Draft US Regulations on Dynamic Positioning (DP)

The US Coast Guard (USCG), under the Department of Homeland Security, has issued a notice of proposed rulemaking (NPRM) on Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems. This notice can be found at www.gpo.gov/fdsys/pkg/FR-2014-11-28/pdf/2014-27594.pdf. The draft rulemaking includes DP standards for all aspects of DP, including operation, design, training, manning and watchkeeping. The IMCA Secretariat is reviewing the details, but from our initial quick review, members’ attention is drawn to the following key points:

• The new requirements would apply to US and non-US registered MODUs and other offshore vessels operating on the US Outer Continental Shelf (OCS);
• New and existing MODUs using DP systems, and any other vessel that uses a new DP system, to engage in Critical OCS Activities, must obtain a DP notation equivalent to IMO MSC/Circ.645 equipment class DP-2 or higher from a classification society recognised by the US Coast Guard;
• New and existing MODUs, and new vessels other than MODUs, engaged in Critical OCS Activities must comply with certain provisions of IMO MSC/Circ.645 and the MTS DP operations guidance documents;
• Higher risk vessels would be required to obtain plan review and surveys from a dynamic positioning system assurance organisation;
• Dynamic positioning operators (DPOs) must be credentialed mariners, but need not be licensed;
• Minimum training should meet the standards of IMCA M 117 – The training and experience of key DP personnel.

Members may wish to submit comments through IMCA, in which case these need to be received by close of business on Friday 30 January 2015 to ensure a timely submission to the USCG.

Originally issued with the following reference(s): IMCA M 14/14, IMCA SEL 14/14