Offshore Non-Mineral (Renewable/Alternative) Energy Support Vessel Frequently Asked Questions (FAQs)

Yes, if entering port or U.S. territorial seas.

PSC exams are required only for vessels that “arrive” in the U.S. by coming into port or anchoring within 12 nautical miles (NM). Some wind farm installation vessels bound for the U.S. Outer Continental Shelf may never arrive in the U.S. and may remain beyond 12 NM while conducting operations. If these vessels do not arrive in the U.S., they are NOT required to undergo a PSC exam by the local OCMI.

Vessels that do not arrive and are not required by their operations to enter inside 12 NM may not have a need for an exam for the duration of their activities.

Published 01Nov2023.

As a core, the valid applicable safety certificates required by the SOLAS convention and the applicable environmental compliance certificates required by MARPOL remain acceptable for general PSC compliance.

Alternatively, some flag states and class societies are issuing Mobile Offshore Unit (MOU) safety certificates based on the vessel meeting the design and operating criteria of the MODU Code, in lieu of (or in conjunction with) the applicable SOLAS safety certificates. There are a couple of important items to note in these cases:

1. Due to the unique designs and operations of many foreign wind farm vessels, the MODU code offers a logical and acceptable alternative level of safety, and so has been accepted for PSC compliance.
2. Some vessels are issued MOU certificates based on the national standards of the vessel’s flag state. National MOU certificates are not acceptable for PSC compliance. The vessel must have valid safety certificates associated with international convention or code (SOLAS or MODU Code).

Additionally, foreign vessels arriving with more than 12 persons in addition to crew (such as wind farm installation techs and the like) should be currently certificated to comply with international convention by certification as either a passenger ship or alternatively a Special Purpose vessel under the Special Purpose Ships (SPS) Code. For awareness purposes, the Industrial Persons (IP) Code has been accepted by IMO and is set to go into effect in July of 2024 as a new Chapter of SOLAS and will offer an alternative for large industrial vessels on international voyages carrying more than 12 industrial persons (per IMO definition). Note that this does not impact vessels approved under the MODU Code (since it already provides for the carriage of more than 12 persons in addition to crew on international voyages), as long as the vessel meets the lifesaving equipment carriage and operational requirements, versus simply the vessel design standards.

Developed in conjunction with CG-CVC guidance. Published 01Nov2023.

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).

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.

Short Answer: Yes, in most circumstances.

Discussion: While USCG regulations do not explicitly mention DP systems, the topic has been discussed in numerous CG policies, guidance and legal reviews.

Note: Additional case-by-case reviews and determinations may have been made by the CG in regard to DP as propulsion, but only those that have been available to the public are discussed in this explanation.

NVC 8-68 first addressed this issue when released on November 15, 1968, due to "an increasing number of non-self-propelled units being equipped with positioning machinery, steering aids and propulsion assist units." In this NVC, the CG policy on tunnel type "thrusters" and "kickers" used solely for transiting locks and/or canals would not be considered as a basis for classifying a vessel as self-propelled. However, the NVC went on to say that "vessels equipped with directional maneuvering equipment and/or substantial propulsion assist units will normally be considered as self-propelled vessels" regardless of if a towing vessel was employed in the operation.

NVC 8-68 was cancelled by Change 1 to Marine Safety Manual Volume II (MSM II) on July 7, 2014, and the language of the policy was condensed and included at MSM II A.6.F (pages A6-6 and A6-7). The policy was modified for vessels equipped with directional moving equipment to note that "this would include dynamic positioning (DP)". MSM II A was moved to COMDTINST 16000.70 on Sep 20, 2021, but the policy remained the same:

"To further clarify, unidirectional tunnel type "thrusters" and "kickers" used solely for transiting locks and/or canals would NOT be considered a basis for classifying a vessel as self-propelled. Vessels equipped with directional maneuvering equipment and/or substantial propulsion assist units will normally be considered self-propelled (this would include dynamic positioning (DP)); notwithstanding the fact that a towing vessel may be employed in the operation."

CG-094 (Judge Advocate General and Chief Counsel) issued a memorandum to CG-5 (Assistant Commandant for Marine Safety, Security and Stewardship) on February 11, 2011, with the subject of "Potential Legal Issues Associated with Vessels Employing Dynamic Positioning Systems" and the redacted memo was included as Appendix I to the Report of Investigation for the MODU DEEPWATER HORIZON casualty. The memo thoroughly discusses the law and history surrounding vessels and the classification of being self-propelled. At paragraph 23, the memo concludes that:

"Under current law, a watercraft operating with a DP System is an underway, self-propelled vessel, and subject to all the regulatory requirements of "traditional" vessels."

The USCG Marine Safety Center (MSC) states that "DP systems are propulsion control systems and are considered as vital systems" in section 4 of MSC Plan Review Guidance Procedure No. E2-24, dated December 14, 2021. The previous revision of the procedure, dated November 9, 2011, essentially stated the same thing, although in less direct verbiage. MSC Technical Note 02-11, CH-1, dated December 11, 2020, states in paragraph 2.b that "DP systems are considered to be a vital component of the propulsion control system" and goes on to say that "DP systems are routinely used as the primary maneuvering system during critical operations".

Frequently asked questions are posted on both the NAVCEN and OCSNCOE websites that state that a vessel that is using DP to maintain position is considered as underway, not making way in regard to the Navigation Rules and should be marked by navigation lighting or dayshapes to indicate that condition.

While a DP system may have the primary purpose of station keeping or proceeding along a specific path (usually for an industrial purpose, such as pipe laying or cable laying), the CG has considered systems that have the ability to move and maneuver a vessel as a means of self-propulsion for more than 50 years and has reiterated that DP systems fall within that category.

Published 09Jan2024.

The U.S. Coast Guard sees the safe transfer of people between a vessel and an offshore facility to primarily be an operational risk element that should be controlled through effective safety management practices, as applicable to the vessel. Personnel transfer systems support key shipboard operations, and the operation and maintenance of the systems should be included and verified within the vessel’s safety management system, if applicable.

The Coast Guard does not have any published regulations or policies that provide explicit system requirements for crew transfer systems and equipment. As such, the systems must meet general equipment design and operations standards applicable to the vessel (e.g. 46 CFR Subchapters F and J for vessels inspected under Subchapter L) on which they are installed. For vessels enrolled and inspected under the Alternate Compliance Program (ACP), there are no items in the ACP Supplement that would address these systems explicitly, so the systems would be required to comply with general international convention requirements and classification society rules.

Personnel transfer systems should provide for the safety of all persons involved in personnel transfers, including a safe and suitable means of transfer and the capability of safely carrying out the operations. Personnel transfer systems should be designed, constructed, tested and installed to a degree suitable for the arrangement and purpose of the vessel. This includes evaluating the expected need of the vessel with respect to its movements in a seaway and to maintain vessel position over time. 

As it relates to vessel design, items that may affect the vessel must be addressed during plan submittal/review. These items may include loads placed on the hull structure, use of dynamic roll compensation systems, normal and emergency electrical loads, vital systems automation and vessel stability. This list is potentially not all inclusive and simply giving a general example of impacted systems and processes.

Published 10Apr2024.