AMSA Acceptance of Performance-Based

Inspection Regimes on FPSOs

Rob Gehling & Alex Schultz-Altmann

Ship Inspection & Registration

AMSA, Canberra

About AMSA

VISION - Safe and clean seas, saving lives.

MISSION - Ensuring safe vessel operations, combatting marine

pollution, and rescuing people in distress.

VALUES:

Professional –act with integrity and pragmatism in our approach

Collaborative –value and respect others and cooperate to

achieve our objectives

Dedicated – committed to MISSION and responsive to needs of

customers and stakeholders

Accountable –take responsibility for decisions and actions.

AMSA’s Safety Jurisdiction

• s.640 of the Offshore Petroleum and Greenhouse Gas Storage

Act 2004 dis-applies the Navigation Act 2012 from an offshore

vessel when that vessel is within the definition of “facility” under

cl. 4 of Sch. 3 of OPGGSA.

• FPSOs are subject to the Navigation Act 2012 at other times

such as on delivery/docking voyages to and from the operating

location or when they have dropped the riser to manoeuvre

away from the site in severe sea/weather conditions.

• Navigation Act 1912’s special treatment of offshore vessels and

units is discontinued

– Now subject to the same application criteria as other ships apart from

dis-application under OPGGSA

– Non-disconnectable cannot be treated as fixed platforms when not

“facilities” under OPGGSA

• So Navigation Act 2012 applies whenever OPGGSA dis-

application is not in force

– Delivery voyages including non-propelled vessels

– Docking voyages

– Release from riser to avoid severe weather/sea

Navigation Act 2012

Disconnectable FPSOs - 1

• FPSOs are required to have valid international safety

certificates whenever subject to Navigation Act 2012

• SOLAS and Load Line

• SOLAS reg. I/10 requires inspection of the outside of the

ship’s bottom twice in any five-year period

• Relevant survey guidelines Res. A.1104(29) and A.1049(27)

specify bottom inspections to be in drydock except that

alternate inspections (every second one) may be in-water

• Effectively requires drydocking every 5 years, which is generally

disruptive to FPSO operations

• Particularly in the final years of field life

• AMSA has long recognised this docking problem

• Note to 7.8 of Marine Order 60 (Floating Offshore Facilities)

provides for AMSA to accept in-water bottom inspections on

FPSOs if conditions are met

– but of doubtful legal effect in over-riding a Convention provision

• AMSA was active at IMO in development of MARPOL FPSO

Guidelines MEPC.139(53) providing some relaxation regarding

surveys, and MSC-MEPC.2/Circ.9 which urges Administrations

to take a pragmatic approach to the application of Convention

requirements to FPSOs

• The latter has not yet been incorporated into Marine Orders

Disconnectable FPSOs - 2

A Solution

• For the FPSO OKHA, AMSA has approved a Performance-

Based Inspection regime which pragmatically achieves equivalent

survey outcomes to the statutory bottom inspection provisions of

SOLAS and the Enhanced Survey Programme for oil tankers

• Based on an extensive study of the vessel’s current structural integrity and

predicted corrosion

• Vessel surveyed on-location and not required to leave riser for drydocking

while class society rules are complied with

• Equivalence issued under existing Marine Order 60.

• Similar studies initiated for a second FPSO to translate to PBI

Scheme

FPSO Lifeboat Safety

• FPSO problems extend beyond bottom survey to lifeboat drills

• AMSA recognises that davit-launched lifeboats may not be

readily and safely retrieved at sea but are still required by

SOLAS to be manoeuvred in the water each 3 months

• Safety of personnel in lifeboat is primary

• Equivalent arrangement involving enhanced maintenance

checks and annual assisted boat launching now issued for two

FPSOs – again this is a performance-based regime

• AMSA open to discussion with operators of other FPSOs

otherwise still subject to 3 month requirement

• AMSA is in the initial stages of reviewing MO.60

• It is proposed that MO.60 will be merged with MO.47 (MODUs)

• Some safety measures of the MODU Code are more

appropriate to the configuration and operation of FPSOs than

the corresponding traditional ship requirements

– eg. fire protection, escape, life-saving appliances

• PBI regimes to be alternative to 5-yearly docking cycles

Revision of Marine Order 60 - 1

• New MO will also cover other floating facilities (eg. FLNG, CPF)

when under the Act and may provide for voluntary maintenance

of safety certification when Act is dis-applied

– FLNGs to be subject to technical requirements of International Gas

Carrier Code

• Industry will be fully consulted

• Schedule is subject to drafting priorities but the new MO is

intended to be in place later this year

Revision of Marine Order 60 - 2

• Current and proposed actions by AMSA in relation to

application of statutory requirements to FPSOs are in

accordance with AMSA Values

– Professional – integrity, pragmatism

– Collaborative – value, respect, cooperation

– Dedicated – responsive, committed to Mission (ensuring safe vessel

operations, combatting marine pollution, and rescuing people in distress)

– Accountable – take responsibility

Conclusion

Any questions?