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Fixed Platform Frequently Asked Questions (FAQs)

Please find  answers to commonly asked questions related to Fixed Facilities (Platforms) below.

Answers in this FAQ section are not a substitute for applicable legal requirements, nor are they rules (however, some questions may have an answer that comes directly from existing regulation or policy). The answers are not intended to require or impose legally binding requirements on any party. Answers provided represent the OCSNCOE’s current thinking, after researching existing regulations and policy, as well as consultation with Coast Guard Subject Matter Experts. These answers are intended to assist industry, mariners, the public, the Coast Guard and other regulators in applying statutory and regulatory requirements. When available, the FAQ will direct the reader to the official documents, such as the Federal Register, the Code of Federal Regulations or NVICs and policies. The answers provided are subject to change with regulatory or policy updates.

Regulatory Requirements

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Deficiencies or hazards found by the owner or operator during a facility self-inspection, will typically need to be corrected or eliminated within 30 days and prior to completion of Form CG-5432.

33 CFR 140.105(c), (d) and (e) stipulate the requirements associated with deficiencies discovered during a self-inspection. §140.105(c) states “Deficiencies and hazards discovered during an inspection of a fixed OCS facility under §140.103(a) must be corrected or eliminated, if practicable, before the form CG-5432 is completed [emphasis added].” §140.105(d) contains additional requirements for lifesaving and firefighting deficiencies that cannot be corrected prior to completion of Form CG-5432.

A review of comments associated with the Federal Register notices related to 33 CFR 140.105 further explain the 30-day period to correct deficiencies. Figure 1 (below) depicts a timeline for changes to this section.

53 FR 18981 published the Self-Inspection Program for Fixed OCS Facilities with timeframes discussed under comment #11 at 53 FR 18978:
The Coast Guard believes that it is not necessary to provide a timeframe for the correction of deficiencies in the regulations. With the expansion of the reporting period to 30 days, the vast majority of Forms CG-5432 will be submitted with no outstanding deficiencies. The owners/operators should be able to correct most deficiencies found during the inspections within the 30 day period allowed for submission of the report to the OCMI.[emphasis added]

67 FR 5916 published the Inspection Under, and Enforcement of, Coast Guard Regulations for Fixed Facilities on the Outer Continental Shelf by the Minerals Management Service. With this change, the requirement to submit a copy of the CG-5432 to the Coast Guard was eliminated and the requirement keep the latest two years of the form onboard/available (67 FR 5913, comment #1 to 33 CFR 140.103(c)) was implemented. This change also required the owner/operator to submit the completed CG-5432 that indicates outstanding deficiencies within 30 days after completion of the inspection to the appropriate MMS District office (updated to BSEE by 79 FR 36405), which will specify a time period for correction.

Figure 1: Changes to Fixed OCS Facility Inspection Requirements:
Changes to Fixed OCS Facility Inspection Requirements

For a deficiency found by a USCG or BSEE inspector, the inspector specifies the due date for correction of each deficiency.

33 CFR 140.105(b) states “Any deficiency or hazard discovered during an inspection by a Coast Guard marine inspector or a BSEE inspector is reported to the unit's owner or operator, who shall have the deficiency or hazard corrected or eliminated as soon as practicable and within the period of time specified by the inspector [emphasis added].”

These deficiencies do not have the 30-day timeframe like those of a CG-5432 facility self-inspection. It is up to the inspector to evaluate the deficiency and assign a timeframe for correction. It has been the policy of the USCG to allow no more than 30 days for these corrections. If the correction cannot be made within 30 days (or lesser time specified by the inspector), an extension must be requested.

Lifesaving Requirements

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Short answer: The equipment listed in 33 CFR 144.01-15. “The equipment required for a lifeboat is a bailer, boat hook, bucket, hatchet, lantern, life line, two life preservers, matches, full complement of oars and steering oar, painter, plug, and rowlocks, of the same type, kind, and character as required for lifeboats carried on vessels engaged in navigating bays, sounds, and lakes other than the Great Lakes, and rivers.”

Additional explanation: Lifeboats that are in service can be approved under approval series 160.035 (domestic only service) or 160.135 (SOLAS approved/international service). "035" boats are still in service, and can remain in service as long as they are maintained in a serviceable condition. These boats are no longer being manufactured and the regulations that governed their construction (46 CFR 160.035) were removed in the 2012 annual edition of the CFR. All current CG-Approved lifeboats are being built as "135" SOLAS boats under the provisions of 46 CFR 160.135.

For 160.035 lifeboats, a 2011 (or earlier) edition of 46 CFR 160 is needed for reference; for 160.135 lifeboats, 2012 (or later) editions of 46 CFR can be utilized. Annual editions of the CFR can be downloaded from gpo.gov/fdsys.

46 CFR 160.035 did not include equipment requirements for the lifeboats, as this was handled by the respective subchapter that the vessel (or facility) was inspected under (e.g. 33 CFR Subchaper N, 46 CFR Subchapters, I, I-A, W, etc.), based on the type of vessel/facility and the service and 'route' of that vessel. 46 CFR 160.135 incorporates the Life-Saving Appliances (LSA) Code, 2010 edition, by reference and the LSA does include the equipment list, as SOLAS boats are all intended for the same type of service. While the equipment requirements in 33 CFR 144.01-15 plainly apply to "035" boats, they also apply to the "135" boats as a CG approved deviation from the equipment carriage requirements incorporated by reference through 46 CFR 160.135.

The regulations in 33 CFR 144 haven't seen many changes from the original publishing in 1956 (and the equipment list still reads the same), but the 'intent' is that lifeboats on Fixed Platforms are an alternative to the primary lifesaving appliances, lifefloats, and minimal equipment is therefore allowed.

No, liferafts on fixed facilities may be arranged to float-free, but it is not required. Inflatable liferafts are required to be set-up similar to a life float for distribution and mounting (33 CFR 144.01-15(a) refers back to §144.01-5). The raft must be:

   a) Located in an accessible location, and
   b) Mounted on the outboard sides of the working platform in such a manner as to be readily launched.

Note that a “standard” inflatable liferaft rack (cradle) and straps are designed for use with a hydrostatic release, so adjusted/alternate straps may be necessary if the standard rack is utilized without the hydrostatic release.

No. 33 CFR 144.01-5, as referred to from §144.01-15(a), requires inflatable liferafts to be mounted on the outboard sides of the working platform in a manner as to be readily launched. Typically accepted arrangements that meet this criteria are with the liferafts mounted:

   1) Outboard of the rails,
   2) Above the rail, so not to require lifting over the rail to launch, or
   3) Between a rail opening or access provided explicitly for the purpose of liferaft launching (the arrangement must not leave excess gaps that do not meet the unprotected perimeter requirements for railing at 33 CFR 143.110(a)).

Inflatable liferafts are required to be serviced 12 months (annually) from the date of last servicing (i.e., date that the raft was "packed"), in accordance with 46 CFR 160.151-57, but there are allowances for new liferafts or liferafts that are stored in a controlled environment after servicing in accordance with 46 CFR 151-57(n).

A new liferaft may go up to two years before first servicing, after the date it was first packed, if:
   1) Dated survival equipment in the liferaft will not expire before the sticker expiration date; and
   2) The liferaft will not be installed on a vessel certificated under SOLAS.

The expiration date may be extended from the date a liferaft was serviced or first packed for a liferaft that has been stored indoors, under controlled temperatures (between 32°F and 113°F), up to the length of time that the liferaft remained in storage as follows:
   1) Up to 6 months with no additional actions, provided the storage requirements were met.
   2) Up to 12 months if the liferaft is opened, inspected, and repacked in an approved servicing facility. When the liferaft is opened, the condition of the liferaft must be visually checked and found to be satisfactory, the inflation cylinders must be checked and weighed, all expired survival equipment must be replaced and all undated batteries must be replaced.

Under normal circumstances there is no grace period for the servicing of liferafts. Liferafts have to be serviced by the last day of the month that is indicated on the expiration sticker attached to the liferaft container. While the servicing certificate issued by the servicing facility is required to include the date of servicing and repacking, it may or may not indicate the expiration date.

Liferaft servicing procedures can be found at 46 CFR 160.151-57. Excerpts related to marking, documentation and expiration are included below for ready reference.


§160.151-57(m) The servicing facility must complete the following for each liferaft that passes these inspections and tests:
   (1) Permanently mark the liferaft on its outside canopy, or on a servicing-record panel on an interior portion of one of its buoyancy tubes near an entrance, with—
      (i) The date of the servicing;
      (ii) The identification and location of the servicing facility; and
      (iii) If applicable, an indication that the special fifth-year servicing was performed.
   (2) Permanently and legibly mark on the identification device provided in accordance with §160.151-17(c), or on the outside canopy of the liferaft, the name, if known, of the vessel on which the raft will be installed or the name, if known, of the vessel owner.
   (3) Affix an inspection sticker to the liferaft container or valise. The sticker must be of a type that will remain legible for at least 2 years when exposed to a marine environment, and that cannot be removed without being destroyed. The sticker must be about 100 mm × 150 mm (4 by 6 inches), with the last digit of the year of expiration superimposed over a background color that corresponds to the colors specified for the validation stickers for recreational-boat numbers in 33 CFR 174.15(c), and be marked with the Coast Guard identifying insignia in accordance with the requirements of 33 CFR 23.12. The sticker must also contain the following:
      (i) The name of the manufacturer of the liferaft.
      (ii) The year and month of expiration determined in accordance with paragraph (n) of this section.
      (iii) Identification of the servicing facility, printed on the sticker or indicated on the sticker by punch using an approval code issued by the Commandant.

§160.151-57(n) The expiration date of the servicing sticker is 12 months after the date the liferaft was repacked, except that:
   (1) For a new liferaft, the expiration date may be not more than two years after the date the liferaft was first packed, if—
      (i) Dated survival equipment in the liferaft will not expire before the sticker expiration date; and
      (ii) The liferaft will not be installed on a vessel certificated under SOLAS.
   (2) For a liferaft stored indoors, under controlled temperatures (between 0 °C (32 °F) and 45 °C (113 °F)), for not more than 6 months from the date it was serviced or first packed, the expiration date may be extended up to the length of time the liferaft remained in storage.
   (3) For a liferaft stored indoors, under controlled temperatures (between 0 °C (32 °F) and 45 °C (113 °F)), for not more than 12 months from the date it was serviced or first packed, the expiration date may be extended up to the length of time the liferaft remained in storage, if the liferaft is opened, inspected, and repacked in a servicing facility approved in accordance with §§160.151-49 and 160.151-51. When the liferaft is opened—
      (i) The condition of the liferaft must be visually checked and found to be satisfactory;
      (ii) The inflation cylinders must be checked and weighed in accordance with paragraph (b)(12) of this section;
      (iii) All survival equipment whose expiration date has passed must be replaced; and
      (iv) All undated batteries must be replaced.

§160.151-57(p) The servicing facility must issue a certificate to the liferaft owner or owner's agent for each liferaft it services. The certificate must include—
   (1) The name of the manufacturer of the liferaft;
   (2) The serial number of the liferaft;
   (3) The date of servicing and repacking;
   (4) A record of the fifth-year gas-inflation test required in paragraph (g) of this section, whenever that test is performed;
   (5) A record of the hydrostatic test of each inflation cylinder required in paragraph (e) of this section, whenever that test is performed;
   (6) A record of any deviation from the procedures of the manufacturer's servicing manual authorized by the OCMI in accordance with §160.151-53(d);
   (7) The identification of the servicing facility, including its name, address, and the approval code assigned by the Commandant in accordance with §160.151-51;
   (8) The name, if known, of the vessel or vessel owner receiving the liferaft; and
   (9) The date the liferaft is returned to the owner or owner's agent.

Operational Requirements

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Heli-decks that are converted into work decks no longer meet the exemptions afforded by 33 CFR 143.110(b) and must meet the intent of §143.110(a) and (c) while being utilized as a work deck/work area.

Converting a heli-deck to a work deck may occur as part of a maintenance project (e.g. used to provide access to well heads or stage equipment for maintenance/workover operations) and is often a temporary arrangement. As such, the railing for a temporary conversion to a work deck can also be temporary in nature (i.e. constructed from scaffolding rails and clamps), as long as it meets the height and intermediate rail requirements of §143.110(a) and provides adequate protection for the personnel that will be working on the deck. The entire heli-deck does NOT need to be railed if the arrangement provides protection to personnel for the area/portion of the heli-deck that is being utilize as a work deck.

BSEE inspectors are verifying work deck railing arrangements in accordance with Z-PINCs 135 and 140.

Additional discussion:
33 CFR 143.110(a) requires guards, rails or fencing around the unprotected perimeter of all floor and deck areas and openings. §143.110(c) requires suitable guards and rails for each stairway and catwalk. Helicopter landing decks are allowed alternate means of perimeter protection per §143.110(b), which is typically accomplished via horizontal skirting and/or fencing/netting.

The deviation from the general railing requirements of 33 CFR 143.110(a) and (c) are allowed for heli-decks to facilitate aircraft operations and provide a safe area for helicopter landing with minimal obstructions. If/when a heli-deck is converted to a work deck, the heli-deck is no longer capable of supporting helicopter operations and must be outfitted with suitable railing around the perimeter of the work area and stairway openings. The skirting/fencing and open stairways allowed by §143.110(b) for do not provide adequate protection for workers that may be preoccupied with other tasks while working on a converted heli-deck.

Other than numbering changes, the guards and rails section, as currently published at 33 CFR 143.110, has not changed since initially published as §143.15-1 and 143.15-5 on February 9, 1956. Comments were received in conjunction with the March 4, 1982 revisions to 33 CFR Subchapter N and recommended substantive changes to include §143.110 (see 47 FR 9372), but no changes have been affected to date.

Short answer: No, the gangway to a liftboat that is jacked up alongside a fixed platform can be used as an additional means of escape, but cannot be used in lieu of the means of escape required by 33 CFR 143.101.

While a gangway from the liftboat to the platform may serve as the main pathway between the two units during the intended operations, manned and unmanned OCS facilities must be provided with the number and arrangement of primary and secondary (if applicable) means of escape required by 33 CFR 143.101.

Any deviation from the primary and/or secondary means of escape requirements (i.e. damaged by weather, removed in conjunction with decommissioning activities) must be requested and approved through the Officer in Charge, Marine Inspection.

Required means of escape from a fixed OCS facility are summarized below (as associated with manned and unmanned scenarios by 33 CFR 143.101):

Manned OCS Facility (manned facility and manned platform are defined under 33 CFR 140.10 as “people are routinely accommodated for more than 12 hours in successive 24 hour periods”):
   • Two (2) primary means of escape from the uppermost level that contains living quarters or that personnel continuously occupy, and
   • One (1) primary means of escape from working levels without living quarters, shops or offices in structural appendages, extensions and installations that personnel only occupy occasionally and one or more secondary means of escape when required by the Officer in Charge, Marine Inspection (OCMI) from such areas

Unmanned OCS Facility (unmanned facility and unmanned platform are defined under 33 CFR 140.10 as a facility “which is not a manned facility even though it may be continuously serviced by an attending vessel”):
   • One (1) primary means of escape from the uppermost working level, and
   • One (1) secondary means of escape when personnel are onboard for every 10 persons onboard, excluding facility appendages and installations unless required by the Officer in Charge, Marine Inspection (OCMI)

All means of escape shall extend from the uppermost level specified, to each successively lower working level and to the water surface and be suitably accessible for rapid facility evacuation. When two or more means of escape are installed, at least two shall be as nearly diagonally opposite of each other as practical.

Financial Responsibility

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Short answer:
Fixed OCS Facilities and FOFs are required to demonstrate OSFR and MODUs are required to carry a COFR for a tank vessel or a non-tank vessel based on its operation.

Further discussion:
The requirements for an OSFR are found in 30 CFR 553 and the requirements for a COFR are found in 33 CFR 138.

This is based on 30 CFR 553.10:
(a) This part applies to any COF [Covered offshore facility] on any lease or permit issued or on any RUE [Right-of-use and easement] granted under the OCSLA or applicable State law.
(b) For a pipeline COF that extends onto land, this part applies to that portion of the pipeline lying seaward of the first accessible flow shut-off device on land.

Covered Offshore Facility (COF) in 30 CFR 553.3 means a facility:
(1) That includes any structure and all its components (including wells completed at the structure and the associated pipelines), equipment, pipeline or device (other than a vessel or other than a pipeline or deepwater port licensed under the Deepwater Port Act of 1974 (33 U.S.C. 1501 et seq.)) used for exploring for, drilling for, or producing oil or for transporting oil from such facilities. This includes a well drilled from a mobile offshore drilling unit (MODU) and the associated riser and well control equipment from the moment a drill shaft or other device first touches the seabed for purposes of exploring for, drilling for, or producing oil but it does not include the MODU; and…,

33 CFR 138.15(b) states:
For the purposes of financial responsibility under OPA 90, a mobile offshore drilling unit is treated as a tank vessel when it is being used as an offshore facility and there is a discharge, or substantial threat of a discharge, of oil on or above the surface of the water. A mobile offshore drilling unit is treated as a vessel other than a tank vessel when it is not being used as an offshore facility,

33 CFR 138.230(d) states:
Offshore facilities. The OPA 90 limit of liability or offshore facilities other than deepwater ports, including for any offshore pipelines, is set forth at 30 CFR 553.702.

OSFR and COFR Applicability
  Oil Spill Financial Responsibility Certificate of Financial Responsibility
Mobile Offshore Drilling Unit No Yes
Floating OCS Facility Yes No
Fixed OCS Facility Yes No