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Regulatory: Coast Guard Introduction. CAPT David Nichols US Coast Eighth District Outer Continental Shelf Division. Environmental Conventions and Regulations: Coast Guard. Introduction: New OCS Division on the Eighth District Staff Collaborative Relationship with BSEE.

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Regulatory: Coast Guard Introduction

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Regulatory coast guard introduction

Regulatory: Coast GuardIntroduction

CAPT David Nichols

US Coast Eighth District

Outer Continental Shelf Division


Environmental conventions and regulations coast guard

Environmental Conventions and Regulations: Coast Guard

  • Introduction:

  • New OCS Division on the Eighth District Staff

  • Collaborative Relationship with BSEE


Environmental conventions and regulations coast guard1

Environmental Conventions and Regulations: Coast Guard

  • DEEPWATER HORIZON lessons learned:

  • Commandant’s Final Action Memo

  • Prevention is key to environmental protection

  • “One Gulf, One Standard”

  • Regulatory and policy changes


Regulations coast guard active pre rule ocs training

Regulations: Coast GuardActive Pre-Rule: OCS Training

  • DWH Investigation CG Final Action: 1B, 1C, 3E , 3F

  • BSEE/USCG MOA OCS-08 on (MODUs) signed 4 June 2013

  • Key Points:

    • Marine Crew training could prevent or mitigate environmental incidents

    • Marine crew should be capable of mitigating/responding to blowouts/fires should safety systems or procedures fail

    • Coast Guard checks compliance during exams


  • Regulations coast guard voluntary guidance fixed firefighting

    Regulations: Coast GuardVoluntary Guidance: Fixed Firefighting

    • DWH Investigation CG Final Action: 2D

    • Notice of Interim Voluntary Guidance (77 FR 70172)

  • Key Points:

    • Consideration should be given to automatic operation of a fixed deluge system on drill floor and adjacent areas upon gas detection

    • Could prevent ignition and potential loss of well control


  • Regulations coast guard guidance proposed rule electrical equipment

    Regulations: Coast GuardGuidance & Proposed Rule: Electrical Equipment

    • DWH Investigation CG Final Action: 1A

    • Notice of Policy (77 FR 71607)

    • Notice of Proposed Rulemaking (78 FR 37760)

  • Key Points:

    • Would provide uniformity for all MODU’s operating on the U.S. OCS

    • Would require that certification of electrical equipment intended for use in hazardous areas be test by a competent independent lab IAW 2009 IMO MODU Code


  • Regulatory policy needs coast guard guidance dynamic positioning

    Regulatory Policy Needs: Coast GuardGuidance: Dynamic Positioning

    • DWH Investigation CG Final Action: 1B, 1C, 3E , 3F

    • NOSAC Task Statements (2010, 2013)

    • Notice of Interim Voluntary Guidance (77 FR 62247)

  • Key Points:

    • Position Loss on DP Vessel is environmental concern

    • During “Critical OCS Activity;” environmental concern greater

    • Recommends use of Marine Technology Guidelines


  • Regulatory policy needs coast guard proposed rule casualty reporting

    Regulatory Policy Needs: Coast GuardProposed Rule: Casualty Reporting

    • 33 CFR Subchapter N – OCS Activities

    • 46 CFR Part 4 – Navigable U.S. waters

    • Notice of Proposed Rulemaking (79 FR 1780)

    • Voluntary Reporting policy (CG-5PC letter of June 19, 2013)

  • Key Points:

    • Harmonizes casualty reporting requirements for U.S. and foreign operators on the OCS

    • Enhances knowledge of potential problem areas so that a proactive approach can be taken

    • Voluntary reporting for dynamically positioned MODU’s not currently required to report


  • Regulatory policy needs coast guard active pre rule sms on ocs vessels

    Regulatory Policy Needs: Coast Guard Active Pre-Rule: SMS On OCS vessels

    • Attention to safety procedures/systems prevents environmental incidents

    • DWH Investigation CG Final Action: 1A, 5D, 5I, 5K, 5L

    • BSEE/USCG MOA OCS-07 on SEMS and SMS signed 30 April 2013

    • Advanced Notice of Proposed Rulemaking (78 FR 55230)

  • Key points:

    • How should a vessel SMS interface with an Operators SEMS plan?

    • How should authority over vessel interface with authority over OCS activity?


  • Regulatory policy needs coast guard wrap up

    Regulatory Policy Needs: Coast GuardWrap up

    Questions?


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