Training of MOUs personnel (including MODU’s personnel) STCW and IMO Resol A 1079

Origin of IMO resolution For the « small » history, within the extraordinary development of the OFFSHORE INDUSTRY, the intention of the IMO was initially to develop a convention of training and certification for our personnel (STCW-OFFSHORE). The profession pled that an obligatory training and certification would be difficult to apply since it must, by contract, to employ local personnel… which has the characteristic to be very "volatile".

Origin  In replacement it was studied a resolution which, if it is not obligatory strictly speaking, nevertheless is strongly recommended and made mandatory by many flags ( U.K., LIBERIA, Bahamas,NEDERLANDS etc….).  Issued in 1999, the first recommendations (Resol A 891) for training of Personnel on MOUs have been applied for almost 15 years  Today a new resolution (A 1079) has been issued in 2014 and have added some recommendations for security awareness and certification

Something new compare to A 891  New definitions for: Certificate of competence (COC) and certificate of proficiency (COP) for offshore personnel in conformity with this new Resolution  ISPS code as it is and associated assignment as SSO and CSO  A new personage appears the PIC (person in charge) which clarify the position in charge on board between the OIM and the Master

Some important definitions  Company is the entity responsible for the operations of the MOU and so has agreed to take over all the duties and responsibilities imposed by the present recommendations  They are only recommendations; but the client can impose it in your contract

Definition for UNITs  MOU (Mobile Offshore Unit) means a vessel able to perform offshore operations other than carried out by normal vessels  The MODU is one of them specialized in drilling

Same categories of personnel  Category A: visitors & special personnel staying no more than 3 days on board the MOU  Category B: Special Personnel without responsibilities for safety, security and survival of others  Category C: Regularly assigned special personnel with responsibilities to safety, security and survival of others  Category D: maritime crew (includes OIM, BS, MS, BCO, deck & engine officers, radio operator and seafarers ratings)

Crew: Still two main categories  Maritime crew (offshore personnel category D) who has to conform to STCW convention  Offshore personnel (categories A, B and C) who has to conform with the present resolution

Category A  Visitors or personnel staying no more than 3 days on board the MODU  Needing an induction training on arrival on the MODU and renewed when necessary (company decision)

Induction meeting  Generally carried out at the desembarking from the helicopter in a specific room: Consists of a video demonstration and visit on site  The Safey Officer is in charge and ensure issuance of COP, recording and revalidation (5 years) -Warning: this training familiarization course is now often requiring an approval from the Flag

Familiarisation training and instruction  For personnel BCD working on board the MOU should receive offshore orientation & safety familiarization training & instruction including security renewed every 5 years  Can be carried out ashore with particularities of the MOU  COP is issued

Security awareness training  All personnel (B, C, D) every five years must receive security awareness training STCW VI/6-1 (ISPS code).A COP is provided;

In addition for regularly personnel BCD  Personnel without responsibilities in safety of others, should receive should receive specific training in survival, firefighting, first aid, personal safety and social responsibility and security awareness, use of drills etc… this is similar to the BST of STCW for all seafarers  This traininig is provided preferably ashore or on board and personnel should hold a COP or equivalent

Standard of proficiency  Despite the corresponding content in STCW BST  Resolution 1079 present the contents of all these minimum standard of proficiency for the MODU’s personnel in tables with methods for evaluating competencies

Personnel with assigned duties on the muster list  This personnel (C &D) should hold generally STCW (VI/2, VI/4 & VI/6-2) or COP corresponding certificates valid 5 years max  NB all these training are similar to those of STCW from BST and specific trainings  + HLO training and dynamic positionning for DPO (see our extra presentation P3 IMCA)

KEY PERSONNEL  Depending of the specilization of the MOU, key personnel may need specialized training decided by the flag  For personnel holding STCW certificates, a specific list of additional training is recommended :

KEY PERSONNEL what is it ?  OIM OFFSHORE INSTALLATION MANAGER : person appointed to be in charge of offshore operations  BS Barge supervisor: giving support to the OIM for marine matters can be the barge master  MS Maintenance supervisor : responsible for operation and maintenance of all machinery and equipment ‘chief engineer

Other key personnel  BCO Ballast Control Operator on column stabilized MOU  PIC Person in Charge responsible in an emergency (NB typical in the Offshore industry) can be the Master or the OIM  Tendency today is to nominate only the Master as the PIC

The PIC: Master or OIM ?  In fact there are two things which are not compatible with ISM code: The Master has the overall responsibility for safety and security  The code does not expect to have an OIM responsible of the MODU when all operations are going well and a MASTER responsible when rhere is an emergency … Crazy situation which have been highlighted as one of the cause of DWH diasater

Training of key personnel of MOU  The resolution define the training necessary for key personnel over two conditions: holding a suitable STCW officer certificate or not  This is quite logic  STCW officers must know the offshore operation part  Offshore key personnel must know the marine officer part

Example of training required for OIM of Offshore origin  Construction and stability of a floating unit  Marine regulations in case of transit-Meteorology  Mooring/DP: station keeping, anchor recovery  Emergencies/safety and security of the MOU: crisis management/crowd control  Dangerous goods and safe working practices  Handle of transfers or loading of equipment

For BS or BCO  Stability is an important academic knowledge for them also especially for the ballast operator (remember the P 36 accident in 2001)  From my experience as a consultant for ISM implementation and stability teacher: I realised the important gap between offshore personnel and marine personnel in matter of stability even of a ship)

For personnel with STCW certificates  For the different functions as:  OIM, a Master or chief mate must follow a specific training course on well contraol and MOU specific stability  For BS or BCO the same officers must complete a MOU stability course  All training courses to be approved by the flag administration

More information in the Resolution A 1079 Fitness for duty Guidance on drills and exercises

FITNESS for DUTY  Flag Administration must take the following into account before issuing The MODU or MOU certificate:  Competence of watch keepers and medical standard  Prevention of drug and alcohol abuse  Management of rest hours (10hrs a day) and prevention of fatigue

Drills & exercises  The resolution includes a very interesting chapter on drills and exercises on board offshore MOUs  NB these guidance could be used, when adapted, on all ships  A programme of drills & exercises following this guidance should be included in the preparation system to respond to emergencies (ISM§ 8)

Planning of drills The programme must include:  Realistic drills as much as possible  Routine drills  Periodicity covering all possible emergencies  Recording of activities and follow up  Periodical assessment of individual competence

IN conclusion The OFFSHORE INDUSTRY has evolved very much in the past years and uses today mobile floating units of various types: Drilling ships, semi (platforms), self propelled barges with dynamic positioning and being able to move by themselves from a work place to another one but also on long distances.

MODU are treated differently in maritime regulation ISM & ISPS  For construction and operations you have the MODU code (79 or 89 and today 2009)  MODUs are included in ISM and ISPS codes; But not the MOUs!  It is common to-day to see the self-Propelled MOUs are following the MODU code and ISM/ISPS codes!

SITUATION TO-DAY STCW convention applies. From the point of view of maritime crew’s mandatory certificates these units are regarded as ships and thus, the STCW convention applies. a complementary offshore specialization These units are thus manned with a STCW 95 maritime crew which acquired a complementary offshore specialization in specialized centers like ABERDEEN or ROTTERDAM or LESCAR in FRANCE

STCW 2010 have a small § on MOUs  In the part B- V/d and it is very clear: Difference is specified between non self-propelled and MOUs on station or on voyages  MOUs on station are subjected to the national legislation of the coastal state in whose Exclusive Econiomic Zone (EEZ) they are operating Such coastal states should also take account of relevant IMO recommendations and should not prescribe higher standards for MOUs registerd in other countries

STCW 2010  Give also some recommendations on knowledge of crews on anchor-handling supply vessels operations  And on personnel operating Dynamic positionning systems

FPSOs and FSUs  These units have a flag so Flag States and Coastal states should cooperate with a view to ensuring the compliance of FPSOs/FSUs with applicable international standards on maritime safety, marine environment protection, enforcement and control measures such as surveys and certification, maritime search and rescue, casualty investigation and emergency response

Sovereign rights of coastal state  The rights of the safety regime for FPSOs and FSUs  Are on non-disconettable units which are designated to be permanently moored as without mechanical means to move under their own propulsion  On also disconnectable self or non self propelled units when operationg on sites

Principle of application  While compliance on all IMO standards and industry guidelines contributes to safety, pragmatic approach should be used when these units on location or not.  On location SOLAS, STCW do not apply when MARPOL Annex 1 apply so it is recommended that an approved safety management system as required by the ISM code should apply  Off location, a self-propelled FPSO or FSU will have to comply to SOLAS, and the ISM code apply again in addition of MARPOL

So finally  While the ISPS code has been considered necessary for FPSO and FSU as well as an emergency response system on board  The solution is in applying ISM, ISPS codes and appropriate corresponding guidelines