Transocean offshore operation 3

OFFSHORE OPERATIONS COURSE SECTION 3. CERTIFICATION AND INSPECTION

Training to be FIRST

1

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 AFFEC TIING 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

OFFSHORE OPERATIONS COURSE SECTION 3. CERTIFICATION AND INSPECTION CHAPTER ! INTRODUCTION


2

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.

OFFSHORE OPERATIONS COURSE SECTION 3. CERTIFICATION AND INSPECTION CHAPTER 2 CERTIFICATION AUTHORITIES


3

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.



4

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)



5

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).



6

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.



7

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.



8

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



9

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.



10

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



11

Liberian Flag


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



12

Norwegian Flag


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



13

Panamanian Flag


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



14

USA Flag


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

OFFSHORE OPERATIONS COURSE SECTION 3. CERTIFICATION AND INSPECTION CHAPTER 3 SURVEYS-INSPECTIONS


15

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.



16

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



17

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.



18

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.

OFFSHORE OPERATIONS COURSE SECTION 3. CERTIFICATION AND INSPECTION CHAPTER 4 THE CERTIFICATES


19

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.



20

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



21

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.



22

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.



23

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.



24

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.



25

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.



26

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).



27

Fig.4.4 Examples of Radio Station License and Report on Radio Station Report



28

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.



29

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.



30

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.



31

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.



32

Fig. 4.6 Example of the IMO MODU Safety Certificate



33

Fig: 4.7 Example of attachment with Non-Conformances to the MODU Safety Certificate.



34

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



35

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.



36

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



37

Fig. 4.8 Example of International Oil Pollution Certificate



38

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.



39

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.



40

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



41

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.



42

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.



43

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.



44

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.



45

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.



46

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



47

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)



48

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



49

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



50

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.



51

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 COMPLI ANCE” (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



52

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.



53

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.



54

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.



55

4.4.6 UNITED STATES OF AMERICA The authority for US controlled waters is split between two agencies – United States Coast Guard (USCG) and Mineral Management Service (MMS). USCG covers the marine aspects (structure, stability, watertight / weather tight integrity, ballasting, pollution prevention, life saving appliances, fire protection, power generation / distribution, ventilation, hazardous areas, mooring, fire / gas detection, etc.) and the MMS covers the drilling and industrial aspects. Normally the Operator will deal exclusively with the MMS. The MMS will normally perform a survey of the drilling and well control equipment prior to the well being spudded to confirm that the conditions stated by the operator in application for the drilling permit have been met. The requirements of the USCG are presented in the published Code of Federal Regulations (CFR), with 46 CFR Subchapter I-A and 33 CFR Subchapter N being relevant when working on the US continental shelf. A US flagged installation is partly covered by the Certificate of Inspection. A foreign flagged installation requires inspection by the USCG every year, with issue of a LOC. The LOC covers similar aspects as the Certificate of Inspection. There are three methods of obtaining an LOC:

1. Full compliance with US standards, as per a US flagged installation.

2. The requirements of the Flag State being accepted as providing a level of technical and operational safety equivalent to or greater than the standards of a US flagged installation. Currently, only Panama has been accorded this status for new MODU's.

3. Full compliance with the IMO MODU Code and 46 CFR requirements not

covered by the MODU Code. This only applies to units designed and constructed to the IMO MODU Code, and issued an IMO MODU Code certificate.

It should be noted that installations with non-conformances against the MODU Code accepted by the Flag State would not have those non-conformances accepted by the USCG. Both ’79 and ’89 versions of the MODU Code are recognised. An installation must be in possession of a “Vessel Certificate of Financial Responsibility” against pollution. Contact should be made with Operational Services Houston or Houston Insurance Department.

Engineering

Transocean offshore operation 3