Pro po sing a n a lte rna tive me tho d o f de mo nstra ting c o - - PowerPoint PPT Presentation

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 11th 2019

• 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
• rganisations 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
• f 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.

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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.

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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

• f 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.

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• 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.

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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.

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• Providing all the above criteria are met, the United States Coast Guard could

then issue the vessel’s Certificate

• f

Inspection (COI) based partly

• n

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.

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• 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.

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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

• f

both time and money by

• ffering

an alternative method

• f

compliance to contractors, as well as potential improvements to the safety of diving operations being undertaken from USCG regulated vessels.

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