NVIC 08-91: Inspecting existing uncertificated offshore supply vessels

United States COMDTPUB P16700.4 Coast Guard NVIC 8-91 21 May 1991 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 8-91 Electronic Version for Distribution Via the World Wide Web Subj: Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Liftboats

Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Lifeboats — PURPOSE. This Circular publishes guidance for the issuance of Certificates of Inspection to

existing offshore supply vessels (OSV's), including liftboats, that were not previously inspected.

Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Lifeboats — DIRECTIVES AFFECTED. NVIC 8-81 and Change 1 are canceled.

DIRECTIVES AFFECTED. NVIC 8-81 and Change 1 are canceled.

Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Lifeboats — BACKGROUND.

a.

Public Law 96-378 provides for the inspection and certification of all OSV's.

Existing, uncertificated, conventional (i.e., shipshape, nonself-elevating hull) vessels were inspected and certificated under the guidance provided in NVIC 8-81.

An existing, conventional offshore supply vessel is one that was operating as such on or before January 1, 1979 or, if not in service of any kind before that date, was contracted for on or before that date and entered service as such before October 6, 1980. b.

An OSV is defined in 46 U.S.C. 2101(19) as "a motor vessel of more than 15 gross tons but less than 500 gross tons that regularly carries goods, supplies, or equipment in support of exploration, exploitation, or production of offshore mineral or energy resources and is not a small passenger vessel." The application of this definition is not affected by the physical location of the vessel.

The word "offshore," as it modifies "supply vessel" has no geographical significance.

As long as the vessel in question fits the definition of an OSV, it is considered an OSV and must be inspected as such.

"Offshore" is not defined by statute or regulation.

Past administrative policy has been to define "offshore" as that water seaward of the coastline (as measured from the mean high water mark).

A review of the legislative history of applicable statutes provides no congressional intent to create a regulation-free zone for OSV's when operating "inshore or inland." c.

Liftboats were originally uninspected vessels intended to provide a stable work platform for construction and maintenance of fixed structures in shallow, protected, or partially protected water.

Over the years designs were modified for service in deeper waters, farther from shore.

A review of liftboat casualties showed that these vessels had been routinely carrying goods, supplies, equipment, and offshore workers to offshore structures in addition to performing their traditional function as construction and maintenance support vessels.

Accordingly, liftboats were reclassified as OSV's and brought under inspection.

Change 1 to NVIC 8-81 provided guidance pertaining to initial certification of existing liftboats.

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 8-91 d.

The effect of these policy determinations was to require a number of previously uninspected vessels to now be inspected and certificated.

The Coast Guard has initiated a regulatory project (CGD 82-004 and CGD 86-074) to promulgate regulations specifically addressing OSV's and the unique design and operation of these vessels, including liftboats. these rules, once promulgated, will apply to new vessels.

In the interim, this Circular replaces the guidance in NVIC 8-81 and Change 1.

Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Lifeboats — DISCUSSION.

a.

This guidance is intended to apply to the initial inspection of existing, uncertificated OSV's.

The guidance also applies to the subsequent inspections of OSV's (including liftboats), now certificated, that were brought under inspection under the previous guidance of NVIC 8-81 and/or Change 1. b.

In the case of existing, conventional vessels, the majority of initial inspections were completed using the provisions of NVIC 8-81.

Subsequent inspections of conventional OSV's should be conducted in accordance with this Circular.

Many provisions of the previous guidance have been incorporated into this Circular. c.

The initial inspection of many liftboats was conducted using the guidance of NVIC 8-81, Change 1, published in March 1988.

The Coast Guard has since learned that a significant percentage of the liftboat fleet works in waters close to shore, either "Lakes, Bays, and Sounds," or within the Boundary Line.

The Boundary Line in the Gulf of Mexico is twelve miles from a line which marks the seaward limits of the contiguous zone (46 CFR 7.105).

Liftboats operating inside the Boundary Line need not meet standards as stringent as those intended for those operating beyond the Boundary Line because of their proximity to a safe harbor or other location where they can elevate to survive a severe storm. d.

Subsequent inspections of existing liftboats should be conducted in accordance with this Circular.

This inspection guidance is derived from existing guidance, regulations in 46 CFR Subchapters I and T, and sections of Subchapter IA which address the unique characteristics of self-elevating units. e.

There may also be a number of small, conventional OSV's that work in "Lakes, Bays, and Sounds" or other "inshore or inland" waters that have never been inspected.

Previously, they would not have been subject to inspection unless carrying "passengers or freight for hire." However, if routinely carrying goods, supplies, or equipment in support of exploration, exploitation, or production of offshore mineral or energy resources, these vessels are subject to inspection as OSV's.

It is expected that these vessels are generally small, less than 100 gross tons.

The basic provisions of this guide may be used to conduct the initial and subsequent inspections for certification in lieu of strict compliance with Subchapter I or T (as applicable).

Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Lifeboats — GRANDFATHER PROVISIONS. Public Law 96-378 requires that on or after 1 January 1989,

each existing OSV that is twenty years or older is subject to inspection the same as a new vessel. It is expected that most of these vessels will be voluntarily retired from service since the economic life of an OSV is generally considered to be about 15 years. Those remaining in service should be inspected by the Officer in Charge, Marine Inspection (OCMI), on a case-by- case basis, to determine the extent it complies with current regulations, recognizing that original plans for these old vessels may be difficult to provide. The vessel's service history should be NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 8-91 considered in identifying areas of noncompliance. Grandfathered lifesaving and fire fighting equipment, not previously replaced, must be replaced with Coast Guard approved equipment. Other equipment and systems should be addressed on a case-by-case basis.

Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Lifeboats — MANNING. The manning of all OSV's should be in accordance with applicable standards as

summarized in enclosure (1). The OCMI may consider other manning proposals based on statutory requirements and the vessel's route and conditions of operation. Inquiries on manning issues should be addressed to Commandant (G-MVP-4).

Initial and Subsequent Inspection of Existing, Uncertificated Offshore Supply Vessels, Including Lifeboats — IMPLEMENTATION.

a. Owners/operators of uncertificated OSV’s, including liftboats, should make application for inspection and certification to the cognizant OCMI in whose zone the vessel is operating. b. Existing, conventional OSV’s should have been initially inspected under NVIC 8-81. Self-elevating OSV's (liftboats) operating beyond the Boundary Line should have either been inspected or made application under NVIC 8-81, Change 1. Subsequent inspections may be accomplished as provided for in enclosures (2) & (3). This guidance is essentially the same for these vessels as provided in NVIC 8-81 or Change 1, as applicable. c. Self-elevating OSV's operating inside the Boundary Line should be inspected in accordance with the applicable guidance in enclosures (2) & (3). d. Conventional vessels, not previously inspected because they work in "Lakes, Bays, and Sounds" or other "inshore or inland" waters, must be inspected as required by P.L. 96- 378. The guidance in enclosure (2) may be used for this purpose. End: (1) Manning of Offshore Supply Vessels (2) Guidance Pertaining to the Inspection and Certification of Existing Offshore Supply Vessels Including Liftboats (3) Additional Guidance Pertaining to the Inspection and Certification of Existing Liftboats