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The Quality (R)Evolution
• Introduction• A Perfect Storm• Tragedy• Economic Necessity• Regulation
• A Perfect Opportunity• Learning from Past Mistakes• Economic Potential• Industrial Evolution
• The Quality (R)Evolution• A Local & Global Opportunity
• Dynamic Positioning Assurance• Challenges to Progress
What is the Quality (R)Evolution?
• Evolution• “Recommended Practice” Becomes guidance Becomes rules/regulations
• Revolution• Industry evolution is being expedited as a result of:• Tragedy• Economic necessity• Regulation
DP Incidents
Data: International Marine Contractors Association. Dynamic Positioning Station Keeping Incidents: Incidents Reported for 2007 (DPSI 18). IMCA M 198, August 2009.
USCG DWH ROI – 22 April 2011
Appendix I – Potential legal issues associated with vessels employing dynamic positioning systems
• Outlines the gaps found in DP regulation found during the course of the Deepwater Horizon investigation.
• Memorandum “is the basis document everything will derive from.”
Lessons learned
The Deepwater Horizon’s DP capabilities are in no way implicated in the tragedy, but the subsequent investigation uncovered several DP related issues with regard to DP regulation.
Issues highlighted in the DWH report
•Definitions:•Self propelled motor vessel•On location•Underway
•Manning implications
•Authority over foreign vessels utilizing dynamic positioning (DP) systems engaged in Outer Continental Shelf (OCS) activities in the US.
Definitions
Clarification of terms used in current regulations:
Self-propelled motor vessels• In light of the broad and generally applicable regulatory definitions of “motor vessel”
and “self propelled,” a vessel operating in DP mode… is considered a self-propelled vessel.
On location• Under our current regulations, any vessel holding position solely through the use of
its DP system cannot be “on location.”
Underway• Because a vessel operating under DP is not at anchor, nor is it made fast to shore
or the ocean bottom, it is by definition “underway.”
Manning implications
As defined above, any vessel or watercraft operating under the control of a DP system is classified by the USCG as self-propelled and underway.
Therefore, manning requirements are dependent on size of the vessel and fall under the applicable federal regulations, specifically 46 U.S.C. Part F that specifies complement , citizenship requirements, watch length and rotations, and minimum number of licensed individuals.
U.S. Authority over foreign DP capable assets
The U.S. maintains a certain amount of authority over ANY vessel operating on its jurisdictional waters, as outlined in 46 U.S.C. §§ 2301-2302 and 43 U.S.C. §§ 1331-1356a.
Regulations may be promulgated by the Coast Guard as deemed necessary.
•Evolution•“Best industry practice”Becomes guidanceBecomes rules/regulations
The GREY AREA
The USCG is attempting to impose/enforce regulation on a sector of the industry that has no international regulation, only guidance and recommended practice.
Where this is of particular concern is in enforcing manning requirements. Neither the U.S. or international regulatory bodies have any clear requirements for the minimum manning of DP vessels.
The very last line of Appendix I states:
Any new regulations to be promulgated should consider current international standards/practices and that DP technology is constantly evolving.
Where will regulations increase/tighten?
Data: Economist Intelligence Unit, Ltd. Deepwater Ahead? The outlook for the oil and gas industry in 2011, Economist Intelligence Unit (magazine), January 2011.
What are the greatest challenges?
Data: Economist Intelligence Unit, Ltd. Deepwater Ahead? The outlook for the oil and gas industry in 2011, Economist Intelligence Unit (magazine), January 2011.
Where do the opportunities lie?
Data: Economist Intelligence Unit, Ltd. Deepwater Ahead? The outlook for the oil and gas industry in 2011, Economist Intelligence Unit (magazine), January 2011.
The Quality (R)Evolution and its global impact
A local and global opportunity
• Current industry climate provides opportunity to affect positive change within the industry
• Guidance already exists in the form of IMCA guidelines, NI recommendations, etc.
• Existing guidelines provide the majority of NOSAC recommendations to the USCG and MTS DP Guidelines.
• Regulation in place in the US• Applied to foreign vessels working in the US• Adoption of similar standards by foreign operators in order to compete• Standards incorporated into company operating guidelines
The dynamics of DP Assurance
RegulatoryChanges
Guidance
Incidents &Repercussions
DecisionMaking
DecisionMaking
Capabilities
Capabilities
EconomicConsiderations
Capabilities
Original image: Kongsberg
Progress
Components of DP Assurance
DP ASSURANCE
CMID
DP Procedures
DP Manning
DP FMEA
DP Annual Trials
DP Documentation
IMO
IMCA
Class
Company Internal Requirements
Safe Mode of Operation
OVID
ISM & Maintenance
DP Capability
USCG
FSOG
Operational Procedures
Oil Majors’ Requirements
The tools of Dynamic Positioning Assurance
• CMIDs• DP and Ballast FMEA• DP Proving trials• DP Annual trials• Vessel DP Operation Manuals• Company DP Operation Manuals• DP Procedures• DP & Ballast FMEA Gap Analysis
• DP Suitability Surveys
• DP Condition Surveys
• DP Training
• DP Reps/Leads
• Safe Mode of Operations
• ASOG and FSOG
• DP Incident Investigations
• `
How are DP Assurance goals attained?
Establish and maintain relationships in the industry to track new developments and changes
Work alongside clients and industry partners to develop specific, built-to-suit DP Assurance programs
•Bridge the gap between existing regulations, recommended practice, and client requirements•Company and vessel specific guidelines•Establish guidelines that accurately reflect capabilities
Provide continuous support throughout the length of the client/provider relationship
Conclusions
Dynamic Positioning Regulation is a work in progress and SHOULD continue to be so in order to grow alongside an evolving industry and technology
The ultimate goal of any regulation is to improve the overall safety standard of an entire industry
In the field of DP Assurance, regulation—whether it is currently in place or proposed—should not represent an obstacle to productivity or profitability
DP Assurance provides the guidance and tools necessary to create opportunity in an evolving regulatory environment by encompassing a proactive rather than reactive approach
…?
Thank you for your attention.
Any questions or comments?
Contact :
Chad N. Fuhrmann – DP Assurance Lead, [email protected]+1 281 685 0836