Regulatory aspects in the Indian Offshore Shipping Sector

1. Regulatory aspects in the Indian Offshore Shipping Sector Suresh Kumar Chief Ship Surveyor Directorate General of Shipping

2. Vessels used in Indian Offshore sector • Platform Supply/support/standby vessels • Anchor Handling/Towing Vessels • Accommodation Barges • MODUs • Drill ships • Crew boats • Diving /ROV Support vessel • Heavy lift/Crane vessels • Multipurpose vessels • Seismic survey vessels • Research vessels • Pipe laying vessels • Oil Spill response vessels • Vessels with DP /FiFi/deep sea diving capabilities

3. Safety & Pollution Prevention provisions National provisions • Merchant Shipping Act, 1958 and MS Rules International Conventions/codes • SOLAS, LL 1966, MARPOL,STCW • SPS Code [1983/2008] • MODU Code [1979/1989/2009, Res.A1023(26)] • OSV Code [Code of Safe Practice for the Carriage of Cargoes and Persons by Offshore Supply Vessels Res. A 863(20)] • OSV Guidelines [Guidelines for the design and construction of OSVs- MSC Res.236(82)/Res. A 469(XII)] • Limited amount of hazardous substances in bulk [Res.A 673(16), as amended] • Some of these are not mandatory internationally

4. Offshore Support Vessels • As OSVs have become bigger, more powerful, more technology-intensive, and packed with more functional roles, all to serve the needs for supporting offshore activities in deeper waters and harsher environments • These vessels are often involved in towing, anchor handling, fire fighting, underwater inspection and positioning of mobile drilling rigs, as well as assisting in various offshore construction works

5. OSV Guidelines (IMO Resolution A.469(XII) • IMO introduced Resolution A.469(XII) in 1981 mainly to address stability / damage stability criteria and certain constructional aspects. • Side wing tanks became necessary to meet the damage stability criteria • This code is not mandatory • OSVs are generally built as per these guidelines • This has been superseded by OSV Guidelines 2006 (IMO Resolution MSC.235(82))

6. OSV Guidelines 2006 (MSC.235(82)) • OSV Guidelines had been adopted in 1981 were based on the requirements of SOLAS 1974 (as amended in that year) • Relevant subsequent amendments to SOLAS incorporated • Applicable for OSVs built after 1st July 2007 • IMO issued MSC/Circ.645 & MSC/Cir.738 Guidelines for Vessels with DP system

7. IMO Resolution A.863(20) – OSV Code • IMO Resolution A.863(20) – Code of safe practice for the carriage of cargoes and persons by offshore supply vessels [OSV Code] • Was adopted by IMO in 1997 • Resolution contains issues pertaining to operations of OSVs when interfacing with offshore installations • Interfacing issues that follow from the carriage of cargoes and personnel • Cargo stowage and securing, • Port operations and operations at the offshore installation • While developing the ISM Procedure Manual, OSV Code should be taken in to account as per the DGS circular

8. Regulatory requirements – SPS Code • All Special Purpose Ships built after 13th May 2008 to comply with SPS Code 2008 (DGS S.D Circular No 3 of 2008 dated 13/10/2008) • Ships built before 13/5/2008 to meet SPS Code 1983, as applicable. • Accommodation dumb barges can have MODU compliance as well. • Applicable to Indian ships as well.

9. SPS Code • SPS Code 1903 / SPS Code 2008 • Certain types of ships operating in the offshore fields, due to their specialized nature of work, carry several personnel who are neither crew members nor passengers. • If the vessel carries more than 12 Special Personnel, such vessels should have SPS Code compliance certificate • Eg: Accommodation barges, Crew Boats, Crane barges, Cable laying ships, Seismic survey vessels, Diving Support Vessels

10. Who are Special Personnel • Scientists, technicians on ships engaged in research, non-commercial expeditions and survey • Personnel engaged in marine training • Salvage personnel on salvage ships, Cable-laying personnel on cable-laying ships, Seismic personnel on seismic survey ships, Diving personnel on Diving Support ships, pipe-laying personnel on pipe layers and crane operating personnel on floating cranes.

11. MODU Code 2009 • Code for the Construction and Equipment of Mobile Offshore Drilling Units, 2009 (2009 MODU Code). • 2009 MODU Code applies to MODUs built on or after 1 January 2012. For MODUs constructed before that date, the provisions of the 1989 MODU Code still apply. • 2009 MODU code updates 1989 MODU Code1989 applicable for MODUs built since 1 May 1991. The 1989 MODU Code superseded the 1979 MODU Code adopted by Assembly resolution A.414(XI) • Code was amended: • To maintain compatibility with SOLAS amendments; • To introduce the harmonized system of survey and certification; • To provide guidelines for vessels with dynamic positioning systems; • To introduce provisions for helicopter facilities..

12. MODU Code • Items covered : • Material, Structural strength • Stability, intact and damaged • Weathertight/watertight integrity • Temporary or emergency mooring equipment • Propulsion machinery, including shafts and propellers • Steering gear and rudders • Auxiliary machinery • Pumping and piping systems, including valves • Electrical installations • Protection against fire and explosion • Safety equipments

13. IMO Resolution A.673(16) • IMO Resolution A.673(16) – Guidelines for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk on offshore support vessels • Amended by IMO Resolution MEPC.158(55) and MSC.236(82) • Apply to OSVs carrying limited amounts of hazardous and noxious liquid substances • Do not require full compliance of IBC Code / Annex II of MARPOL 73/78

14. IMO Resolution A.673(16) • For application of the Guidelines, “limited quantities” means that the aggregate quantity of bulk liquids as identified in 1.2.2 (of the Guidelines, as amended) do not exceed 800m3 or a volume in cubic metres equal to 40% of the vessel’s DWT, whichever is less. • For well-stimulation vessels which are permitted to carry more than the maximum amounts as specified above, should meet subdivision, intact and damage stability OSV Guidelines 2006 (Resolution MSC.235(82)), but with damage occurring anywhere in the ship’s length at any transverse watertight bulkhead.

15. Regulatory Aspects-Chartering Annually about 160 to 180 ships are chartered for offshore operations These foreign offshore vessels have to obtain license from DGS under Section 406 / 407 of the Merchant Shipping Act No Objection Certificate (NOC) from INSA stating that suitable Indian ships are not available is a pre condition for license Indian ship has the right of refusal (ROFR) Compliance with SPS Code / MODU Code, as the case may be is necessary especially when there are more than 12 persons other than ship’s crew are on board

16. Regulatory Aspects-Chartering of foreign offshore vessels • Vessels are to be classed with IRS or any IACS Class society • If not classed with IRS & above 25 years of age, IRS must carry out surveys equivalent to annual surveys and ISM audit equivalent to Intermediate SMC Audit • If the vessel carries more than 12 Special Personnel, such vessels should have SPS Code / MODU Code compliance

17. Oil Pollution response Part XI-A of MS Act (prevention and containment of pollution) is applicable to offshore installations as well What needs to be done? IMO to Make MODU Code & SPS Code mandatory Develop a new Code for offshore construction vessels Inclusion of new E&P areas in NOS DCP Redefine the Tiers in the NOS-DCP Evaluate emergency preparedness in offshore areas Improve regional co-operation for deepwater emergency response (OPRC Convention) Enactment of compensation regime for accidents from oil platforms

18. THANK YOU