b) Classification Certificates Surveys
ANNUAL
CONTINUOUS
INTERMEDIATE
SPECIAL PERIODIC SURVEY REPORTS.
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Fig.4.10 Example of the Classification Certificate
1) Annual Hull Survey
The survey concentrates focuses on the soundness and integrity of the structure.
On JU’s
The cantilever area and surrounding support of the drilling structure.
Major openings in hull and structure. Critical joints and bracings. With
the unit in elevated position, the underwater part should be credited to
the underwater hull survey. The jack house and jacking system. Legs as
far as possible.
Column Stabilised Units.
Depending on the draft the outside connections of the vertical columns
to the upper and lower hull, diagonals, girders, trusses and in general the
high stress points of the construction. Internal structure parts and all
items essential for the seaworthiness of the unit.
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The Annual Survey period is three (3) months either side of the
anniversary date, i.e. If the date is June then the Annual Survey is due
between April and September (referred to as the Survey Window).
However this does not apply to the Annual Survey coinciding with the
end of the five (5) year cycle, which must be completed by the end of
that cycle.
2) Annual Machinery Survey.
The inspection program follows the instructions in accordance with the
Classification rules for building vessels and/or MODU’s.
For self-propelled units the inspection program is more extensive than
for JU’s and non self propelled units. For all units it includes auxiliary
machinery, pumps, piping, electrical systems and safety devices
3) Special Periodic Survey for Hull and Machinery
Most rigs are under the Continuous Survey System. Each year the
survey follows a program to credit 20 % of the total required survey
items. At the end of a five year period, a final survey completes the
cycle and the Classification Society issues the new hull and machinery
certificate for another 5 year period.
A rig not on a continuous cycle must be completed within the 4th
and 5th
Years of the cycle. Any previous inspection results i.e. before the 4th
year cannot be credited and everything must be completed before the
end of the 5th
yr.
The Special Periodic Survey is a very extensive inspection. It goes
beyond the purpose of this course to discus the items of the Special
Periodic Survey in detail. All departments on board are involved.
Structure, machinery, electrical systems, tanks, and cofferdams,
foundations of heavy equipment, the mooring system, the ballast system,
sea chests, racking systems, safety equipment, fire fighting equipment
electric motors, alarm system and many others undergo thorough
inspections and tests.
Done in combination with the UWILDD, a good-, and well timed
planning and co-ordination of projects is most important. Do not
underestimate the tasks. It is advisable to assign a project co-ordinator,
who will be responsible to prepare the project and to follow up on a day-
to-day schedule with all parties.
It is normal to do as much accessible items while the rig is working to
minimize the time spent ‘off line’ at the Inshore or Shipyard visit. The
inshore visit will ‘catch’ all the underwater exterior parts, which are
normally submerged. Items inaccessible (such as Sea Inlet Valves) are a
typical example.
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The tail shaft inspection is part of the vessel shaped units. The
inspection applies to self-propelled units and involves pulling the shaft
or removing the thruster shafts for visual inspection, magna-flux, and
inspection of the bearings. This is normally done in dry dock For the
MODU’s in floating condition, the Classification Society will provide a
procedure for each specific case, depending on the type of installation
and method of inspection. The divers inspect the thrusters in accordance
with an approved program. Transocean SedcoForex developed a method
to pull the tail shaft in floating condition for the Sedco 703. For the
removal of thrusters a special lifting system enables to inspect the
thrusters above the pontoons
4) The intermediate or mid term surveys
The ’intermediate’ or ‘mid term’ (ABS – DNV). This structural
survey is also associated with rule requirements for the Dry-docking or
equivalent Survey. This concern the rule requirements to inspect the
underwater parts, normally done during submerged during operation.
The Intermediate is often satisfied by a proper survey using a Remote
Operated Vehicle (ROV). If not, this means that the rig needs not stop
operating to come inshore or to dry-dock. The 5th
year is coincident with
other structural inspection and refurbish. Normally divers are employed
at the 5th
year.
The Major or Special Periodic Survey This structural survey also requires
inspection of the underwater parts normally submerged during operation. Such as.
hull and braces. Close out at the 5th
year should coincide with an Underwater Survey
in Lieu of Dry Docking (UWILDD).
1) (c) Dry Docking or Underwater Survey in Lieu of Dry Docking (UWILDD)
The hull survey schedule demands for two dry dock surveys in a 5 year cycle. The
intermediate dry dock survey can take place within six month of the 2 ½ year period.
However, the second one has to take place before the end of the 5 year cycle.
In general, it is not a problem to find a dry dock to facilitate a Drilling Vessel. Due to
the size and configuration, a dry dock for a Semi Submersible may not be available at
all or the location is too far away to be practicable.
To obtain the same information as required for a dry dock, the Classification Society
provided for approved procedures to evaluate the condition of underwater part of the
hull with a survey by divers. For example, ABS submitted a publication “Guide for
Underwater Inspection in Lieu of Dry Dock Survey”. Normally the UWILDD takes
place in sheltered waters at light draft. To safe time and cost carry out the UWILDD
together with the Special Periodic Survey.
The owner will normally employ an underwater diving company which will have the
approval of the Class Society, to visually inspect, photograph and film selected weld
areas, anodes, thrusters, sea chests, inlet valves and any other area agreed between the
vessel and the Class Society.
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Provide the diving company with detailed instructions and drawings. Include cleaning
procedures, selected areas for weld inspection and video/photograph requirements,
anode inspection, corrosion checks, damage reporting, sea chests and inlet valve
inspections and any other special requirements. Confirm and agree with the surveyor
on the procedure.
For a unit on a continuous survey, spread the UWILDD items for hull classification
over two surveys.
Drilling Vessels
Use normal dry dock facilities
Jack Up’ s
Carry out the UWILDD survey with the hull clear of the water. Examine
the leg chords, diagonals, bracing etc during the jack up operations. The
hull inspection is easy with the hull above water. Divers perform the
inspection of the spud cans and associated connections.
Semi Submersibles.
The important areas are the column to hull connections, diagonals,
girders and trusses and highly stressed areas, hull and thrusters, sea
chests and strainers, fair leaders, anchor racks connection to the hull.
Dry-docking is only relevant if the vessel is in dry-docking for a major refit or life
enhancement work.
As above if dry-docked the same inspection items arise. I.e. Sea Inlet valves, hull
welds, hull condition.
1) (d) Anchor Chain Inspection
As a component part of a mooring system, anchor chain inspection is required by
class and on occasions by a coastal state - depending on the unit’s area of operations.
However, the extent of the requirements can vary, i.e. DNV quotes API RP2I in their
rules whereas others do not. The inspection ensures that the anchor chain condition is
in accordance with acceptable standard.
Owners inspection criteria takes into consideration the chain ‘age’ and ‘Service life’
which he computes with present chain ‘conditions’ (conditions reported from rig
moves are important). In addition, a unit’s area of operation, loading and tensioning
since the last inspection and mooring analysis are also into accounted for.
The Class Society surveyor carries out the inspection at the intermediate and at the
five-year interval. It is part of the Special Periodic, Major, and continuous survey
completions.
Reference should be made to the Class Certificate ‘Notations’ and the Class rules
when discussing the survey ‘scope’ with Class. The owner’s requirements are
generally in line but may be ‘less’. Less may be acceptable depending on the class
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notation. The ultimate target is to always know the health of the mooring system
before carrying on.
Harmonise the anchor chain inspection to satisfy all three above mentioned
certification authorities at the same time. Normally the chain inspection takes place in
conjunction with the UWILDD
The section Mooring explains the various procedures to inspect the mooring chain or
wire.
1) (e) Structural Surveys
The Class Society (ABS, DNV) conducts its structural inspection program via
Annual, Intermediate and Major / Special Periodic Surveys. They will credit the
satisfactory completion of survey items to the Certificate of Classification.
For units on a continuous survey cycle the aim is to complete approximately 20% of
the survey items each year. However, this 20% is flexible and depends on the on
operational commitments.
Annual:
Visual examination above the waterline, with internal inspection of
critical areas, as considered necessary.
Intermediate:
Annual scope plus a UWILDD
Major / Special Periodic Survey:
Carried out at the end of the five-year cycle. This survey is more
extensive than an annual i.e. with external/internal inspection combined
with UWILDD. The best procedure is to perform this survey in sheltered
waters with the rig at shallow draft.
The Major/SPS survey to recapitulate on continuous items (such as hull
tanks) and to get finished up with as much survey items credited as
possible.
The Class STATUS is the best place to see the due dates for the various
equipment and associated surveys such as the UWILDD.
Enhanced visual and Non Destructive Examination (NDE) of critical
areas combined with a UWILDD and thickness gauging of selected
areas of hull structure is required at the Major / Special Periodic Survey.
This survey may be commenced on LOCation, and completed in
sheltered waters with the rig at shallow draft.
NOTE:
Skin valves such as the sea inlets require examination internally at the 5th
year. This
requires divers to blank off the inlets. The requirement can be split i.e. do port side at
intermediate survey and complete with starboard side at the major survey. (However,
the valve ‘due dates’ will then also be split. So preferable do all at the 5th
year)
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NOTE:
Where units have satisfactorily completed a life enhancement program, the structural
inspection program will be modified accordingly, taking this into consideration.
Owners requirements:
The owners requirements for NDE and inspection may well be over and
above the requirements of class. A typical example is the TYPE 4
inspection done on 700 series rigs. This inspection requires much NDT
of external weld connections (Usually Magnetic Particle Examination).
Where a type 4 applies to a rig the rig should contact the field support
group for advice well before the Major/SPS survey is due (as the
owner’s requirements normally take place at the same time).
1) (f) Class Status Report. (Fig. 4.11)
The Class Status report provides for a overview of the history and future of the
Classification and associated certificates.
Fig 4.11. The first page of the Class Stratus Report
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1) (g) Annual Survey – PMS (Preventive Maintenance System) (Fig. 4.12)
Regular inspection and reviews of the PMS records ensure that the maintenance and
condition checking of equipment complies with recognized standards as well as Class
Society requirements (ABS, DNV).
Being ‘approved’ the ‘PM system’ itself comes under survey. Satisfactory ‘PM
system’ survey will require that the PM procedures and records pass audit. If the PMS
records are of an acceptable level and quality the surveyor should require no more
than a general examination plus a satisfactory demonstration of safety devices and
alarms.
An annual review of the PMS records, by the surveyor, is carried out at
the same time as an annual survey for class. Satisfactory completion and
crediting of this review negates any need to submit and ‘annual PMS
report’ to class headquarters (i.e. ABS),
The surveyor will issue a report on the PM system (No Certificate is
issued other than the initial ‘PM system Approval’ Letter. Note that the
approval is subject to satisfactory annual survey.
NOTE ON DNV:
Chief Engineers as appointed by the owner and as approved by the class society
(particular to DNV) may work within the PM system to approve items for credit over
the period. For example such as when equipment is opened for service or repair, an
‘Approved Chief Engineer’ can credit this to the Class continuous survey.
Fig. 4.12. Example of a Planned Maintenance System Approval
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4.4 COASTAL STATE ORGANISATION AND
CERTIFICATES.
To operate within the Continental Shelf of a country the owner of the unit has the
legal obligation to comply with laid down rules and regulations.
The requirements of coastal state legislation can be very complex and change very
rapidly. Region specific policies and procedures must contain the process to follow to
ensure compliance with the Coastal State Legislation applicable to the Region.
The formalities to obtain the permit to enter the Continental Shelf and start operations
differentiate greatly from one country to another. One can say that in European
countries, the US and Canada a more complex administration and control system is in
place than in other parts of the world.
The Rig Manager and nominee must be familiar with the requirements for the specific
area of operation. The Rig Manager together with the OIM are responsible to ensure
that the maintenance and operations procedures of the installation are at all times in
accordance with the applicable legislation.
Coastal states have, to a greater or lesser extent, accepted international maritime
certificates (SOLAS; MODU Code, ILLC, MARPOL, etc.) issued by or on behalf of
recognised maritime administrations. In addition, coastal states have to varying
degrees delegated authority to act or issue documents on their behalf to certain
classification societies or other agencies. The extent of acceptance and authorisation
must be clarified with the coastal state. Where there exists acceptance of the maritime
certificates and/or Classification Society by the coastal state, surveys and certificates
required to comply with the requirements of the coastal state legislation should, as far
as possible, be conducted simultaneously with the maritime certificates and/or
Classification Society surveys.
The following summarises the technical provisions of the main coastal states.
This good information comes from by the Aberdeen Certification Department.
4.4.1 CANADA
The Canadian certification regime is split on two levels. There are national
requirements and provincial requirements.
On a national level, a Letter of Compliance (LOC), to confirm compliance with the
IMO MODU Code and MODU standards, must be obtained from SSB. This LOC has
validity for one year and is subject to renewal following satisfactory survey by the
SSB. In principle, the LOC is not required to be maintained whilst the installation is
operating outside Canadian controlled waters.
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The various provinces have their own additional requirements. Newfoundland
(including Labrador) requires a Certificate of Fitness (COF) to be issued by the
Certifying Authority (normally the Classification Society) against specific
operational, technical, and working environment requirements including inspection,
maintenance, and weight control. Nova Scotia has a similar requirement with slightly
differing provisions. These COF are normally valid for five years, but will have an
expiration dated marked on them, and are subject to periodic survey by the CA. In
principle these certificates should be maintained whilst outside the controlled waters,
otherwise the installation will be required to comply with the more stringent
requirements of a new installation when re-entering controlled waters.
4.4.2 DENMARK
The technical and operational requirements for operating in Danish controlled waters
are given in “Administration of Hydrocarbon Licenses – Mobile Offshore
Installations”, administered by the Danish Energy Agency (Energi Styrelsen).
Before an installation is allowed to operate in Danish controlled waters, a “Permit for
Operation” is required. This permit is granted by the Danish Energy Agency in co-
operation with the Danish Maritime Authority (Søfartsstyrelsen). The permit has
validity for maximum five years, subject to surveys and inspections by the relevant
agencies and authorities. When the installation is taken out of Danish controlled
waters, a new application is required on re-entering controlled waters and the
installation will be considered as a new installation entering Danish controlled waters
for the first time. Other authorities must approve certain parts of the installation, for
example the helideck, separately. For the helideck application must be made to the
Civil Aviation Administration, Denmark, and Department of Safety Regulation who
will issue an “Approval of helideck” based on the relevant sections of the civil
aviation regulations.
4.4.3 NETHERLANDS
The Dutch Mining Authority (Staatsoezicht op de Mijnen – SODM) has the
jurisdiction over offshore drilling activities in Dutch controlled waters. The
requirements of the relevant legislation have been subject to change over recent years
and case-by-case clarification should be sought.
4.4.4 NORWAY
The compliance system in Norway is currently being restructured and will
involve a process called “ACKNOWLEDGEMENT OF COMPLIANCE”
(AOC).
Future revisions of this manual will reflect progress of implementation.
The requirements for operating in Norwegian controlled waters are given in the
publication “Acts, regulations and provisions for the petroleum activities”
(“Regelverkssamling for petroleumvirksomheten”), published in two binders and
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administered by the Norwegian Petroleum Directorate (Oljedirektoratet). The
published requirements contain the laws, the acts of parliament, the regulations to be
complied with, and the authorised guidance to the regulations. The publication is
updated annually to incorporate new or revised regulations and guidance.
The Operator is defined as “the licensee” and has the responsibility to ensure
compliance against the requirements. However, the Company must be able to
demonstrate and document compliance to the Operator. Further, the company has
responsibilities as a “main contractor” under the terms of the regulations and must be
able to demonstrate control of the activities over which it has influence against the
requirements.
The Norwegian regulations, in theory, accept that, for mobile drilling units, existing
documentation, including maritime certificates issued by Norwegian or foreign Flag
State authorities, may be used as basis for documentation of compliance with the
requirements stipulated in the regulations. In practice the installation owner has had to
be able to document compliance against the requirements of the NMD from 1986
onwards or the 1989 MODU Code. This provision is particularly important for
aspects covered by the regulations that are too onerous or inappropriate for the design
and operation of drilling installations (e.g. structural requirements). There are two
main ways of demonstrating this base line compliance:
1. NMD LOC against NMD requirements for a Norwegian flag installation, and;
2. “Statement of Compliance” from the CS against the 1989 MODU Code and
NPD regulations.
Under the first option, the installation is subject to the approval process, scope, and
frequencies of inspections as if the installation were to have Norwegian flag. The
LOC is issued in place of the COF with all other certificates being accepted as issued
by the Flag States representatives. The NMD do not assess the installation
additionally against the specific requirements of the NPD regulations.
Under the second option, the Classification Society is making a formal statement on
the compliance status of the installation against the requirements of the NPD using the
class and flag compliance status as a base line.
It should be noted that neither of these options relieves the Company of the
responsibility for ensuring compliance against the requirements of the NPD.
When evaluating the relative advantages and disadvantages of these two options
consideration should be taken of factors such as; cost, contractual obligations, current
Classification Society and Flag Administration, current certificate status, future
employment prospects, authority focus, etc.
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In addition, the installation must comply with the working environment laws, which
require annual inspection by local health authorities and medical authorities. The
lifting appliances, including all loose gear must be subject to annual testing and
inspection by a “competent person” authorised by the NMD. The helideck and
equipment is subject to review by the Civil Aviation Authority and initial and periodic
inspection by the helicopter operator.
The NPD have become very active in following up Operators (Clients). This follow-
up has been carried out by way of inspections and audits on installations and audits of
the Operator, and the Company’s, management systems. On installations where no
COF or LOC has been issued by the NMD, the NPD will invite the NMD to act as
their marine executive agency in the performance of onboard technical inspections.
These inspections tend to focus on stability, subdivision, watertight / weather tight
integrity, ballasting, and station keeping. Once the Rig Manager has received
notification that the NPD, with their appointed executive agencies, intend to perform a
direct inspection / audit the Rig Manager must ensure that the installation is prepared
and made available for the inspections / audit.
The Rig Manager and OIM are responsible for ensuring that the installation is
annually reviewed against the requirements of the latest edition of the NPD
regulations and guidance. Non-conformances against the regulations must be properly
registered and documented. The documentation must include the technical or
operational measures taken to provide for a comparable level of safety given by the
regulation. The documentation must also include the plan for bringing the installation
in conformance with the regulation, if applicable. In connection with the annual
review of the installation against the latest regulations, the non-conformance list must
also be reviewed to determine if there are factors that may change the status of
existing non-conformances. This should be seen as a holistic approach whereby the
existing non-conformance listing and the regulations are reviewed in interaction with
one another to identify if there exists a compounding effect of one or more non-
conformances in association with the regulation being considered. A sample of the
evaluation form, non-conformance log and non-conformance tracking forms that may
be utilised to assist in this process are included at the end of this section. These forms
are particularly useful in evaluating compliance and its installation, which frequently
work between UK and Norwegian sectors.
4.4.5 UNITED KINGDOM
Authority for offshore safety in UK controlled waters has been delegated to the Health
Safety Executive (HSE). The directive of the HSE has been to take the UK Health and
Safety at Work Act and implement it offshore by way of introducing a suite of general
industry and specific offshore regulations.
This legislation, introduced under the umbrella of the Health and Safety at Work Act,
centres around the Safety Case Regulations which in turn are supported by additional
regulations concerning the management, control of emergencies, operation, design
and construction of offshore installations.
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Further to this main legislation there are a number of additional regulations
concerning: reporting of dangerous occurrences; suitability of equipment; safety,
health, and welfare; monitoring and control of noise; monitoring and control of
electricity; lifting equipment and lifting operations. In addition, helicopter operations
and helidecks are subject to review by the agencies acting on behalf of the Civil
Aviation Authority.
In the context of this legislation, the Company is defined as “The Duty Holder” and
holds the responsibility for the provision of a safe place of work and for
demonstrating compliance with the legislation.
The legislation demands that the Duty Holder demonstrates discharging of this
responsibility by presenting an accepted case for safety (Safety Case) and ensuring
that the procedures and arrangements set out in the document are followed. The
acceptance of the Safety Case may not be construed as indicating compliance with the
other statutory requirements mentioned above.
Two particular requirements of the supporting legislation are the need for a
Verification Scheme and a Written Scheme of Examination. The Verification Scheme
demonstrates functionality, survivability and availability of those items of equipment
or systems deemed to be safety critical (“Safety Critical Elements”). The Written
Scheme of Examination demonstrates that all plant associated with the protection of
personnel from fire and explosion, and for securing effective emergency response, is
maintained and available.
The Company has elected, due to the similarity of requirements, to combine the
Verification Scheme and the Written Scheme of Examination into one installation
specific document. The regulations require that this document is drawn up in
consultation with an Independent Competent Person known as the ICP, (e.g. CS) and
that it is subject to verification (including testing and examination where appropriate)
throughout the life cycle of the installation. The Company planned preventative
maintenance system is used as demonstration of the continued performance
(Performance Assurance) of Safety Critical Elements and plant associated with the
protection of personnel from fire and explosion, and for securing effective emergency
response by recording maintenance, inspection and testing carried out. The
regulations allow for work carried out to meet other requirements (i.e. Flag State and
Classification Society) to be credited towards the verification process.
The Safety Case is subject to continuous review and must be resubmitted for
acceptance by HSE at least every three years. Any major modification, significant
event or any changes that may affect the Safety Case require review and re-submittal
of the Safety Case.
The Rig Manager is responsible for ensuring that the Safety Case, Verification
Scheme, and Written Scheme of Examination are implemented and subject to review
and re-submittal as required. Technical Field Support and QHS&E Departments will
support the Rig Manager in discharging this responsibility.