National Academy Studies on US Flag Registry

DNV GL © 2014 16 September 2015 SAFER, SMARTER, GREENER DNV GL © 2014

16 September 2015 Blaine Collins

MARITIME

National Academy Study on US Flag Registry

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The Classification Society Perspective

DNV GL © 2014 16 September 2015

The Classification Perspective: Agenda

DNV GL in Brief DNV GL and USCG ACP Brief History DNV GL classed US fleet and ACP How we work with the USCG today DNV GL ACP Experience vs. Other Flags Class and the USCG: Common Objectives: Differences Observations DNV GL and USCG working practices and relationships Potential Improvements in ACP Conclusion and Q+A

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DNV GL © 2013

We are a global classification, certification, technical assurance and advisory company

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Organized to maximize customer value

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OIL & GAS

MARITIME

ENERGY

BUSINESS ASSURANCE

SOFTWARE

RESEARCH & INNOVATION

CYBERNETICS

DNV GL © 2013

Only by connecting the details can we impact the bigger picture

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We classify, certify, verify and test against regulatory requirements, rules, standards and recommended practices

We develop new standards and recommended practices

We qualify new technologies and operational concepts

We give expert advice to enhance sustainable business performance

DNV GL © 2013

The world’s leading ship and offshore classification society

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24%

Global reach

13,000

Quality ships and mobile

offshore units in DNV GL Class, 270 mill GT

Survey stations in 100+ countries and expertise in all ship and offshore segments

market share (Gross Tonne) of the world’s classed ships and mobile offshore units

Consistently among the top ranking societies in Port State Control performance

DNV GL © 2013

DNV GL and ACP History

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First Foreign Class Society: – USCG Recognition First Foreign Class Society:

– USCG ACP Authorizations

Worked together in implementing ACP Oversight and audits, comms, data (DNV Exchange)

Continuous and ongoing improvements

Comments today related mostly to ACP: ACP authorizes USCG to harmonize US/International Stds


DNV GL Classed US Fleet

147 US flag vessels Ship Types:

– Container – Ro/Ro – Car Carrier – Passenger ship – Tanker – Diving support – Bulk Carrier – Fishing – Yacht

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DNV GL ACP Vessels

9 Vessels in Operation –Container/Ro-Ro –OSV/Dive Support –Car Carrier –Passenger ship –Bulk Carrier 4 Vessels on Order

–LNG Fueled Container –LNG Ready Container

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How we work with the USCG today

USCG HQ: Sets policy and regulations: – Director of Commercial Regulations & Standards (CG-52)

– Office of Design and Engineering Standards – Office of Operating and Environmental Standards – Office of Commercial Vessel Compliance

Marine Safety Center: Like our technical/plan approval centers – Technical reviews of plans, case-by-case decisions, tonnage Officer in Charge Marine Inspection (OCMI)

– Survey and field activities

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DNV GL ACP Experience vs. Other Flags: Positive Aspects

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Open to discussion, active in oversight, granting exemptions, inspections, etc. USCG HQ/MSC personnel knowledgeable and willing to admit competence gaps Responsive:

– Policy Letter for helidecks: (CAP 437, global standard)

– Policy Letter for FOI/FPSO – Delta House, LLOG, BW Pioneer

Collaborative


DNV GL ACP Experience vs. Other Flags: Challenging Aspects

Can be extremely rigid

Can be slow to respond – approval or schedule delays

All flags have specific interpretations, but U.S. has many & very specific

– However, US Supplements are continuing to prove an effective tool

Personnel transfers every 3 years

– Relationship and corporate knowledge

– Civilian personnel offsets

Lags on international regulatory actions – MLC, but SOVC authorized

Keeps new and novel (to USCG) design approval, i.e. LNG fueled ships

– DNV GL approves ship, except fuel system and containment (USCG)

– USCG recognizes DNV GL has over 2 decades of LNG fuel experience

– Anticipate this will change in near future

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DNV GL ACP Experience vs. Other Flags: General

Numerous communication channels – NVIC’s, Policy Letters, etc

– Suggest USCG consider other alternatives to more quickly harmonize CFRs with international regulations and communicate US interpretations

– U.S. Supplement

Evaluate oversight activities re: risk and possible duplication

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Class and USCG: Common Objectives; Common Differences

Class and industry often cite international arrangements:

– U.S. says pump rooms are Zone 0, even with ventilation

– U.S. requires IECEX certified equipment vice the more common ATEX certified equipment in hazardous areas

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“You can’t always get what you want”

Need to recognize and respect that USCG serves multiple stakeholders

Valid basis, i.e. Deepwater Horizon casualty


Observations

Rulemaking varies widely and creates uncertainty – Time from ANPRM or NPRM could be 1-5 years or never

– Not purely USCG – industry typically requests comment extensions

– Number or complexity of comments not known until close of period

NVICs: – Confusion over guidance or tool for compliance vs directive with

force of law – Some NVIC’s outdated and should be withdrawn

– Review for update, applicability, etc. – NVIC 10-82 predates ACP and has been superseded by ACP

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DNV GL and USCG Working Practices and Relationships

Meeting at least twice annually for ACP and other discussions

DNV GL ACP Coordinator in weekly contact with USCG via phone/email

Communications is good and effective

DNV GL shares information about R & D, new RPs (LNG Bunkering), pubs, etc.

DNV GL comments on rulemaking, as appropriate

Collaborative relationship

Mutual commitment to improvement

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Potential Improvements in ACP

Supplement: (No. 1 Improvement Recommendation)

– Single Supplement for all ACP class societies?

– USCG and Class working group

– USCG and Class to identify areas where Class and IMO rules are ≥ – USCG and Class to identify common, and acceptable, equivalencies for

known gaps (US interpretations?)

– Embody in Supplement

NVIC 10-82 is superseded by ACP, but not retired

Reality check on moving to only Class Rules + International Regulations:

– All flags have specific requirements

– ACP is Class Rules + International Regulations + Supplement = US CFRs

– US Supplement is effective way to address identified gaps not covered by Class Rules/International Regulations

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Conclusion: Continuing Development of ACP Benefits US Flag

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ACP

Traditional USCG/CFR


SAFER, SMARTER, GREENER

www.dnvgl.com

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Blaine Collins [email protected] 201-512-8900

Documents

National Academy Studies on US Flag Registry