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plan review, inspection during construction, and in-service inspection. In-service inspec- tion involves extensive testing of critical safety systems, review of the safety management system (where applicable), and attendance at dry dock for examination of internal structural members. Foreign-flag MODUs operating on the U.S. OCS are subject to Coast Guard Port and Coastal State Control oversight on at least an annual basis, and more frequently in some cases. Foreign-ag MODUs must comply with all applicable IMO requirements, including the IMO MODU code, or meet the U.S. standards or equivalent. Most ag states for foreign-ag MODUs rely on ROs to conduct inspections and issue the necessary certicates on their behalf. It is the responsibility of the ag state to ensure compliance with the standards. Coast guard examinations of foreign- ag MODUs certied by a reputable ag state are intended to verify substantial compli- ance with the standards. Compliance exams typically involve checking documents and certicates, testing the most critical safety and lifesaving systems, and assessing the crew competency to handle emergencies. ey do not typically involve detailed inspection of internal structure, electrical systems, or aux- iliaries. If a Port State Control exam reveals a concern, the coast guard will engage the ag state to conduct a more in-depth inspection. e coast guard will issue a certicate of com- pliance to those foreign MODUs operating in the U.S. OCS that demonstrate full compli- ance with our coastal state requirements. Deepwater Horizon investigation Immediately following the explosion and sinking of the DWH, the coast guard and the Minerals Management Service--since replaced by the Bureau of Ocean Energy Management (BOEM) and the Bureau of Safety and Environmental Enforcement (BSEE)--convened a joint investigation to gather and examine evidence regarding the circumstances of the incident, and to make recommendations to help prevent future similar events. The coast guard members of the joint investigation team (JIT) focused on aspects of the incident under coast guard jurisdiction. ese include the explosions and re, the evacuation, the ooding and sinking, and the safety systems including the safety management systems implemented by the vessel operator. e ndings, conclusions, and recommendations of the coast guard members of the JIT were published in April 2011 as volume I of the JIT report. e com- mandant?s nal action memo, which directs action on the JIT?s recommendations, was made public in September 2011. The non-administrative recommenda- tions of the coast guard JIT members can be generally characterized as those regard- ing domestic and international standards for MODUs operating on the U.S. OCS, and those regarding oversight to ensure compli- ance with the standards. e commandant concurred or partially concurred with the majority of the JIT recommendations and directed action to enhance safety on the OCS by improving both standards and oversight. þÿ TTaking action e coast guard is taking action to improve both the standards and the compliance regime for U.S. and foreign MODUs. Even before the DWH incident, the coast guard was proposing extensive regulatory changes to Title 33 CFR, Subchapter N, which includes standards for the design, construction, test- ing, and operation of MODUs, including critical systems such as electrical, machin- ery, reghting, and lifesaving equipment. That effort has been driven by the need to ensure regulations keep pace with the state of technology, and has now been informed by lessons learned from DWH. Many of the sys- tems examined by the JIT will be addressed in the proposed Subchapter N regulations, including systems that help prevent explo- sions, mitigate the impact, and ensure the survivability of critical systems such as re pumps. Other critical safety systems not spe- cically called out by the JIT in relation to the DWH incident, such as dynamic positioning Coast guard Chief Warrant þÿ OOcer Gene Sykes inspecting the NW0 ballast tank during the Ram-Powell in-service inspection program in þÿ OOctober 2010. ABS Surveyor Jorge Cuidad del Carmen, left, and Chief Warrant þÿ OOcer Gene Sykes witnessing a SEI þÿ L OLOD Phase II swim-by inspection at the port in Dos Bocas, Mexico. January 2012 www.sname.org/sname/mt A Coast Guard Perspective continued (policy brieng) 01_25_FDept_SNAME_Jan12_P4.indd 812/22/11 3:35 PM