I MCA a nd ADCI wo rking to g e the r to b e ne fit o ffsho re c o mme rc ia l diving I mpro ving pe rfo rmanc e in the marine c o ntrac ting industry Pro po sing a n a lte rna tive me tho d o f de mo nstra ting c o mplia nc e with 46 CF R Pa rt 197, Sub pa rt B (Co mme rc ia l Diving Ope ra tio ns) Presenters: Phil Newsum ADCI, Peter Sieniewicz IMCA Venue: DNV GL Facility: Katy, Texas . Date: September 11 th 2019
A po ssib le a lte rna tive me tho d o f c o mplia nc e • This proposal doesn’t alter or change the current CFR in any way. • The USCG, by way of a policy letter, have recently permitted two organisations to demonstrate compliance with the respective CFR’s through membership of their associations. • In April 2019, ADCI and IMCA approached the USCG to explore the possibility of using this method to demonstrate compliance during a diving vessel examination for the components relating to CFR 46, Part 197 General Provisions: Sub Part: B Commercial Diving Operations. • The existing full inspection regime undertaken by the Coast Guard would still also be available for organisations who wish to undergo a full inspection or who are not members of either organisation. • ADCI and IMCA were asked to bring this proposal to the next NOSAC meeting for discussion. 2
A po ssib le a lte rna tive me tho d o f c o mplia nc e Aim: • The aim of the policy would be to allow members to demonstrate full compliance with CFR 46, 197 by being a member of either ADCI or IMCA. • The contractor could use his current membership certificate as a method to demonstrating compliance with CFR 46, Part 197, for the diving and diving system portion of a vessel’s examination, • It is recognized that the current standards used by both Associations adhere to, and exceed, the current CFR requirements. 3
A po ssib le a lte rna tive me tho d o f c o mplia nc e Application: • The policy would apply only to ADCI and IMCA Members • The ability to demonstrate compliance during a USCG Inspection will still remain an alternative to membership of either organisation. • Members wishing to fulfil the CFR requirements through membership would be required to be a member of good standing in either or both Associations and be able to present a valid membership certificate for the year at the time of inspection. • The United States Coast Guard will still retain the authority to board the vessel and inspect the diving system and diving operation for compliance at any time. 4
A po ssib le a lte rna tive me tho d o f c o mplia nc e • Companies applying for membership must meet the standards required by either Association. • It is accepted by industry that these standards far exceed the legislative requirements contained in the CFR. • For continued membership, companies must maintain these standards. • Failure to do so could result in serious penalties including: suspension or expulsion of the company from either Association and this could have implications to contractor who choose to use the certificate as a method of demonstrating compliance. • In addition, both Associations have recently entered into a Memorandum of Understanding (MOU) so information on poor performing mutual members can be shared. • Details of any suspension or expulsion would also be provided to the United States Coast Guard (USCG) should this proposal proceed. 5
A po ssib le a lte rna tive me tho d o f c o mplia nc e Proposed Policy: • If the contractor is using the membership certificate option as the method to demonstrate compliance with CFR 46, Part 197, for the diving and diving system portion of a vessel’s examination, credit will only be applied providing the following conditions are met: — The vessel complies with all relevant Coast Guard legislation i.e. both the vessel survey and audit requirements and there are no major identified, uncorrected non-conformances before the issue of the Coast Guard certificate. — There can be no significant outstanding deficiencies from any previous examinations conducted by the Coast Guard. — The organisation is a member in good standing. — For vessels that are classed by a recognised classification society, there are no significant outstanding issues for class at the time of the inspection. 6
A po ssib le a lte rna tive me tho d o f c o mplia nc e • Providing all the above criteria are met, the United States Coast Guard could then issue the vessel’s Certificate of Inspection (COI) based partly on membership of either Association. • We realise that this proposal is a change in approach in the way diving vessels are currently inspected by the Coast Guard, however, we feel there are benefits in terms of both time and money by offering an alternative method of compliance, as well as improvements in safety to diving operations being undertaken from USCG regulated vessels. 7
A po ssib le a lte rna tive me tho d o f c o mplia nc e • This proposal would only apply to vessels and dive operations in the Outer Continental Shelf (OCS). • Should there be movement with the final draft of the new 46 CFR Part 197, Subpart B, and it becomes law, this proposed alternative would then no longer be in effect. 8
A po ssib le a lte rna tive me tho d o f c o mplia nc e Summary • This proposal doesn’t alter or change the current CFR in any way. • The ability to demonstrate compliance during a USCG Inspection will still remain an alternative to membership of either association. • In fact compliance with the proposed policy by being a member of either IMCA or ADCI would be tougher as the requirements for membership of either association exceed requirements of the CFR. • However, by choosing the alternative method we feel there are benefits in terms of both time and money by offering an alternative method of compliance to contractors, as well as potential improvements to the safety of diving operations being undertaken from USCG regulated vessels. 9
Working together to benefit offshore commercial diving w w w .adci-int.org w w w .im ca-int.com
Recommend
More recommend
