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www.offshoreoperators.com January 2017 OOC-G-2017-1
OOCGuidance:FixedPlatformMeansofEscape
1 Regulatory Background & Intent The United States Coast Guard (USCG) under 33 CFR 143.101 outlines required means of escape from fixed offshore platforms. These requirements cover manned and unmanned OCS facilities with the intent to provide offshore workers at least two means of escape from a fixed platform in the event of an emergency. The intent of the regulation is not to have stairways or ladders that extend into the water, but to enable accessibility to a personnel landing or level closest to the water surface. These escape paths must be free of obstructions and maintained in a safe condition at all times.
2 Means of Escape There are two categories for means of escape, primary and secondary.
2.1 Primary Means of Escape (PME) A primary means of escape must be a fixed stairway or a fixed ladder of metal construction, which is accessible from the uppermost deck level that contains living quarters or that personnel occupy continuously, to each successively lower working level and then to the personnel landing.
2.2 Secondary Means of Escape (SME) A secondary means of escape can be either the same as a primary means or portable, flexible ladders, knotted man ropes or other devices approved by the OCMI that extend from the uppermost working level to or beyond the elevation of the personnel landings.
For single well caissons, a Secondary Means of Escape (SME) can be jumping from the work deck if it is: (a) no more than 20-feet by 20-feet (or 400 square feet) in size, and (b) no more than 20-feet above mean low water.
3 Requirements for Means of Escape
3.1 Manned OCS Fixed Platforms Each manned OCS fixed platform must have at least two Primary Means of Escape.
3.2 Unmanned OCS Fixed Platforms Each unmanned OCS fixed platform must have at least one Primary Means of Escape. When personnel are on board, you must also have at least one Secondary Means of Escape in addition to the one Primary Means of Escape.
3.3 Functional Demonstration (Drills) The USCG or designee may require personnel to demonstrate adequate and functional primary means of escape. This functional demonstration may include the movement along the escape path(s) to the personnel landing.
This functional escape demonstration does not include entering the water or demonstration of Secondary Means of Escape. Equipment associated with Secondary Means of Escape is subject to inspection upon request of USCG or their designee.
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www.offshoreoperators.com January 2017 OOC- -2017-1
PME - Stairs
SME – Ladder & Knotted Rope
EXAMPLE: Unmanned Fixed Platform 1 PME, 1 SME
Personnel Landing
EXAMPLE: Manned Fixed Platform 2 PME
PME - Stairs PME - Stairs
Personnel Landing
Personnel Landing
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COMDTINST 16000.7B
USCG Marine Safety Manual, Vol. II: Materiel Inspection
SECTION G: OUTER CONTINENTAL SHELF ACTIVTIES
CHAPTER 5: Procedures Applicable to Fixed OCS Facilities or Platforms 6. Lifesaving/ Firefighting Equipment
a. Variances. BSEE consults with the local OCMI to determine suitable options,temporary measures or restrictions during the repair or replacement of requiredfirefighting equipment and lifesaving appliances. BSEE initiates this process withthe local OCMI. In cases where the owner/operator contacts the Coast Guarddirectly, BSEE shall be notified immediately.
b. Approval process. The Coast Guard shall continue to approve equipment for useon fixed offshore facilities and publish the list of approved equipment in theFederal Register and COMDTINST M16714.3 (Series) in accordance with 33CFR 140.15(b). The Coast Guard shall also notify BSEE of any newly approvedequipment and provide training as needed.
7. Catwalks – Manned Platforms
33 CFR 143.101 (c) requires all manned OCS facilities be provided with at least two primary means of escape extending to the water. 33 CFR 143.101 (a) defines primary means of escape as fixed stairways or ladders of metal construction. For OCS facilities that are connected to adjacent facilities by bridges, or catwalks which allow free access from one facility to another, the catwalk may serve as one of the primary means of escape provided:
a. The catwalk leads to another location that provides a primary means of escapeextending to the water, and
b. There is a sufficient amount of primary lifesaving gear per 33 CFR 144.01-1 or144.01-15 at this alternate location to accommodate 100% of the personnelonboard the manned facility if they cross the catwalk and egress to the water viathis alternate escape route.
8. Single Well Caissons – Unmanned Platforms
33 CFR 143.101(d) requires unmanned OCS facilities be provided with one primary means of escape and, when personnel are onboard and one secondary means of escape for every 10 persons onboard. In the case of small single-well caisson type facilities, the primary means of escape is usually a fixed ladder from the topside structure (work deck) to the waterline. Since the work deck on these platforms is typically very small, a worker cannot become trapped far from the primary escape route. Furthermore, the risk to workers attending these facilities is quite low because there is usually very little processing equipment onboard, plus the limited frequency and duration in which personnel visit these facilities further lessens the risk. Taking all this into consideration, a
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COMDTINST 16000.7B
USCG Marine Safety Manual, Vol. II: Materiel Inspection
SECTION G: OUTER CONTINENTAL SHELF ACTIVTIES
CHAPTER 5: Procedures Applicable to Fixed OCS Facilities or Platforms single-well caisson type facility must have one primary means of escape but will not be required to have a secondary means of escape, even when workers are on the platform, provided:
a. The work deck is no more than 20 ft x 20ft (or 400 square feet) in size, and
b. The work deck is no more than 20 ft above mean low water.
9. Swing Ropes and Knotted Man Ropes
A primary means of escape shall be installed to meet the requirements in 33 CFR 143.101. A secondary means of escape shall be constructed and installed to the satisfaction of the cognizant OCMI. Item (8) of Fixed Platform Inspection Program, CCGD8INST 16711.1 (series) is the recommended standard for construction and maintaining man ropes and swing ropes. Particular attention should be given to man ropes and swing ropes due to weathering of the ropes and the dangers that are encountered when using these devices.
Man ropes should be replaced immediately if there is any evidence or wear, dry rot, mildew or ultraviolet deterioration. Swing ropes are subject to all the same considerations as man ropes.
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LOUISIANA OFFICE TEXAS OFFICE One Lakeway-3900 N. Causeway, Blvd., Suite 700, 10777 Westheimer Rd., Suite 700 Metairie, Louisiana 70002 Houston, Texas 77042 (504) 934-2159 Office / (504) 455-0868 Fax (713) 589-6710 Office / (504) 455-0868 Fax
September 18, 2015
Eighth Coast Guard District OCS Division – OCMI 13th Floor, Room 1341 500 Poydras Street New Orleans, LA 70130 Attn: Captain Reynolds
Dear Captain Reynolds,
One of our member companies brought to my attention a recent effort by the Coast Guard’s OCS National Center of Expertise (OCS NCOE) to train Coast Guard and BSEE personnel on aspects of inspecting fixed offshore production platforms. The company representative I spoke with expressed some concern regarding information that was passed by the Coast Guard concerning escape/egress ladders. Specifically, that escape/egress ladders must extend below the water and no longer terminate above the surface of the water. The reasoning behind this was to provide access out of the water should someone fall in.
As you know, the regulatory intent of egress ladders is to provide a means off of the platform in case of emergency and there are no specific requirements to provide access back onto a platform via a fixed ladder. This very issue was the subject of further clarification by your office (then Captain Dan Ryan) back in June 2003. That letter is attached for your reference as well. It has also come to my attention that BSEE may start to actively enforce this “requirement” based on the information passed in the training.
I am concerned that information related to matters of interpretation of inspection issues, no matter how well-‐intended, may create unnecessary regulatory constraints for our members and could result in costly modifications for items that are not required by regulation or policy. As I’m sure you can well appreciate, the level of oversight the Coast Guard provides on fixed offshore platforms has largely waned since granting the authority to BSEE (then MMS) to inspect these structures on behalf of the Coast Guard in 2002. Since that time, there has been varying levels of interaction between the agencies with regard to the level of training the Coast Guard was to provide so that BSEE could better understand the items and systems under the purview of the Coast Guard. Further exacerbating this effort has been the continual loss of expertise of both Coast Guard and BSEE personnel as they rotate into and out of their respective positions.
While we welcome any effort the Coast Guard undertakes to help train BSEE in aspects of fixed platform inspections, we have concerns about the level of oversight or involvement that may or may not be provided by the actual regulatory authority which, in this case, is your office as the OCMI. Our understanding of the role of the OCS NCOE is that they support and advise the OCMI but they do not represent the OCMI and they do not necessarily have any OCMI authorities vested within their structure. If I have mischaracterized that relationship, please let me know.
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LOUISIANA OFFICE TEXAS OFFICE One Lakeway-3900 Causeway, Blvd., Suite 700, 10777 Westheimer Rd., Suite 700 Metairie, Louisiana 70002 Houston, Texas 77042 (504) 934-2159 Office / (504) 455-0868 Fax (713) 589-6710 Office / (504) 455-0868
In order for any effort to succeed that provides updated training on the aspects of items under Coast Guard jurisdiction on fixed platforms, it should have engagement and input from the industry. The OOC has the resources and historical perspective that can assist you with closing any perceived gaps in policy or regulation for fixed platform inspections. Some of these have been captured in legacy District Eight instruction letters; others may only be evident in letters to individual companies. Before any further training or development of jobs aids the Coast Guard may be working on to aid BSEE in fixed platform inspection, I respectfully request a meeting with you and representatives of the OSC NCOE. I would like to ensure that we move forward in manner that takes into account established regulation and policy guidance. Thank you for your consideration.
Respectfully submitted,
Evan H. Zimmerman Executive Director Offshore Operators Committee
c.c.: Mr. Lars Herbst, BSEE GOMR
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Title 33-Navigation and Navigable Waters
terpret or apply sec 4 87 Stat 462 43 U S C1333
SOURCE §§ 142 01 to 14120 contained inCGFR 56-4 21 F R 902 Feb 9 1956
§ 142 01 Application
The provisions of this part shall applyto all artificial islands and fixed struc-tures located on the outer continentalshelf
§ 142 05 Inspection requirements
The Officer in Charge Marine Inspec-tion, will perform or have performedthe inspections of artificial islands orfixed structures within his area of juris-diction to determine that the require-ments in this subchapter are met Theseinspections will be at such time or timesas he may deem necessary
§ 142 10 Scope of inspections
In the inspection of an artificial islandor a fixed structure, the person assignedwill inspect the lifesaving appliancesfirefighting equipment, emergency equip-ment observe emergency drills (if nec-essary) and otherwise satisfy himselfthat all provisions of the regulations inthis subchapter have been complied withand that the emergency equipment is ingood condition and satisfactory in everyrespect
§ 142 15 Deficiencies
Any deficiency will be reported to theowner The owner shall have the defi-ciency corrected as soon as practicableAny equipment required by the regula-tions in this subchapter found to be defi-cient or unsatisfactory by the personperforming an inspection will be con-demned Such condemned equipmentshall be repaired or replaced as soon aspractical Condemned lifesaving or fire-fighting equipment which cannot besatisfactorily repaired, shall be so muti-lated that it cannot be used for the pur-pose for which it was originally intended
§ 142 20 Authority to perform inspec.tions
Persons assigned to this work may atany time lawfully inspect an artificialisland or fixed structure
PART 143-CONSTRUCTION ANDARRANGEMENT
Sec143 01-1143 01-5
Subpart 143 01-General
ApplicationScope of requirements
SubSec143 05-1143 05-5143 05-10
ipart 143 05-Means of Escape
TypesManned platformUnmanned platform
Subpart 143 10-Personnel Landings
143 10-1 Manned platforms143 10-5 Illumination
Subpart 143 15-Guards and Rails
143 15-1 Floor or deck areas and openings143 15-5 Catwalks and stairways
AUTHORITY §§J 143 01-1 to 143 15-5 Issuedunder sec 633 63 Stat 545 14 U S C 633Interpret or apply sec 4 67 Stat 462, 43U S C 1333
SoURCE §§ 143 01-1 to 143 15-5 containedinCFGR56-4 21F R 902 Feb 9 1956
Subpart 143 01-General§ 143 01-1 Application
The provisions of this part apply toall artificial islands and fixed structures§ 143 01-5 Scope of requirements
No requirements are established withrespect to the construction and arrange-ment of artificial islands and fixed struc-tures except as necessary to comply withsafety requirements contained in thissubchapter
Subpart 143 05-Means of Escape§ 143 05-1 Types
Means of escape shall be fixed stair-ways or fixed ladders They shall beconstructed of metal and shall extendfrom the platform to the surface of thewater at the low range tidal mark§ 143 05-5 Manned platform
At least two means of escape shall beprovided for each manned platform§ 143 05-10 Unmanned platform
At least one means of escape shall beprovided for each unmanned platform
Subpart 143 10-Personnel Landings§ 143 10-1 Manned platforms
Sufficient personnel landings shall beprovided on each manned platform toassure safe access and egress When dueto special construction personnel land-ings are not feasible then suitable trans-fer facilities to provide safe access andegress shall be installed§ 143 10-5 Illumination
The personnel landings shall be pro-vided with satisfactory illumination
Page 312
§ 142 01
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Chapter I-Coast Guard
The minimum shall be one-foot candleof artificial illumination as measured atthe landing floor and guards and rails
Subpart 143 15-Guards and Rails
§ 143 15-1 Floor or deck areas andopenings
(a) Except for helicopter landingdecks which are provided for in para-graph (b) of this section, and areasnot normally occupied, the unprotectedperimeter of all floor or deck areas andopenings shall be rimmed with guardsand rails or wire mesh fence The guardrail or fence shall be at least 42 incheshigh The two intermediate rails shallbe so placed that the rails are approxi-mately evenly spaced between the guardrail and the floor or deck area Promded,That if a toe board is installed then oneof the intermediate rails may be omittedand the other rail placed approximatelyhalf way between the top of the toe boardand the top guard rail
(b) The unprotected perimeter of thehelicopter landing deck shall be pro-tected with a device of sufficient strengthand size as to prevent any person fromfalling from such deck
§ 143 15-5 Catwalks and stairways
Each catwalk and each stairway shallbe provided with a suitable guard rail orrails as necessary
PART 144-LIFESAVING APPLIANCES
Subpart 144 01-Manned PlatformsSee144 01-1 Life floats14401-5 Location and launching of life
floats144 01-10 Equipment for life floats144 01-15 Alternates for life floats144 01-20 Life preservers144 01-25 Ring life buoys144 01-30 First-aid kit144 01-35 Litter144 01-40 E m e r g e n c y communications
equipment
Subpart 144 10-Unmanned Platforms144 10-1 Life preservers144 10-5 Ring life buoys144 10-10 Other lifesaving appliances
AurHoarry if 144 01-1 to 144 10-10 issuedunder sec 633 63 Stat 545 14 U S C 633Interpret or apply see 4 67 Stat 462 43U S C 1333
SoU sCE if 144 01 to 144 10-10 contained inCGFR 56-4 21 F R 903 Feb 9 1956 exceptas otherwise noted
Subpart 14401-Manned Platforms§ 144 01-1 Life floats
Each manned platform shall be pro-vided with at least two approved lifefloats The life floats shall have suffi-cient capacity to accommodate all per-sons present at any one tume§ 144 01-5 Location and launching of
life floatsThe life floats shall be distributed in
accessible locations and mounted on theoutboard sides of the working platformin such a manner as to be readilylaunched§ 144 01-10 Equipment for hfe floats
(a) Each life float shall be providedwith a painter This painter shall be amanila rope or equivalent, not less than2% inches in circumference and of alength not less than three times the dis-tance from the low water line to the deckor place where the life float is stowed
(b) An approved electric water lightshall be provided for each life float Thewater light shall be attached to the lifefloat by a lanyard not less than onefathom nor more than two fathoms inlength The water light shall bemounted in a bracket so that when thelife float is launched the water light willpull free of the bracket
(c) Two paddles shall be provided foreach life float The paddles shall not beless than five feet nor more than sixfeet long The paddles shall be stowedin such a way that they will be readilyaccessible from either side of the lifefloat when in the water§ 144 01-15 Alternates for life floats
(a) Approved lifeboats, approved liferafts or approved inflatable life raftsmay be used in lieu of approved lifefloats for either all or part of the capac-ity required When either lifeboats orlife rafts are used approved means oflaunching will be required Inflatablelife rafts when used, shall be dis-tributed and mounted as required forlife floats under § 144 01-5
(b) The equipment required for alifeboat is a bailer boat hook bucket,hatchet, lantern, life line two life pre-servers, matches full complement ofoars and steering oar painter, plug, androwlocks, of the same type, kind andcharacter as required for lifeboats car-ried on vessels engaged in navigatingbays sounds and lakes other than theGreat Lakes, and rivers
Page 313
§ 144 01-15
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Tuesday, January 28, 1962
detached fuel tank. Therefore, until recentlY there ·was no need for any ventilation requirements for fuel tank compartments in outboard motorboats as fuel tanks were integral with the motors and carried outside the hulls of the vessels.
FEDERAL REGISTER
by changing the second entry under the Percent column headed "Heat-damaged kernels" to read ".5".
[9 CFR Part 201 l REGULATIONS UNDER PACKERS AND
STOCKYARDS ACT 93. The autho1ity to prescribe regulations . regarding uninspected vessels <motorboats) is inR.S. 4405, as amended, Notice That Amendments to Registra-4462, as amended, and secs. 8, 1'7, 54 tion and Bonding Regulations and Stat. 165, as amended, 166, as amended; Related Regulations Are Under 46 U.S.C. 375, 416, 526g, 526P· . Consideration ITEM IX-ARTIFICiM. IstANDS AND F'IxED . .., ... n
S TURES ON THE OUTER CONTINENTAL On Sep~embe1· 28, 1961, w.t:re was TRUC published m the FEDERAL REGISTER (26
Sm:tF F .R. 9136), a. notice that consideration 94. It is proposed to amend 33 CFR was being given as to whether certain
143.05-1, 143.05-5, and 143.05-10 regard- regulations under the Packers and ing emergency means of escape from Stockyards Act (9 CFR Part 201) should artificial islands and fixed structures. be amended or revised in view of the These proposals were initiated as a re- changes in current marketing conditions sult of the recommendations by the Ma- and the 1958 amendment to the Act i·ine Board of Investigation which inves- which extended the scope of the Act in tigated an e:>.'Plosion and fir~ on the certain respects. The notification in"Off shore Platform Timbalier Block 134- vited any interested persons whet wished 01," Gulf of Mexico, July 26, 1959, with to do so to submit proposals with respect
' loss of life. It was the opinion of the to changes in §§ 201.10 to 201.13, inBoard as a result of the casualty that elusive, concerning registrations, and present regulations regarding means of §§ 201.29 to 201.34 inclusive, concerning escape required clarification. The Board market agency and dealer bonds <9 CFR determined that in this casualty there 201.10-201.13, 201.29-201.34). was only one means of escape from the Recommendations which have been quarters level to the rig floo1· but that received from interested persons, 1! there were two fixed stairways from: the adopted, may require changes or revirig floor to the surface of the water. sions in regulations other than those Since the terminology of the oil industry specified in the notice of September 28, describes the platform as the structure 1961. SpecificallY those regulations on which the drilling rig and equip~ent which may reqUlre changes are §§ 201.69, are placed, this platform bad two means 201.60, 201.61, 201.66, 201.67, 201.68, of escape. Therefore, the purpose of this 201.79, and 201.81, concerning certain p1·oposal is to amend regulations so that trade practices and services of persons two means of escape are required from subject to the Act (9 CFR 201.59, 201.60, each level to the surface of the water. 201.61, 201.66, 201.67, 201.68, 201.79, and These.proposals were con:iidered and en- 201.81). dorsed by the National Offshore Oper- Any interested person who wishes to ations Panel at its meeting on February submit proposals and the reasons there-7, 1961, at Washington, D.C. for, or comments with respect to these
95. The authority to prescribe regula- regulations .may do so by filing them tions regarding artificial islands and with th~ ?~ector, ~ackers and Sto?k-
. ....,_., 63 stat yards D1vis1on, Agricultural Marketing fl."ted structures is m sec. ".,,,., · Service, United States Deparbnent of 545; 14 u.s.c. 633. These regulations Agriculture, Washington 25, D.C., not interpret or apply sec. 4, 67 Stat. 462; later than 30 days after publication 43 u.s.c. 1333. hereof in the FEDERAL REGISTER. The
Dated: January 12, 1962. time for :filing proposals with :respect to §§ 201.10-201.13 and 201.29-201.34 1s hereby extended for the same period. Copies of the present regulations may be obtained on request from the Director.
[SEAL] J. A. HmsHFIELD, Vice Admiral, U.S. Coast Guard,
Acting Commandant. [F.R. Doc. 62-731; Flled, Jan. 22, ·1962; If it is decided after consideration of all
a:so a.m.J proposals and comments received pursuant to this notice and consideration of all other relevant matters that the regu-
DEPARTMENT OF AGRICULTURE lations should be amended a notice of proposed rule-making will be publlshed in the FEDERAL REGISTER setting forth any Agricultural Marketing Service
C 7 CFR Part 26 l
GRAIN SORGHUM
specific proposed amendment.s. At that time all interested persons will have an opportunity to submit their views on such proposed amendment.s.
Official Grain Standards of the United Done at Washington, D.C., this 17th States; Notice of Proposed Rule · day of January 1962. Making CLARENCEH. GIRARD,
Correction · Director, In F .R. Doc. 62-368 appearing at page Packers and Stockyards Division.
409 of the issue for Saturday, January [F.R. Doc. 62-'l07; Flled, Jan. 22, 1962;' 13, 1962, the t'!lble in § 26.653 is c0rrected 8:46 a.m.J
Agricultural Stabilization and Conservation Service
665
[ 7 CFR Part 1064 1 l [Docket No. A0-23-A20 and A0-23-A22]
MILK IN GREATER KANSAS CITY MARKETING AREA
Decision on Proposed Amendments to Tentative Marketing Agreement and to Order .
Correction In ~.R. Doc. 61-12366, appearing at
page 12710 of the issue for Friday, December 29, 1961, the following words should be inserted immediate].y preceding the signature of James T. Ralph: "Signed at Washington, D.C., Decembe1· 22, 1961.".
DEPARTMENT OF LABOR Wage and Hour Division
[ 29 CFR Part 541 l EXECUTIVE, ADMINISTRATIVE AND
PROFESSIONAL EXEMPTIONS Notice of Proposed Rule Making
Section 13(a) U> of the Fair Labor Standards Act of 1938 <29 u.s.c. 213(a) (1) ) • proVides an exemption from the minimum wage a.nd overtime requiremen~ of the Act for any employee employed in a bona fide executive, administrative, or professional capacity. The Administrator of the Wage and Hour and Public contracts Divisions of the Deparbnent of Labor is authorized t-0 define and delimit these terms. The regulations established pursuant to this authority are contained in 29 CFR Part 541. These regulations provide, among other things, that no person shall be considered a bona fide executive 1f he is paid less than $80 a week on a salary basis ($55 a week if employed in Puerto Rico or the Virgin Islands> • and that no person shall be considered a bona fide administrative or professional employee 1! he is paid less than $95 a week on a salary or fee basis ($70 a week if employed in Puerto Rico· or the Virgin Islands). These regulations also contain special provisions for such employees who are paid $125 a week or more. The widespread increases in wage and payroll levels which have ta.ken place since these salary tes~ were established in Feb111a.ry, 1959, indicates that consideration should be given to further changes of these rates. According~. notice 1s hereby given of
proceedings to be held on Monday, March 26, 1962, at 10 o'clock a.m., in Conference Room B, Departmental Auditorium, Constitution Avenue, between 12th and 14th Streets NW., Washingt-0n, D.C., before Hearing Examine1·, Clifford P. Grant, at which time interested persons may submit oral data, views, or arguments on the following question: What, if any, changes should be made in 29 CFR 541.Hf>. 541.2 Ce) , and 541.3(e) with respect to the level
~Formerly Part 913.
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