INTERNATIONAL MARITIME ORGANIZATION

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IMO FSI 16/14/1 26 March 2008 Original: ENGLISH

SUB-COMMITTEE ON FLAG STATE IMPLEMENTATION 16th session Agenda item 14

REVIEW OF THE CODE FOR THE IMPLEMENTATION OF MANDATORY IMO INSTRUMENTS Applicability of IMO Conventions to FPSOs and FSUs Submitted by the International Association of Classification Societies (IACS)

SUMMARY Executive summary: Strategic Direction: High-Level Action: Planned Output: Action to be taken: Related documents: This paper provides the experiences and views of IACS on the applicability of some IMO Conventions to FPSOs and FSUs 2 2.1.1 2.1.1.5 Paragraph 11 MSC 83/28 and MSC 83/27/8

Background 1 The Maritime Safety Committee, at its eighty-third session (3 to 12 October 2007), requested the advice of the Sub-Committee with respect to the applicability of IMO Conventions to floating production, storage and offloading vessels (FPSOs) and floating storage units FSUs, before considering the establishment of any new work programme item (MSC 83/28, paragraph 27.23). 2 Recognizing that the Committee also requested the advice of the STW Sub-Committee with respect to the STCW Convention and that the applicability of all annexes of MARPOL 73/78 to FPSOs and FSUs is clear, this document comments on the application of the SOLAS and Load Lines Conventions.
For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

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3 When evaluating the applicability of SOLAS to FPSOs and FSUs, it is necessary to consider if the FPSO or FSU is capable of being mechanically propelled by its own means. In this regard, it is noted that there are two characterizations of FPSOs and FSUs: .1 non-disconnectable, whereby the FPSO/FSU is permanently moored and has no mechanical means of self-propulsion; and disconnectable, whereby the FPSO/FSU is capable of disconnecting from its moored position and has a mechanical means to transit by self-propulsion.

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Applicability of SOLAS 4 As per SOLAS regulation I/3(a)(iii), the Convention does not apply to ships not propelled by mechanical means. 5 Accordingly, SOLAS does not apply to non-disconnectable FPSOs and FSUs, but would, in principle, apply to disconnectable FPSOs and FSUs, as clarified in paragraph 6 below. However, it is noted that there exist two provisions in SOLAS which allow some deviation from the application of SOLAS to disconnectable FPSOs and FSUs: .1 under SOLAS regulation I/4(a), a ship, which is not normally engaged on international voyages but which, in exceptional circumstances, is required to undertake a single international voyage may be exempted by the Administration from any SOLAS requirements provided that it complies with safety requirements which are adequate in the opinion of the Administration for the voyage in question; and under Article IV of SOLAS, a ship, which is not subject to the provisions of the present Convention at the time of its departure on any voyage, shall not become subject to the provisions of the present Convention on account of any deviation from its intended voyage due to stress of weather or any other case of force majeure. It has been the experience of IACS Members that: .1 where an FPSO/FSU is required to transit under its own mechanical propulsion to a port (e.g., for dry docking), then there has been some discretion provided by Administrations under SOLAS regulation I/4(a) where the FPSO/FSU does not fully comply with all the current provisions of SOLAS. In such instances, the FPSO/FSO is in a ballast condition without any cargo on board;

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if an FPSO/FSU is in a situation where it must temporarily disconnect from the riser at the operating station for the minimum period necessary to ensure the safety of the vessel in extreme environmental or emergency conditions, then this operation is permitted, without full compliance with SOLAS, under Article IV of SOLAS; in cases where a dispensation from SOLAS requirements for hardware was granted by an Administration, it usually was with respect to an oil tanker converting to a FPSO/FSU and concerned the requirements of the following SOLAS regulations: .3.1 .3.2 .3.3 .3.4 II-1/3-3 on the safe access to tanker bows; II-1/3-4 on emergency towing arrangements on tankers; II-1/3-6 on permanent means of access for tank inspection; II-2/4.5 on cargo areas of tankers, access from cargo deck (for example, for location of turbines as this part of SOLAS prohibits any room (except stores for cargo handling equipment) from being located above the cargo tanks. Turbines are in this context used as an example of an installation that may have been accepted inside the cargo area of an FPSO that could not have been accepted in this area in accordance with SOLAS on a tanker); and V/22, Visibility requirements from bridge.

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Also, it has been the experience of IACS Members that, from time to time, Administrations do not always require compliance with the provisions associated with the ISM and ISPS* Codes, though some coastal States in whose jurisdictional waters the FPSO/FSU is stationed, may specify otherwise; and .4 additionally, some Administrations accept, in accordance with SOLAS regulation I/5, equivalent arrangements which comply with the Code for the Construction and Equipment of Mobile Offshore Drilling Units, 1989 (1989 MODU Code) recognizing that the Preamble of the Code states that the Code ensures a level of safety for such units, and for personnel on board, equivalent to that required by the International Convention for the Safety of Life at Sea. 1974, as amended, and the International Convention on Load Lines, 1966, for conventional ships engaged on international voyages.

Noting MSC 77/26 paragraph 6.67, MSC/Circ.1097 and MSC/Circ.1111.

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Applicability of the Load Lines Convention 7 Based on its Article 5(1), the Load Lines Convention applies to FPSOs and FSUs.

8 Although it is noted that, inter alia, there exist two provisions in the Load Lines Convention, which allow some deviation in a manner simlar to that described in paragraph 5 above, for SOLAS, it is the experience of IACS Members that such deviations have not generally been excercised by flag Administrations. IACS View Point 9 In reviewing document MSC 83/27/8 (ITF), IACS notes that ITF considered that an FPSO or FSU, which is capable and required to operate as a ship, should also be in compliance with the requirements of the ISM Code (and the minimum requirements of the STCW Convention) and that exemptions under SOLAS regulation I/4(a) should not be granted in this respect. 10 Based on the comments provided in paragraphs 3 through 8 above and noting the outcome of STW 39 (STW 39/12, paragraph 11.35), IACS agrees with the views reflected in paragraph 9 above, but considers that there is no compelling need to undertake the development of a set of requirements for the hardware aspects of FPSOs and FSUs (i.e., matters addressed by the Load Lines Convention and the relevant SOLAS chapters). Action requested of the Sub-Committee 11 The Sub-Committee is invited to note the information provided and take action as appropriate. _____________

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