Outer Continental Shelf National Center of Expertise (OCSNCOE)

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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.

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.

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) 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 (a typical example is on smaller platforms where the wellheads are accessed through the heli-deck) and is often a temporary arrangement. As such rails on these converted heli-decks may be of a temporary nature (e.g. constructed from scaffolding pieces as in typical offshore construction projects), as long as the temporary railing meets the intent and protection of the §143.110(a) requirements (heights, courses and securely fastened). The entire heli-deck does NOT need to be railed if the rail 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.

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.