Making way vs not making way

The DWH hearings have got my brain thinking, a bad thing I know.

I know this has been covered here before but this time I want to forget the MODU code and other regulatory nonsense. I’m just talking about nautical definitions.

Here are my questions:

  1. Again, forgetting regulatory nonsense, can we all agree the Horizon was underway?

  2. If so, and assuming there is always some amount of current, was it making way or not making way?

For the last question you do have to consider the MODO code and other regulatory nonsense:

  1. The Marshal Islands has three designations for MODU’s; moored to the bottom, self propelled and DP (it does not specify the difference between a semi and a drillship). The DWH was classed as self-propelled (I think we can all agree that it was) but wasn’t it also Dynamically Positioned and thus should have been classed under the more stringent safe manning requirements of a DP vessel?

I have always been taught that a self-propelled modu was one that’s moored on location but has propellers to move itself between locations. Like the drillships that are moored but have two traditional propellers. If so then wasn’t the DWH, and most currently operating Transocean rigs, classed wrongly??

[QUOTE=cmjeff;35399]The DWH hearings have got my brain thinking, a bad thing I know.

I know this has been covered here before but this time I want to forget the MODU code and other regulatory nonsense. I’m just talking about nautical definitions.

Here are my questions:

  1. Again, forgetting regulatory nonsense, can we all agree the Horizon was underway?

  2. If so, and assuming there is always some amount of current, was it making way or not making way?

For the last question you do have to consider the MODO code and other regulatory nonsense:

  1. The Marshal Islands has three designations for MODU’s; moored to the bottom, self propelled and DP (it does not specify the difference between a semi and a drillship). The DWH was classed as self-propelled (I think we can all agree that it was) but wasn’t it also Dynamically Positioned and thus should have been classed under the more stringent safe manning requirements of a DP vessel?

I have always been taught that a self-propelled modu was one that’s moored on location but has propellers to move itself between locations. Like the drillships that are moored but have two traditional propellers. If so then wasn’t the DWH, and most currently operating Transocean rigs, classed wrongly??[/QUOTE]

I think that you are absolutely right, a DP vessel is underway at all times. During the hearings both the USCG Captain and one of the lawyers agreed on that too, as a matter of fact the latter argued quite a lot about it. Moreover, isn’t the sea time on a DP Vessel recognised by the USCG based on the assumption that she is underway at all times? Next question is, who is in charge of a vessel underway, a licensed Master Mariner or a holder of an industrial endorsement (read OIM) ?

[QUOTE=cmjeff;35399]The DWH hearings have got my brain thinking, a bad thing I know.
I have always been taught that a self-propelled modu was one that’s moored on location but has propellers to move itself between locations. Like the drillships that are moored but have two traditional propellers. If so then wasn’t the DWH, and most currently operating Transocean rigs, classed wrongly??[/QUOTE]

Where are there designations for MODU’s in the Marshall Island rules? The CG and Customs considers the vessel “on location”. They wouldn’t even bother to inspect the Bridge equipment like you would on another Port State Control exam.

The DWH actually had more requirements than a TOI drillship because she had to have a Barge Sup (the Chief Mate) and two BCO’s (the DPO’s) on location. I don’t think a drillship needs anyone on the Bridge with a license when “on location” They also added an extra mate when u/w when they switched from Panama flag.

The drillship I’m on now is Marshall Islands and the SMD only has underway. There’s no dual manning.

IMHO…would appear the “experts” have managed to conveniently ignore/omit an “operative” word here…“underway making way-underway not making way”…UNDERWAY!!..the rest is BULL SHIT!

[QUOTE=Orniphobe;35432]Where are there designations for MODU’s in the Marshall Island rules? The CG and Customs considers the vessel “on location”. They wouldn’t even bother to inspect the Bridge equipment like you would on another Port State Control exam.

The DWH actually had more requirements than a TOI drillship because she had to have a Barge Sup (the Chief Mate) and two BCO’s (the DPO’s) on location. I don’t think a drillship needs anyone on the Bridge with a license when “on location” They also added an extra mate when u/w when they switched from Panama flag.

The drillship I’m on now is Marshall Islands and the SMD only has underway. There’s no dual manning.[/QUOTE]

The last drillship I was on was MI, we had a requirement of a Master (unlimited), Chief Mate and Second Mate while “on location”.

[QUOTE=Orniphobe;35432]Where are there designations for MODU’s in the Marshall Island rules?[/QUOTE]

MI document7-038-2.

The DWH was manned under schedule A (on page 6) which pertains to Self Propelled Mobile Offshore Drilling Units. But (in my opinion) she should have been manned under schedule DPV (page 7 of the document).

Like I said, Self Propelled MODU is one that’s moored while on location BUT has propulsion to move herself between locations. The DWH stayed on location via DP so she should have been manned under Schedule DVP… NOT schedule A.

I could be wrong (just trying to figure it out for my ship)?

I agree with you on the safe manning front BUT which nav lights should be displayed by a MODU on location?

Orniphone has quoted the MODU code where it states:

14.7 Safety of navigation
14.7.1 The requirements of the Convention on the International Regula- tions for Preventing Collisions at Sea in force should apply to each unit except when stationary and engaged in drilling operations.
14.7.2 Each unit when stationary and engaged in drilling operations should comply with the requirements for the safety of navigation of the coastal State in whose territorial sea or on whose continental shelf the unit is operating.

Coastal state rules (the CFR’s) mention obstruction lights for MODU’s on location… But if she is, in fact, underway-making way… then, according to costal state rules, she has to show running lights. Right?

[QUOTE=cmjeff;35480]Coastal state rules (the CFR’s) mention obstruction lights for MODU’s on location… But if she is, in fact, underway-making way… then, according to costal state rules, she has to show running lights. Right?[/QUOTE]

See below email, I had to dig for. After the TOI / RBF merger, the Captain I worked for at the time had me ask about manning (because I could speak Coast Guard). RBF had all licensed mates for DPO’s, on this ship at least. I later got in trouble with TOI when the Rig Manager got ahold of it. This is the only thing I have from them although I’ve asked several inspectors.

" “Cushing, John LCDR” JCushing@d8.uscg.mil
SMTP Normal Normal
FW: Drillship question

******, One additional comment: I understand that for a drillship with
DP, the COI (or Safe Manning Document if foreign flag) will usually include
different manning requirements for ““On Location””, ““Voyages under 72 hrs””,
and ““Voyages over 72 hrs””. Obviously, the manning requirements for ““On
Location”” would be the appropriate ones to follow when operating on location in
DP mode.

John M. Cushing Jr.
Lieutenant Commander, USCG
Chief, Merchant Vessel Safety (& Chief, Offshore Compliance)
Eighth Coast Guard District - D8(mvs)
Phone:
Fax:

-----Original Message-----
From: Cushing, John LCDR
Sent: Friday, April 19, 2002 10:49 AM
To:
Cc:

Subject: RE: Drillship question

******, I walked over to our legal office this morning and
found they had completed their research on this issue and made a legal
determination, based largely upon a U.S. Customs ruling from 1985. Regarding
lights, they determined that when a dynamically positioned drillship has a drill
string down into the seafloor (is attached to the wellhead) it is ““in contact
with the seabed of the OCS”” and is considered an ““OCS facility”” and should
display the obstruction lights prescribed in 33 CFR 67.05. However, when it does
not have a drill string down into the seafloor (is not attached to the wellhead)
then it should be considered a vessel and display appropriate navigation lights
in accordance with the International Regulations for Preventing Collisions at
Sea (COLREGS), 1972.

Regarding manning, regardless of whether or not the
drillship has a drill string down into the seafloor it must be manned in
accordance with its Certificate of Inspection (or Safe Manning Document if it is
foreign flag).

Futhermore, I would consider a vessel (or even a ““floating OCS
facility””) that is being held on station by a dynamic positioning system to be
"“underway”", regardless of whether or not it had a drill string down into the
seafloor, and it should be manned accordingly.

Hope this helps, let me know if
you need any further clarification on this issue.

John M. Cushing Jr. Lieutenant
Commander, USCG
Chief, Merchant Vessel Safety (& Chief, Offshore Compliance)
Eighth Coast Guard District - D8(mvs)

Thanks for this. I believe that it supports my argument, expressed in a different post, that a DP vessel for custom purposes is considered in location when engaged in drilling activities, however she is “underway” as is being held on station by a dynamic positioning system, thus she must be manned accordingly.

With this rationale, a DP vessel can never be “On location”?

This begs the question…why does class/flag/company have a different manning underway vs on location?

The USCG makes a statement like this, and then turns a blind eye for 15 years?

[QUOTE=bnhpr;35578]With this rationale, a DP vessel can never be “On location”?
[/QUOTE]

That’s not the way I read it. Once you’re on location, you’re an OCS Facility and the COLREGs don’t apply and alternate manning can kick in. Therefore their definition of underway isn’t relevant.

I don’t like it, but that’s what it says. I hope the USCG and IMO put this issue to rest.

A DP Vessel is considered “on location” exclusively for custom purposes, she is however underway while “on location”.

The flag state have a different manning level because that is a carry over from Jack Up’s and moored semi, as when “on location” they are not underway and thus with reduced manning. Also, bear in mind that Flag States issue the Minimum Safe Manning based merely on the owner’s request. This is a fact, from personal experience. How could it be that the DWH, a fully DP Vessel, did not have a requirement of a Master when “on location”? Where was the control by the Flag State?

About the USCG blind eye, I would also like to hear their explanation; again the answer could be “those boys know what they are doing”… not quite so I am afraid. It was shocking to watch the hearings where there was a display of a complete lack of knowledge about ISM Code, MARPOL, COLREG, etc by “those boys” sitting in the offices and running multi-millions dollars operations AT SEA… pretty sad, actually.

[QUOTE=CaptVal;35619]A DP Vessel is considered “on location” exclusively for custom purposes, she is however underway while “on location”.

The flag state have a different manning level because that is a carry over from Jack Up’s and moored semi, as when “on location” they are not underway and thus with reduced manning. Also, bear in mind that Flag States issue the Minimum Safe Manning based merely on the owner’s request. This is a fact, from personal experience. How could it be that the DWH, a fully DP Vessel, did not have a requirement of a Master when “on location”? Where was the control by the Flag State?

About the USCG blind eye, I would also like to hear their explanation; again the answer could be “those boys know what they are doing”… not quite so I am afraid. It was shocking to watch the hearings where there was a display of a complete lack of knowledge about ISM Code, MARPOL, COLREG, etc by “those boys” sitting in the offices and running multi-millions dollars operations AT SEA… pretty sad, actually.[/QUOTE]

If there is any positive outcome at all, with regard to marine licensing, qualifications and the human factors, I’ll be surprised. It’s off the radar with the general public.

I’m all too familiar with Flag of convenience minimum manning, and how sadly, they stay right at the minimum.