Proceedings magazine is a communication tool for the Coast Guard's Marine Safety & Security Council. Each quarterly magazine focuses on a specific theme of interest to the marine industry.
Issue link: http://uscgproceedings.epubxp.com/i/665311
16 Proceedings Spring 2016 www.uscg.mil/proceedings • is a foreign vessel bound for ports or places under the jurisdiction of the United States and subject to Chap- ter IX of the International Convention for the Safety of Life at Sea (SOLAS). While this regulation may apply to vessels engaged in OCS activities, many vessels in dedicated offshore service do not operate under a regulated SMS or SEMS. In 2013, the Coast Guard published an Advance Notice of Proposed Rulemaking to communicate the agency's intentions to require SEMS on vessels engaged in OCS activities. 4 The rulemaking project is currently under development to evaluate the need for additional safety and environmental management system requirements for OCS vessel operators. Bridging the Gap While leaseholders, pipeline operators, and vessel opera- tors perform routine activities associated with their facili- ties, they may also rely on offshore service contractors to carry out specialized activities. This additional group is not directly regulated, but is usually involved with many of the activities associated with exploration and production processes. Placing all of these parties on the outer continental shelf makes for a complicated interface. To better manage com- munications and risk, the oil and gas operators exercise a bridging process to align safety policies and procedures. Since leaseholders are responsible for all work executed under their lease, they rely on their SEMS to guide their operators and contractors as they perform safety and envi- ronmental activities. The bridging process involves a meeting between manage- ment personnel of each operator to align their safety and environmental management systems. In cases where an operator does not have a safety and environmental man- agement system, the companies' safe work practices are used instead. Often, the operator the leaseholder contracts adopts the SEMS of that leaseholder as its guiding system for safety management during the contracted work period. In all cases, all contracted work between parties on the OCS is completed after signing a bridging agreement. Additional Players, Additional Risk There is a characteristic of the bridging process that presents an added element of risk to OCS operations. Although com- pany management agrees upon the safety and environmen- tal protection measures to be followed during the contract period, the operational interface exists between persons in charge of the facilities or vessels, and these people are not always involved in the bridging process. To reduce the risk of human error due to procedural misunderstanding, onshore facilities that may be Coast Guard-regulated, so the operators have a variety of interfaces that each present a certain degree of risk. Additionally, pipeline operators sig- nifcantly contribute to the OCS risk profle that correlates to the amount of pipeline mileage spanning the seabed. The Pipeline and Hazardous Material Safety Administration is developing a national consensus standard for pipeline safety and environmental management systems. By adopt- ing the API Recommended Practice 1173, PHMSA plans to provide its operators with the framework needed to manage the risks inherent in large-scale oil and gas transportation. Vessel operators provide mobile capabilities for the above- mentioned operators, and are contracted to carry out a vari- ety of outer continental shelf activities. Vessels are typically involved in offshore facility construction, while MODUs perform drilling activities. Vessels also provide support services for facilities engaged in exploration or production processes. This extensive support of offshore infrastructure increases vessel OCS exposure, which increases the risk from offshore activities. Safety Management Systems While the Coast Guard does not have safety management regulations specifc to vessels engaged in OCS activities, it does require safety management systems on certain vessels engaged on a foreign voyage. Title 33 CFR Part 96 contains these regulations that generally apply to a foreign voyage vessel that: • transports more than 12 passengers; • is a tanker, bulk freight vessel, freight vessel, or self- propelled mobile offshore drilling unit of 500 gross tons or more; or View of a foating offshore installation from a vessel at the 500-meter zone boundary. U.S. Coast Guard photo by LT Jason Kling.