Suresh Kumar

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							Regulatory aspects in the Indian
   Offshore Shipping Sector


                          Suresh Kumar
                       Chief Ship Surveyor
                 Directorate General of Shipping
    Vessels used in Indian Offshore sector
•    Platform Supply/support/standby vessels
•    Anchor Handling/Towing Vessels
•    Accommodation Barges
•    MODUs
•    Drill ships
•    Crew boats
•    Diving /ROV Support vessel
•    Heavy lift/Crane vessels
•    Multipurpose vessels
•    Seismic survey vessels
•    Research vessels
•    Pipe laying vessels
•    Oil Spill response vessels
•    Vessels with DP /FiFi/deep sea diving capabilities
       Safety & Pollution Prevention provisions
National provisions
• Merchant Shipping Act, 1958 and MS Rules
International Conventions/codes
• SOLAS, LL 1966, MARPOL,STCW
• SPS Code [1983/2008]
• MODU Code [1979/1989/2009, Res.A1023(26)]
• OSV Code [Code of Safe Practice for the Carriage of Cargoes and Persons
    by Offshore Supply Vessels Res. A 863(20)]
• OSV Guidelines [Guidelines for the design and construction of OSVs- MSC
    Res.236(82)/Res. A 469(XII)]
• Limited amount of hazardous substances in bulk [Res.A 673(16),
    as amended]
• Some of these are not mandatory internationally
        Offshore Support Vessels

• As OSVs have become bigger, more powerful,
  more technology-intensive, and packed with
  more functional roles, all to serve the needs for
  supporting offshore activities in deeper waters
  and harsher environments
• These vessels are often involved in towing,
  anchor handling, fire fighting, underwater
  inspection and positioning of mobile drilling rigs,
  as well as assisting in various offshore
  construction works
OSV Guidelines (IMO Resolution A.469(XII)

• IMO introduced Resolution A.469(XII) in 1981
  mainly to address stability / damage stability
  criteria and certain constructional aspects.
• Side wing tanks became necessary to meet the
  damage stability criteria
• This code is not mandatory
• OSVs are generally built as per these guidelines
• This has been superseded by OSV Guidelines
  2006 (IMO Resolution MSC.235(82))
   OSV Guidelines 2006 (MSC.235(82))

• OSV Guidelines had been adopted in 1981 were
  based on the requirements of SOLAS 1974 (as
  amended in that year)
• Relevant subsequent amendments to SOLAS
  incorporated
• Applicable for OSVs built after 1st July 2007
• IMO issued MSC/Circ.645 & MSC/Cir.738
  Guidelines for Vessels with DP system
   IMO Resolution A.863(20) – OSV Code

• IMO Resolution A.863(20) – Code of safe practice for the
  carriage of cargoes and persons by offshore supply
  vessels [OSV Code]
• Was adopted by IMO in 1997
• Resolution contains issues pertaining to operations of
  OSVs when interfacing with offshore installations
• Interfacing issues that follow from the carriage of
  cargoes and personnel
• Cargo stowage and securing,
• Port operations and operations at the offshore
  installation
• While developing the ISM Procedure Manual, OSV Code
  should be taken in to account as per the DGS circular
   Regulatory requirements – SPS Code

• All Special Purpose Ships built after 13th May
  2008 to comply with SPS Code 2008 (DGS S.D
  Circular No 3 of 2008 dated 13/10/2008)
• Ships built before 13/5/2008 to meet SPS Code
  1983, as applicable.
• Accommodation dumb barges can have MODU
  compliance as well.
• Applicable to Indian ships as well.
                      SPS Code

• SPS Code 1903 / SPS Code 2008
• Certain types of ships operating in the offshore fields,
  due to their specialized nature of work, carry several
  personnel who are neither crew members nor
  passengers.
• If the vessel carries more than 12 Special Personnel,
  such vessels should have SPS Code compliance
  certificate
• Eg: Accommodation barges, Crew Boats, Crane barges,
  Cable laying ships, Seismic survey vessels, Diving
  Support Vessels
         Who are Special Personnel

• Scientists, technicians on ships engaged in research,
  non-commercial expeditions and survey
• Personnel engaged in marine training
• Salvage personnel on salvage ships, Cable-laying
  personnel on cable-laying ships, Seismic personnel
  on seismic survey ships, Diving personnel on Diving
  Support ships, pipe-laying personnel on pipe layers
  and crane operating personnel on floating cranes.
                    MODU Code 2009

• Code for the Construction and Equipment of Mobile Offshore Drilling
  Units, 2009 (2009 MODU Code).
• 2009 MODU Code applies to MODUs built on or after 1 January
  2012. For MODUs constructed before that date, the provisions of the
  1989 MODU Code still apply.
• 2009 MODU code updates 1989 MODU Code1989 applicable for
  MODUs built since 1 May 1991. The 1989 MODU Code superseded
  the 1979 MODU Code adopted by Assembly resolution A.414(XI)
• Code was amended:
• To maintain compatibility with SOLAS amendments;
• To introduce the harmonized system of survey and certification;
• To provide guidelines for vessels with dynamic positioning systems;
• To introduce provisions for helicopter facilities..
                      MODU Code

•   Items covered :
•   Material, Structural strength
•   Stability, intact and damaged
•   Weathertight/watertight integrity
•   Temporary or emergency mooring equipment
•   Propulsion machinery, including shafts and propellers
•   Steering gear and rudders
•   Auxiliary machinery
•   Pumping and piping systems, including valves
•   Electrical installations
•   Protection against fire and explosion
•   Safety equipments
          IMO Resolution A.673(16)

• IMO Resolution A.673(16) – Guidelines for the
  transport and handling of limited amounts of
  hazardous and noxious liquid substances in bulk
  on offshore support vessels
• Amended by IMO Resolution MEPC.158(55) and
  MSC.236(82)
• Apply to OSVs carrying limited amounts of
  hazardous and noxious liquid substances
• Do not require full compliance of IBC Code /
  Annex II of MARPOL 73/78
            IMO Resolution A.673(16)

• For application of the Guidelines, “limited quantities”
  means that the aggregate quantity of bulk liquids as
  identified in 1.2.2 (of the Guidelines, as amended) do not
  exceed 800m3 or a volume in cubic metres equal to 40%
  of the vessel’s DWT, whichever is less.
• For well-stimulation vessels which are permitted to carry
  more than the maximum amounts as specified above,
  should meet subdivision, intact and damage stability
  OSV Guidelines 2006 (Resolution MSC.235(82)), but
  with damage occurring anywhere in the ship’s length at
  any transverse watertight bulkhead.
         Regulatory Aspects-Chartering

• Annually about 160 to 180 ships are chartered for offshore
  operations
• These foreign offshore vessels have to obtain license from
  DGS under Section 406 / 407 of the Merchant Shipping
  Act
• No Objection Certificate (NOC) from INSA stating that
  suitable Indian ships are not available is a pre condition for
  license
• Indian ship has the right of refusal (ROFR)
• Compliance with SPS Code / MODU Code, as the case
  may be is necessary especially when there are more than
  12 persons other than ship’s crew are on board
 Regulatory Aspects-Chartering of foreign
             offshore vessels
• Vessels are to be classed with IRS or any IACS
  Class society
• If not classed with IRS & above 25 years of age,
  IRS must carry out surveys equivalent to annual
  surveys and ISM audit equivalent to Intermediate
  SMC Audit
• If the vessel carries more than 12 Special
  Personnel, such vessels should have SPS Code /
  MODU Code compliance
               Oil Pollution response

• Part XI-A of MS Act (prevention and containment of
  pollution) is applicable to offshore installations as well
What needs to be done?
• IMO to Make MODU Code & SPS Code mandatory
• Develop a new Code for offshore construction vessels
• Inclusion of new E&P areas in NOS DCP
• Redefine the Tiers in the NOS-DCP
• Evaluate emergency preparedness in offshore areas
• Improve regional co-operation for deepwater emergency
  response (OPRC Convention)
• Enactment of compensation regime for accidents from oil
  platforms
THANK YOU

						
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