View non-flash version
and emergency disconnect systems, will also be addressed in the new regulations. e coast guard shares regulatory respon- sibility for MODU safety and environmental stewardship with BOEMRE and has a long- standing memorandum of understanding to foster communications and cooperation, delineate responsibilities and ensure com- patibility in regulations and policy. That understanding has been refreshed, and an interagency work- group has been very active to identify and close gaps in regula- tions and oversight. Internationally, the coast guard is engaged at IMO to make changes as appropriate to the international MODU code based on recom- mendations made by the JIT. Although the coast guard has the authority under the Outer Continental Shelf Lands Act to set standards for all MODUs on the U.S. OCS regardless of ag, the eorts at IMO will help to enhance safety on MODUs worldwide. Similarly, the coast guard is engaged at IMO, through the Flag State Implementation Subcommittee, on provisions for the new code on ROs. e coast guard anticipates the code will be ready for adoption in 2012, will be mandatory, and will include specic and detailed requirements for ROs covering management and organization, analysis and improvement, and quality man- agement system and certication. e code also will address ag state oversight of the ROs acting on their behalf. e code will improve oversight for compliance with international standards for all vessels, including MODUs. þÿ RRisk-based targeting of foreign-ag þÿ MMODUs In June 2011, the coast guard implemented policy on risk-based targeting of foreign-ag MODUs operating on the U.S. OCS. As indi- cated previously, all MODUs operating on th e OCS are required to undergo annual inspec- tion by the coast guard. Aboard foreign-ag MODUs, this consists of an examination to ensure substantial compliance with the requirements as certied by the ag State, typ- ically via an RO. e new policy directs eld commanders to identify foreign-ag MODUs that require closer and more frequent scru- tiny, and then target limited resources to those operations. Very similar to the coast guard port state control targeting for other types of foreign-flag vessels, field commanders will determine the risk posed by foreign- flag MODUs through close examination of the vessel?s accident history, past discrep- ancies, past flag state, recognized organiza- tion, and classication society performance. Risk-based targeting helps to ensure that owners, operators, ag states, and ROs are held accountable for the level of safety and environmental stewardship achieved aboard their MODUs. e coast guard also has taken action to improve the quality of inspections and examinations on the OCS. Before the DWH incident, the coast guard had established the Oshore National Center of Expertise (NCOE). The duties of the NCOE include training MODU inspectors; conduct- ing relevant courses and seminars; and 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. Coast guard examinations of foreign-flag MODUs certified by a reputable ag state are intended to verify substantial compliance with the standards. January 2012 www.sname.org/sname/mt 01_25_FDept_SNAME_Jan12_P4.indd 912/22/11 3:35 PM