REGULATORY ADVISORY: Proposed Manning Changes for Mobile Offshore Drilling Unit

Nearly seven years ago, on April 20, 2010, while conducting temporary well-abandonment activities in the U.S. Gulf of Mexico, the mobile offshore drilling unit (MODU) Deepwater Horizon experienced a series of events that resulted in explosions, fire, loss of eleven lives, sinking of the vessel, and the largest oil spill in the U.S. history.

There were many investigations in the aftermath of the disaster to determine causal factors and identify potential safety improvements to offshore oil and gas drilling. The Department of Homeland Security and The Department of the Interior conducted a joint investigation. All told, the Joint Investigation Team (JIT) held seven public hearings, called over 80 witnesses, issued more than 90 subpoenas, and collected over 400,000 pages of evidence.

Within the U.S. Coast Guard jurisdiction, the JIT recommended 52 safety improvements, on 80 percent of which the Commandant agreed to take action. One major recommendation was to implement regulatory changes that provide clear designation of the person in charge under both operating and emergency situations for all MODUs operating on the U.S. Outer Continental Shelf.

Additionally, in March 2013, the International Maritime Organization (IMO) began its investigation into the Deepwater Horizon casualty.  A proposed amendment to the MODU Code under consideration is “For units that use dynamic positioning systems as a sole means of position-keeping, the master should be designated as the person in charge at all times.”

On November 28, 2014, the Coast Guard published the Proposed Rules on Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems, which requires all MODUs be under the command of an individual holding an appropriate certificate of competency as a master issued by the Flag State authority.

For assistance with regulatory compliance, please contact Meridian Global Consulting at (251) 345-6776 or info@meridian.us.

  1. International Maritime Organization, Review the MODU CODE, LSA CODE and MSC.1/CIRC.1206/ REV.1, SSE 2/12 19 December 2014

  2. Federal Register, Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems; Proposed Rule, Vol. 79, No. 229, November 28, 2014

For more information please contact Meridian.us at (251) 345-6776 or info@meridian.us.

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