The US Office of Design and Engineering Standards issued Change 1 to CG-ENG Policy Letter 02-12, ‘Acceptance of the 2009 MODU Code.’ The 2009 Mobile Offshore Drilling Units Code was amended several times since its adoption.
The most recent amendments include updated design and equipment requirements that derive from the findings of the Deepwater Horizon casualty investigation, a casualty that led to the loss of 11 people, the sinking of the unit and the largest marine oil spill in US history.
Operators of MODUs in the US Gulf of Mexico are encouraged to consider designing and constructing their new MODUs to the latest 2009 MODU Code standards
USCG said.
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Title 33 Code of Federal Regulations provides three options to show that a foreign documented MODU complies with US coastal state regulations. Most of MODU operators on the US Outer Continental Shelf (OCS) choose to comply with 33 CFR 143.207(c), often referred to as Option ‘C’. When choosing this option they present the OCMI with a valid Mobile Offshore Drilling Unit Safety Certificate issued by the flag state or an agent authorized to act on its behalf.
The US Coast Guard has also evaluated the 2009 IMO MODU Code, as amended, and considers the design and equipment standards to be at least as effective as the design and equipment standards of the 1979 and 1989 MODU Codes.
In light of this, OCMIs may consider a foreign documented MODU with a valid 2009 Mobile Offshore Drilling Unit Safety Certificate issued by the flag state or its authorized agent to comply with 33 CFR 143.207(c) after confirming the MODU complies with provisions of the 2009 MODU Code and the relevant amendments.
In addition, when determining if a MODU complies, the term ‘should’ in the Code will be interpreted as ‘must.’ The OCMI should report any discrepancies which may preclude issuance of a COC under this option to Commandant (CG-ENG).
Finally, minor equivalencies noted on the Mobile Offshore Drilling Unit Safety Certificate may be accepted by Commandant (CG-ENG) on a case-by-case basis. Accepted exemptions or exceptions will be documented in MISLE as a ‘Special Note.’