OCSNCOE Unit Emblem (silhouettes of a self-elevating MODU, an OSV and an offshore wind turbine over a silhouette of the United States with the U.S. Coast Guard mark (i.e., racing stripe) in the background).Outer Continental Shelf National Center of Expertise (OCSNCOE)

JACK ST. MALO during offshore construction with attending OSV and Floatel VICTORY. C-ENFORCER underway with water cannons flowing. SEVAN LOUISIANA underway when initially entering the U.S. Gulf of Mexico. Platform GINA off the California coast. Block Island windfarm with attending CTV. SPARTAN 151 dockside in Seward, AK.



Additional OCS & Coast Guard-Related Info Menu


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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 1) How much time is allowed to correct deficiencies found during a facility self-inspection (CG-5432)?

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 for 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 to 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

Published 07Oct2019. Updated 23Mar2023.

 2) How much time is allowed to correct deficiencies found during an inspection by a USCG or BSEE inspector?

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 are not tied to the completion of a CG-5432 like those found by the owner/operator during a facility self-inspection. It is up to the inspector that discovers the deficiency to assign a timeframe for correction. If the correction cannot be made within the time specified by the inspector, an extension must be requested through the issuing agency.

Published 07Oct2019. Updated 28Mar2023.

Lifesaving Requirements
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 1) What equipment is required to be carried in a lifeboat on a Fixed Platform?

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."

Discussion: 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 govinfo.gov.

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 Subchapter N, 46 CFR Subchapters, I, I-A, W, etc.), based on the type of vessel or 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.

Published 15Nov2018.

 2) Are liferafts on fixed facilities required to be float-free?

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.

Published 15Jun2020.

 3) Are liferafts on fixed facilities required to be mounted outside of the rails?

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 these 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. This arrangement must not leave excess gaps that do not meet the unprotected perimeter requirements for railing at 33 CFR 143.110(a).

Published 15Jun2020.

 4) What are the requirements for servicing an inflatable liferaft on a fixed facility? Is there a grace period for their servicing?

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 servicing 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 servicing 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.

Published 15Jun2020.

§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.

 5) Can expiring items in a USCG-approved or USCG-accepted First Aid Kit be replaced individually, rather than replacing the kit in its entirety?

Short answer: A first aid kit, whether a prior CG-approved kit or a newer self-certified to ISO standard kit, does NOT have to be in an unopened condition (i.e., sealed outer wrapper) AND items with expirations can be replaced individually. Read on for more information.

The U.S. Coast Guard published a change in type approval requirements for survival craft equipment as a "final rule" in the Federal Register (FR) via 87 FR 68270 on November 14, 2022, with the rule becoming effective on December 14, 2022. The final rule removed CG type approval requirements for nine types of survival craft equipment, including first aid kits, and replaced them with the requirement that the manufacturer self-certify that the equipment complies with a consensus standard. The Office of Design and Engineering Standards (CG-ENG) summarized the changes via Marine Safety Information Bulletin (MSIB) 07-22, dated November 14, 2022.

First aid kits that were previously required to comply with the type approval requirements of 46 CFR 160.041 now have to comply with ISO 18813:2006, Ships and marine technology - Survival equipment for survival craft and rescue boats. First, we will address first aid kits complying with the referenced ISO standard, and then we will address existing CG-approved kits.

First Aid Kits complying with ISO 18813:2006

ISO 18813:2006, nor USCG regulations related to first aid kits, require the entire kit to be "unopened". As shown in 4.12.1 of the standard, the first aid kit must be packed in a waterproof case that can be "closed tightly after use". 4.12.2 deals with the expirations and how they must be marked on the container or visible through the container.

“4.12.1 The first-aid outfit shall be packed in a waterproof case capable of being closed tightly after use, and the contents shall be approved by the Administration to the appropriate national requirements for the craft in which it is carried. The first-aid outfit shall include the following items, plus any other items required by the Administration:

a. waterproof container;
b. first-aid instructions;
c. analgesic medication - 48 doses minimum;
d. antiseptic preparations - suitable for at least 10 applications;
e. burn preparations - suitable for at least 12 applications;
f. adhesive plasters - 20 minimum in assorted sizes;
g. sterile compression bandage - 10 minimum in assorted sizes;
h. adhesive elastic bandages - 4 m minimum;
i. sterile gauze compresses - 2 minimum;
j. triangular bandages - 2 minimum.

4.12.2 If the first-aid outfit contains expiry-dated items, the date of expiry shall be marked on the outside of the waterproof container, or visible through the container.”

Replacement of individual, expired items is not mentioned in the body of the standard, but it is addressed in Annex A (informative) to the standard: "Maintenance and periodic inspection guidelines". A.2.7 addresses the first aid kit items. Note that A.2.7.1 states that each unit carton within the first aid kit should be in an "intact waterproof package" and A.2.7.2 provides for the individual replacement of expired items.

“A.2.7.1 During periodic shipboard inspections, first-aid outfits not packed in inflatable liferafts should be examined to ensure that they contain all of the items listed in the provided instructions. Each unit carton should be in an intact waterproof package. If it is not, it should be replaced with an equivalent waterproof unit from a supplier of approved first-aid outfits.

NOTE   Standard cellophane-wrapped unit cartons are not waterproof.

A.2.7.2 Any dated medications in the outfit should be replaced during periodic stripping and cleaning of the lifeboat, rescue boat, or rigid liferaft if their expiry date has passed.

NOTE   First-aid outfits packed in inflatable liferafts are inspected during required servicing of the liferaft by an approved service station.

Existing USCG-Approved First Aid Kits

As stated in the notice of the final rule for the changes to type approval (87 FR 68270), "The Coast Guard is not requiring existing vessels to replace their current kits; however, existing vessels must replace medication and ointments within the kits by their expiration date." (See https://www.federalregister.gov/d/2022-23666/p-186)

Replacement of individual, expired components have been acceptable to maintaining the kit as evidenced by previous information promulgated by the Office of Commercial Vessel Compliance (CG-CVC) in the Top 10 Small Passenger Vessels (Subchapter T) Deficiencies report on their website (excerpt pasted below; see last sentence).

Expired first aid kit medication excerpt from the Small Passenger Vessel Top 10 deficiency report.

The last publishing of the CG type approval requirements for CG-approved first aid kits can be viewed in the 2022 annual edition of the CFR at 46 CFR Part 160, Subpart 160.041. These previous regulations did not have any specific expiration marking requirements but did specify that individual cartons "shall contain all information required by Federal and State laws" (46 CFR §160.041–4). Separate regulations, such as those in Title 21, Code of Federal Regulations, would stipulate the expiration dates to be marked for medications that are determined by drug product stability testing.

Safety distributors have seen a recent change in the expiration of first aid kit items where some expirations have decreased from 3 years to 1 year. The CG mentioned varied expirations in the FR notice where "The expiration date of OTC [over the counter] medications is typically between one and five years after manufacture." (See https://www.federalregister.gov/d/2022-23666/p-81).

As mentioned in the final rule, and should have been common practice, these previously approved kits can continue to be used if expired items and opened/used cartons are replaced to maintain the kit in 'good condition' and ready to serve the intended purpose.

NOTE: While the FR did not specifically update the First Aid kit verbiage in 33 CFR 144.01-30, CG-ENG is aware and has noted that all of the same guidance applies to units subject to the Lifesaving requirements of 33 CFR Subchapter N, Part 144, Subpart 144.01. First aid kits will no longer be marked as CG-approved after a manufacturer’s “Certificate of Approval” (which provides for the marking of a CG type approval number to a tested and approved product) issued by the CG expires.

Published 19Mar2024.

Operational Requirements
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 1) What is the railing requirement when a heli-deck is converted into a work deck?

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 utilized 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) 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.

Published 10Dec2018.

 2) Can a liftboat gangway be utilized as a primary means of escape from a fixed platform?

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.

Discussion: 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.

Published 03Jun2019.

Emergency Evacuation Plans
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 1) Is the EEP drill required by 146.125(c)(1) required to be completed once per calendar year or once every 12 months?

Short answer: Once every 12 consecutive months.

Discussion: All elements of the EEP must be exercised through a drill or series of drills on an annual basis.

33 CFR 146.125(c)(1)"At least once a year, all the elements of the Emergency Evacuation Plan (EEP) under §146.140 relating to the evacuation of personnel from the facility must be exercised through a drill or a series of drills. The drill(s) must exercise all of the means and procedures listed in the EEP for each circumstance and condition described in the EEP under §146.140(d)(9)."

The wording is for a "year", rather than a "calendar year", and should be interpreted to mean a 12 consecutive month period. The EEP drill requirements were not part of the proposed rule (24Dec1987), but were added in the final rule (18May1989) as a response to industry comments as published at 54 FR 21568 where it was described as "annually":

"Four comments stated that the EEP regulations should contain a requirement for periodic evacuation drills. The comments stated that periodic interactive drills that test and exercise all the key elements of the EEP are needed to verify that the plan continues to be viable.
The Coast Guard agrees that the periodic drills are necessary to ensure that all personnel are familiar with the EEP. Therefore, a new § 146.125(c) has been added to require that abbreviated EEP drills be held monthly and that a comprehensive drill exercising all elements of the EEP be conducted annually. Also, a new § 146.140(e)(3) has been added to require the operator to ensure that the drills are conducted."

While some USCG operational regulations are specifically worded as a 12-month period, the majority of the types of USCG regulations are categorized as annual or "once in each year" and are treated as a consecutive 12-month period for compliance purposes. A once per "calendar year" requirement could give an extended window of time that would be outside of the intent of periodic training. As an example, a drill in Jan2019 followed by the next drill in Dec2020 could satisfy a once per calendar year requirement, but would clearly exceed the intent of annual, or once a year, training with nearly 24-months passing between drills.

Published 07Oct2021.

 2) What is an "element" of an Emergency Evacuation Plan (EEP) that is referenced in 33 CFR 146.125(c)(1)? Does the annual drill include all equipment (i.e., lifeboats) listed in the EEP?

Short answer: Elements are the components that make up the EEP and yes, the annual drill includes "all" equipment that is listed in the EEP.

Discussion: The phrase "all elements of the Emergency Evacuation Plan" as listed in the emergency drill requirements has often been questioned as to what it really means. Let’s take a look…

33 CFR 146.125(c)(1): "At least once a year, all the elements of the Emergency Evacuation Plan (EEP) under §146.140 relating to the evacuation of personnel from the facility must be exercised through a drill or a series of drills. The drill(s) must exercise all of the means and procedures listed in the EEP for each circumstance and condition described in the EEP under §146.140(d)(9)." [emphasis added]

The term "element" was added to the regulation with the final rule (published 18Mar1989) by the USCG in an effort to address industry comments to the proposed rule (published 24Dec1987).

Please note that the first sentence in the cite states "elements of the EEP under §146.140 relating to the evacuation of personnel from the facility". The requirements of the EEP relating to personnel evacuation are detailed in §146.140(d)(9) through (12) and include recognized circumstances that would place the facility or its personnel in jeopardy and for which a mass evacuation would be recommended. Fires, blowouts, approaching hurricanes and ice floes are specifically mentioned as examples of circumstances that would recommend an evacuation and collisions are another circumstance that is often included in typical EEPs that would initiate an evacuation.

The second sentence in the referenced cite states that "the drill(s) must exercise all of the means and procedures listed in the EEP for each circumstance" [emphasis added] to further stipulate what is required to satisfy the drill requirement.

Means and procedures are listed at §146.140(d)(12) as those for:

  1. retrieving persons from the water during an evacuation;
  2. transferring persons from the facility to the designated type of evacuation method (e.g. designated standby vessels, lifeboats or other evacuation craft);
  3. retrieving persons from the evacuation craft that they were transferred to in the previous requirement; and
  4. the ultimate evacuation of all persons to land, another facility or other location reasonably out of danger for the specific circumstance for the evacuation.

The District Eight OCS OCMI (responsible for the OCS activities on the U.S. OCS in the Gulf of Mexico) has interpreted §146.125(c)(1) "to mean that all lifeboats aboard a facility, shall, at a minimum, be launched with assigned lifeboat crew in order to fulfill the requirements of the annual emergency evacuation drill" in section 5, paragraph a, of D8(OCS) Policy Letter 01-2020, dated 19May2020. The policy letter goes on to discuss alternatives to this requirement in paragraphs 5.d through 5.f.

In the context of lifeboats/capsules, some have questioned if there is a need to test "all" of the boats for units or facilities with multiple boats, or if demonstrating the means and procedures with one, or a sampling of boats, would satisfy the intent. Note that the referenced cite states "all of the means and procedures" and the D8 OCS OCMI has reiterated this in Policy Letter 01-2020.

Also note that while the focus tends to be on lifeboats with this annual requirement, the cite requires exercise of all of the means and procedures for each circumstance that are stipulated in the EEP.

Published 07Oct2021.

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 1) Is a fixed OCS facility, floating OCS facility (FOF) or a Mobile Offshore Drilling Unit (MODU) required to demonstrate Oil Spill Financial Responsibility (OSFR) and/or hold a Certificate of Financial Responsibility (COFR)?

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.

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 138.20(b) states:
For the purposes of applying the evidence of financial responsibility required under OPA 90 and this subpart and the limits of liability set forth in subpart B of this part, and in addition to any OPA 90 offshore facility evidence of financial responsibility requirements that may apply under 30 CFR part 553, a mobile offshore drilling unit is treated as -
   (1) A tank vessel when it is being used as an offshore facility; and
   (2) 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





Published 08Oct2020; cites updated 01Jul2022 to reflect 01Dec2021 amendments to 33 CFR Part 138.

 2) Does an FOF need to obtain or maintain a COFR before it arrives on location and BOEM's OSFR requirements take effect (i.e., during "tow-out")?

Short answer: FOFs that have been determined not to be vessels by the OCMI are not subject to the COFR requirements of 33 CFR Part 138.

Discussion: The question of whether a COFR applies to an FOF during the "tow-out" of the FOF from the quayside facility/construction yard to the installation location on the OCS has been a longstanding question. The Coast Guard revisited this question with internal discussions between the National Pollution Funds Center (NPFC), Headquarters and District Eight legal offices, District Eight OCS OCMI staff and the OCSNCOE during February of 2023.

Research and discussion affirmed that the COFR requirements imposed by the Oil Pollution Act of 1990 (OPA 90), 33 U.S.C. 2701-2761, and 33 CFR Part 138 that implements COFR requirements apply to vessels. Therefore, if an FOF is determined not to be a vessel, as evidenced by the issuance of a non-vessel determination letter in accordance with CG-OES Policy Letter 01-22, the requirements of 33 CFR Part 138 do not apply to these facilities during the tow-out phase of their construction and installation.

Note that the definitions in 33 U.S.C. 2701 and 33 CFR Part 138.220 are specific in regard to "vessels" and types of facilities and are essential to the applicability of a COFR. These definitions differ from more inclusive definitions of "ship" (i.e., vessel) in 33 CFR Subchapter O and MARPOL.

This non-applicability only applies to the USCG's COFR regulations and requirements if the facility is determined to be a non-vessel. The OSFR is a separate coverage found in BOEM regulations at 30 CFR 553 and provides financial responsibilities associated with the lease and lease-related operations.

NPFC issues a COFR to vessels in accordance with 33 U.S.C. 2716(a) and the regulations that implement the statute. OCS facilities (i.e., offshore facilities) have their own set of requirements under 33 U.S.C. 2716(c).

If an FOF is determined to be a vessel, a COFR would apply and a further determination of the correct limit of liability would need to be considered. This would be in addition to any OSFR requirements for OCS facilities that are determined to be vessels.

Published 14Mar2023.

Navigational Aids
Collapse All Expand All
 1) Do obstruction lights need to be level and "focused"?

Short Answer: Yes.


Note: This answer is based on conventional incandescent-type light assemblies. Manufacturer’s instructions should be consulted for LED lanterns or retrofits to ensure compliance with advertised/intended characteristics and range.

Part 1: Leveling

The "ridges" of the Fresnel lens found on obstruction lights serve a very important purpose. These ridges condense the light to the center of the lens and send out a type of light beam to meet the required range. The range or visible distance for offshore structures depends on the structure classification and are summarized as follows (see 33 CFR 67.01-15 for requirements/information related to the classification of structures):

Class "A" structure - visible distance of at least 5 nautical miles (33 CFR 67.20-5).
Class "B" structure - visible distance of at least 3 nautical miles (33 CFR 67.25-5(a)).
Class "C" structure - visible distance of at least 1 nautical mile (33 CFR 67.30-59(a)).

If the light is not level the focal plane will either be above or below the vessel. Either condition could reduce the required range, resulting in non-compliance with regulations and not meeting charted characteristics. See the graphical depiction below.

Graphic depicting focal planes of level and non-level aids to navigation lanterns

The leveling of the lantern can be checked via the built-in bubble levels of some lanterns or with the method displayed below (utilized by U.S. Coast Guard short-range aids to navigation technicians).

Graphic depicting how to verify the leveling of an aids to navigation lantern

Part 2: Focusing

There is another issue, especially on larger lights, that has to do with the "focus" of the light. For the light to be in focus, the lamp needs to be lined up with the center of the Fresnel lens. To check this, there are sighting marks (an "O" and "X" pair or two "X" pair) marked at 180° increments on the outside of the lens. When looking through the "O" to the "X" on the opposite side (180°) of the lens, the lamp should fall between the two sighting marks with the sighting marks aligned. The most common issue with the focus on certain model lights is when the bracket for the lamp changer mounts is installed upside down, which moves the lamp out of the focal plane of the lens.

The graphic below illustrates how to verify that a lantern is properly focused.

Graphic depicting how to verify the focusing of an aids to navigation lantern

Published 19Apr2021.

 2) When does a sound signal (i.e., foghorn) have to be "on"?

In accordance with 33 CFR 67.10-10, sound signals required on Class "A", "B" or "C" structures have to be operated continuously, unless the sound signal can be controlled:

  1. By an attendant on the structure;
  2. Remotely by an attendant on a nearby structure; or
  3. By a fog detection device that is capable of activating the sound signal when the visibility in any direction is reduced to the range required for the facility.

Note that the "attendant" referenced in options 1 and 2 above are intended to be personnel that are able to regularly monitor local conditions and activate the sound signal when conditions diminish to the point that the signal is required. The mere presence of personnel on the facility does not satisfy attendant requirements. The following examples should aid in the explanation:

  1. If all personnel are asleep (i.e., no personnel are on tour/duty/watch), local conditions are not being monitored and the sound signal should be in operation.
  2. Facilities with personnel awake/on tour throughout the course of a 24-hour day would easily be able to monitor visibility conditions and activate the sound signal when needed.

Any time visibility conditions diminish and the sound signal is not active, the facility is out of compliance with regulatory requirements and is a risk to both navigation of vessels in the area and their crew and to the crew on the facility.

Sound signals have to be operated in regard to visibility as follows:
Class "A" structure – when the visibility in any direction is less than 5 miles; and
Class "B" and "C" structures – when the visibility in any direction is less than 3 miles (unless the District Commander prescribes a greater or lesser distance, not to exceed 5 miles).

Published 28Apr2021.
 3) What are the general requirements for a sound signal on fixed OCS facilities?

The sound signal must:

  • sound a 2-second blast every 20 seconds (2 seconds of sound and 18 seconds of silence) (33 CFR 67.10-1(b));
  • be Coast Guard approved (33 CFR 67.10-1(f));
  • be audible over 360° in a horizontal plane for the required range (33 CFR 67.10-5(a)); and
  • be located at least 10 feet but not more than 150 feet above mean water level (33 CFR 67.10-5(b)).

Additional requirements, such as design and markings, are listed at 33 CFR 67.10-1.

Required ranges are as follows:
Class "A" structure – range of at least 2 miles
(unless the U.S. Coast Guard District Commander waives requirements due to the proximity to other structures);
Class "B" structure – at least one-half mile
(unless the District Commander increases the range due to proximity to navigational areas or waives/relaxes requirements due to the proximity to other structures or shoal areas); and
Class "C" structure – at least one-half mile
(for structures located near navigational areas and deemed necessary for safety of marine commerce by the District Commander)

Occasionally, sound signals are relocated (often relocated to a higher deck to minimize damages due to wave action, storm surge and/or sea spray) without taking into account equipment or structures that will reduce the effective range in the direction(s) of the obstruction(s). The graphic below demonstrates this example:

Graphic depicting proper and impeded sound signal installations

Large facilities, or facilities with known obstructions that impede the effectiveness of the sound signal to reach required range in all directions, will often install two sound signals on opposite sides of the facility and synchronize them to sound in unison. For these synchronized systems, the applicable general requirements, characteristics and ranges should still be met.

Note: Please remember to contact the Private Aids to Navigation (PATON) Section at your respective U.S. Coast Guard District prior to equipment changes. CG-4143 application approval is required prior to all changes.
District Eight (Gulf of Mexico OCS facilities) – Email:  D8oanPATON@uscg.mil
District Eleven (California OCS facilities) – Ph: (510) 437-2984

Published 28Apr2021.