Vessel & Facility Operating Standards Division (CG-OES-2) DFO Report to NOSAC CDR Jose Perez Vessel & Facility Operating Standards Division (CG-OES-2) USCG Headquarters April 17, 2014

Goal Annual Update on Coast Guard disposition of NOSAC Final Reports: Bylaws Final Reports Issued; Report Recommendations; and Coast Guard actions The goal for this presentation is to provide you with a summary of the Committee’s recent Final Reports and what action the CG is taking with respect to the recommendations provided by the Committee. You will see several final report and recommendations listed that were discussed in previous updates. I have included them because the subject of the report is being considered at IMO, in Coast Guard rulemaking projects, or policy development and Agency actions with respect to them may not yet be final.

NOSAC Final Reports Carried Over from 2012 Update MARPOL Annex II, A.673 for OSVs (previously reported) - Final report (s) submitted November 16, 2007 and December 8, 2009 Use of Foreign Citizens in OCS Activities (previously reported) – Final report submitted November 5, 2009 Dynamic Positioning Operational and Installation Guidelines (previously reported) – Final report submitted February 9, 2011 Certification and Standards for Large OSVs (previously reported) – Final report submitted May 19, 2011 As you can see, the members of NOSAC as well as their industry counterparts have been very busy in the past five years. For this presentation, I will be focusing on NOSAC reports that have been completed.

NOSAC Final Reports New Since 2012 Update Evacuation & Medical Treatment of Injured Divers from OCS Facilities – Final Report submitted April 12, 2012 Mississippi Canyon Incident Reports Review – Final Report submitted November 8, 2012 Standards for DP Operating Personnel – Final Report submitted November 8, 2012 Coast Guard Implementation of ILO Maritime Labor Convention 2006 – Final report submitted June 25, 2013

NOSAC Final Reports New Since 2012 Update - Continued Accommodation service provided on vessels engaged in OCS activities – Final report submitted November 14, 2013 Electrical Equipment Certification in Hazardous Locations on FF MODUs – Final Report submitted November 14, 2013 Additional Lifesaving and Fire Fighting Requirements on the OCS – Final Report submitted November 14, 2013 Safety Impact of Liftboat Sea Service Limitations – Final Report submitted November 14, 2013 Review of Coast Guard Marine Casualty Reporting – Final Report submitted November 14, 2013

Review of IMO A.673 (16) and Recommendations Concerning OSV’s Final Report on SEP 29, 2010 Final Report Closed The Office of Operating and Environmental Standards (CG-OES) is head of US delegation to an IMO Pollution Prevention and Response (old BLG) working group considering chemical carriage on OSVs. Working group met in Feb 2014 and is in formative stage.  

Use of Foreign Citizens in Outer Continental Shelf Activities Final Report on 5 NOV 2009 Final Report Open Foreign and Offshore Vessels Division (CG-CVC-2) Revisit data and recommendations made in final report. Utilize in conjunction with “OSV and offshore worker purpose and definition” Task Statement issued today by Domestic Vessels Division (CG-CVC-1). On this issue, the CG asked NOSAC to establish a subcommittee to identify, review and assess the current criteria to determine the appropriate use of foreign workers on the Outer Continental Shelf. We further requested that NOSAC prepare a report to include recommendations on the following:  Criteria as to what constitutes a regular member of the crew of a unit engaged in OCS activities.  Identify criteria that would assist the U.S. Coast Guard in determining whether there is a shortage of available and qualified U.S. workers.  Recommend criteria as to which positions could be exempted on a unit based upon lack of availability.  Recommend a benchmark of what constitutes a particularly unusual circumstance; what constitutes an emergency, and what criteria should be met in order to receive head of line privileges.  Review existing Coast Guard policy documents and recommend changes to areas where significant change is needed.

Dynamic Positioning Reports Final Reports Open DP Operational and Installation Guidelines Final Report issued February 9, 2011 Standards for DP Operating Personnel Final Report issued November 8, 2012 DP Design and Engineering Standards Rulemaking project underway (Human Element and Ship Design Division (CG-ENG-1)) DP Personnel Training and Manning Rulemaking project underway (Marine Personnel Qualifications Division(CG-OES-1))  

Certification and Standards for Large OSVs Final Report on MAY 19, 2011 Final Report Open Human Element and Ship Design Division (CG-ENG-1) CG Authorization Act of 2010 OSVs over 6,000 GT (ITC) or 500 GT (Regulatory) rulemaking project currently underway. OMB - review of draft OSV rule   The Office of Management and Budget (OMB) has received for review the draft US Coast Guard interim final rule regarding Offshore Supply Vessels of at least 6000 GT ITC. The draft rule is intended to implement the 2010 statute removing the size limit on OSVs and to ensure the safe carriage of oil, hazardous substances, and individuals in addition to crew on these larger OSVs. OMB review generally takes four months, but can be longer.

Evacuation and Medical Treatment of Injured Divers Final Report on APR 12, 2012 Final Report Closed Office of Search and Rescue Policy (CG-SAR) Health, Safety & Work-Life Directorate (CG-11) Report forwarded to CG Flight Surgeons for transport consideration.

Mississippi Canyon Incident Reports Review Final Report on NOV 8, 2012 Final Report Open Assistant Commandant for Response Policy (CG-5R) and Assistant Commandant for Prevention Policy (CG-5P) Report serves as an authoritative resource for future policy development. Subchapter N update. Rulemaking project currently underway.

CG Implementation of ILO MLC 2006 Final Report on JUN 25, 2013 Final Report Closed Marine Personnel Qualifications Division (CG-OES-1) MLC 2006 Implemented AUG 20, 2013 NVIC 02-13, Guidelines for Implementing MLC 2006 Our Administration is internally deliberating on the possibility of U.S. ratification of the MLC. While these deliberations are taking place, it is not possible for me to directly comment on whether we will or will not ratify the convention. - However, I can state that we fully support the principals of the convention and believe that many of the requirements in the MLC are addressed within existing domestic legislation. - The U.S. decision on whether or not to ratify will depend on the interpretation of the scope of application of the Convention, and any additional measures that would require changes to regulations and/or practice. - Any possible move towards ratification will be made transparently with the U.S. maritime industry, to ensure any concerns raised are properly addressed.

Accommodation service provided on OCS vessels Final Report on NOV 14, 2013 Final Report Open Naval Architecture Division (CG-ENG-2) Report serves as an authoritative resource for future policy development. ASVs will be included in the future 33 CFR Subchapter N update. Rulemaking project currently underway.

Electrical Equipment Certification in Haz Locations Final Report on NOV 14, 2013 Final Report Open Systems Engineering Division (CG-ENG-3) Report serves as an authoritative resource for future policy development. Electrical equipment certification is included in a current rulemaking project applicable to MODUs, floating facilities, and vessels on the OCS.

Additional LS & FF Requirements on the OCS Final Report on NOV 14, 2013 Final Report Open Lifesaving and Fire Fighting Division (CG-ENG-4) Report serves as an authoritative resource for future policy development. Additional Lifesaving and Fire Fighting Requirements are included in a current rulemaking project applicable to MODUs, floating facilities, and vessels on the OCS.

Safety Impact of Liftboat Sea Service Limitations Final Report on NOV 14, 2013 Final Report Open Mariner Credentialing Program Policy Division (CG-CVC-4) Report serves as an authoritative resource for future policy development. Policy change currently under consideration.

Review of Coast Guard Marine Casualty Reporting & Forms Final Report on NOV 14, 2013 Final Report Open Office of Investigation & Analysis, Investigation Div (CG-INV-1) Report serves as an authoritative resource for future policy development. New forms are currently under development.

Questions?

NOSAC Final Reports Carried Over from 2015 Update Use of Foreign Citizens in OCS Activities (previously reported) – Final report submitted November 5, 2009 Dynamic Positioning Operational and Installation Guidelines (previously reported) – Final report submitted February 9, 2011 Dynamic Positioning Operating Personnel Final Report issued 11 8 (previously reported) – Final report submitted November 8, 2012 Certification and Standards for Large OSVs (previously reported) – Final report submitted May 19, 2011 Mississippi Canyon Incident Reports Review (previously reported) Final Report submitted November 8, 2012 As you can see, the members of NOSAC as well as their industry counterparts have been very busy in the past five years. For this presentation, I will be focusing on NOSAC reports that have been completed.

NOSAC Final Reports Carried Over from 2015 Update Accommodation service vessels engaged in OCS activities (previously reported) – Final report submitted November 14, 2013 Electrical Equipment Certification in Haz Locations on FF MODUs (previously reported) – Final Report submitted November 14, 2013 Additional Lifesaving and Fire Fighting Requirements on the OCS (previously reported) – Final Report submitted November 14, 2013 Safety Impact of Liftboat Sea Service Limitations (previously reported) – Final Report submitted November 14, 2013 Review of Coast Guard Marine Casualty Reporting (previously reported) – Final Report submitted November 14, 2013

NOSAC Final Reports Carried Over from 2015 Update Safety Management Systems for Vessels operating on the OCS – Final Report submitted April 17, 2014 Marine Casualty Reporting on the OCS – Final report submitted September 20, 2014 OSV Purpose and Offshore Workers – Final report submitted November 19, 2014 Training and Manning on MOUs and OSVs Operating on the OCS – Final report submitted November 19, 2014

NOSAC Final Reports New Since 2015 Update Commercial Diving Safety on the OCS –Final Report submitted April 8, 2015 Lifeboat Safety – Final report submitted December 3, 2015

Use of Foreign Citizens in Outer Continental Shelf Activities Final Report on NOV 5, 2009 Final Report Open Foreign and Offshore Vessels Division (CG-CVC-2) Dovetails with “OSV and Offshore Worker purpose and definition” Final Report issued November 19, 2014. Regulatory/Policy change currently under consideration.

Dynamic Positioning Reports Final Reports Closed DP Operational & Installation Final Report issued 2 9 2011 DP Operating Personnel Final Report issued 11 8 2012 Human Element and Ship Design Division (CG-ENG-1) Marine Personnel Qualifications Division (CG-OES-1) DP Notice of Proposed Rulemaking issued 11 28 2014.  

Certification and Standards for Large OSVs Final Report on MAY 19, 2011 Final Report Closed Human Element and Ship Design Division (CG-ENG-1) CG Authorization Act of 2010 OSVs over 6,000 GT (ITC) or 500 GT (Regulatory) Interim Final Rule published August 8, 2014.

Mississippi Canyon Incident Reports Review Final Report on NOV 8, 2012 Final Report Open Assistant Commandant for Response Policy (CG-5R) and Assistant Commandant for Prevention Policy (CG-5P) Report serves as an authoritative resource for future policy development. Subchapter N update. Rulemaking project currently underway.

Accommodation service provided on OCS vessels Final Report on NOV 14, 2013 Final Report Closed Naval Architecture Division (CG-ENG-2) Report recommended case by case determination Coast Guard has made several case by case determinations to allow the carriage of more than 36 offshore workers ASVs will be included in 33 CFR Subchapter N update

Electrical Equipment Certification in Haz Locations Final Report on NOV 14, 2013 Final Report Closed Systems Engineering Division (CG-ENG-3) Final Rule applicable to MODUs, floating facilities and vessels on the OCS published in the Federal Register March 31, 2015.

Additional LS & FF Requirements on the OCS Final Report on NOV 14, 2013 Final Report Open Lifesaving and Fire Fighting Division (CG-ENG-4) Report serves as an authoritative resource for future policy development. Additional Lifesaving and Fire Fighting Requirements will be included in 33 CFR Subchapter N update.

Safety Impact of Liftboat Sea Service Limitations Final Report on NOV 14, 2013 Final Report Open Mariner Credentialing Program Policy Division (CG-CVC-4) Report serves as an authoritative resource for future policy development. Policy change currently under consideration.

Review of Coast Guard Marine Casualty Reporting & Forms Final Report on NOV 14, 2013 Final Report Open Office of Investigation & Analysis, Investigation Div (CG-INV-1) Report serves as an authoritative resource for future policy development. New forms are currently under development. PICTURE – COSTA CONCORDIA

Safety Management Systems for vessels operating on the OCS Final Report on APR 17, 2014 Final Report Open Human Element and Ship Design Division (CG-ENG-1) Regulatory project on hold due to 2015 CG Authorization Act (12/18/2014), Sec 322. CG required to provide analysis to Congress on SMS impact by 12/18/2015. The analysis shall include— (1) a discussion of any new operational, management, design and construction, financial, and other mandates that would be imposed on vessel owners and operators; (2) an estimate of all associated direct and indirect operational, management, personnel, training, vessel design and construction, record keeping, and other costs; (3) an identification and justification of any of such proposed requirements that exceed those in international conventions applicable to the design, construction, operation, and management of vessels engaging in United States Outer Continental Shelf activities; and (4) an identification of exemptions to the proposed requirements, that are based upon vessel classification, tonnage, offshore activity or function, alternative certifications, or any other appropriate criteria.

Commercial Diving Safety on the OCS Interim Report on APR 17, 2014 Final Report Open Final Report on April 8, 2015 Vessel and Facilities Operations (CG-OES-2) Notice of Proposed Rulemaking published Feb 19, 2015. Comment period closes May 16, 2015.

Coast Guard Marine Casualty Reporting on the OCS Final Report on SEP 20, 2014 Final Report Open Office of Investigation & Analysis, Investigation Div (CG-INV-1) Vessel and Facilities Operations (CG-OES-2). Notice of Proposed Rulemaking published Jan 10, 2014. Comment period has closed and Final Rule is in clearance. PICTURE - RENA

OSV Purpose and Offshore Workers Final Report on NOV 19, 2014 Final Report Open Dovetails with “Use of Foreign Citizens in OCS Activities” Final Report issued November 5, 2009. Domestic Vessels Division (CG-CVC-1). Regulatory/Policy change currently under consideration

Training & Manning on MOUs & OSVs on the OCS Final Report on NOV 19, 2014 Final Report Open Marine Personnel Qualifications Division (CG-OES-1) Report was in response to ANPRM published April 14, 2014. Notice of Proposed Rulemaking being drafted. PICTURE - BOP on the MAERSK DISCOVERER

Questions?