foi compliance lessons learned and tools for the future · 2017. 12. 22. · foi compliance –...
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Working together for a safer world
FOI compliance – lessons learned and tools for the
future
AOG 2017
FOI compliance – lessons learned and tools for the future
Floating Offshore Installations (FOI) compliance – agenda
Australian FOI – the field of play
Lessons learned
Tools and techniques for the Future
FOI compliance – lessons learned and tools for the future
FOI compliance
Australian FOI – the field of play
Lessons learned
Tools and techniques for the Future
FOI compliance – lessons learned and tools for the future
Currently operators may find
themselves in the following situation
Prescriptive statutory
requirements
Asset specific verification /
inspection schemes
Classification survey cycles
The current regulatory situation for operational FOI’s
FOI compliance – lessons learned and tools for the future
Classification, statutory certification and verification
Verification (Whole
facility)
FOI compliance – lessons learned and tools for the future
Australian FOIs – the field of play
FPSO’s in Australia – existing projects – update July 2016
FPSO Name Class FLAG Client Operator Field Type Hull Date AGE
Modec Venture 11 ABS Panama Santos Modec
Mutineer
Exeter Conversion 1992 24
(FPSO Disconnectable)
Pyrenees Venture LR Australian BHP BHPB Pyrenees Conversion 2007 9
(FPSO Disconnectable)
Ningaloo Vision LR Panama Quadrant Quadrant Van Gogh Conversion 1981 35
(FPSO Disconnectable)
Dampier Spirit ABS Bahamas Jadestone TEEKAY Stag Conversion 1988 28
(FSO Disconnectable)
Okha ABS Australian WEL WEL Cossack Conversion 1999 17
(FPSO Disconnectable)
Nganhurra LR Australian WEL WEL Enfield New Build 2006 10
(FPSO Disconnectable)
Ngujima Yin LR Australian WEL WEL Vincent Conversion 2000 16
(FPSO - Disconnectable)
Northern Endeavour LR Australian NOGA NOGA Laminaria New Build 1998 18
(FPSO - Fixed)
Montara Venture LR Australian
PTTEP
Australasia
PTTEP
Australasia Montara Conversion 1990 26
(FPSO – Fixed)
FOI compliance – lessons learned and tools for the future
The view of the regulators – recent significant events
EMSA audit on class survey policies/records and other measures
International Marine Organisation “RO code” established
Incidents with legal focus on regulators
Legal interpretation vs application of engineering judgement
FOI compliance – lessons learned and tools for the future
Flag state regulators’ policies and approaches
“Domestic” flag states (responsibility for pollution) generally more proactive the FOI business:
• AMSA (MO 60)
• Transport Canada
• UK Marine Safety Authority and European Marine Safety Authority
“Open registries” rely more on classification societies, (but final decision with flag)
AMSA as local “port state” still empowered to detain
FOI compliance – lessons learned and tools for the future
FOI compliance
Australian FOI – the field of play
Lessons learned
Tools and techniques for the Future
FOI compliance – lessons learned and tools for the future
– Conversions
Legacy anomalies/def
iciencies
Arrested corrosion
“Ex” equipment
Commis-sioning
Passive fire protection
Marine fitout vs offshore
best practise
Shipyard vs offshore quality practise
Hull structural baselining
and hot spots
FOI compliance – lessons learned and tools for the future
– Repairs and mods
Planning remediation & improvement is
key
Align work with survey
schedule
Complete survey scope in the yard
Detailed pre-survey of
tanks
Tank corrosion/
scaling may mask defects
Plan access to tanks and pre-fabricate
FOI compliance – lessons learned and tools for the future
Operational fleet statistics
Conditions of class and class memoranda – LR FSO/FPSO fleet comparison
Vessel status Vessel type Condition of class Class Memoranda
History Current History Current
Active FSO 54 138 52
Active FPSO 61 1 85 23
Active FPSO 177 2 148 36
Active FPSO 13 31 22
Active FSO 57 71 26
Active FPSO 43 50 22
Active FPSO 43 48 17
Active FPSO 77 80 28
Active FPSO 35 2 314 41
Active FPSO 12 58 21
Active FPSO 12 31 10
Active FSO 2 89 37
Active FSO 6 127 27
Active FSO 7 77 45
Active FPSO 80 14 110 60
Active FPSO 52 13 119 39
Active FPSO 30 95 33
Active FPSO 43 1 74 22
Active FPSO 3 14 24
Laid up FPSO 27 117 61
Laid up FPSO 39 6 85 43
FOI compliance – lessons learned and tools for the future
Records indicate Australian FOIs are typical in
global performance.
Time efficiency – downtime offshore – items not available for survey or in non
functional state.
Statutory items -
avoiding PSC detentions
Class has more scope for
flexibility, but technical audit trail needed
Closing COCs within the 5
yearly special cycle
Other observations:
Restricted minor
corrosion not remedied can
build into serious
corrosion
Repair efficiencies,
i.e. blast and paint whole vs
spot remediation
Can Class work closer with the Operator for
mutual benefit
– Operations surveys
FOI compliance – lessons learned and tools for the future
Classification Society Issues
Site manning on sampling basis Attention to statutory
requirements
Conversion and transfer of class – availability of records
Early engagement of Class in scope
Working close with the operator
FOI compliance – lessons learned and tools for the future
FOI compliance
Australian FOI – the field of play
Lessons learned
Tools and techniques for the Future
FOI compliance – lessons learned and tools for the future
Improved Planning with the Operator
Understanding of LR survey scope Completion of routine
maintenance and renewal
Onshore preparatory workshops Aligning surveys with Ops
schedules and maximise efficiency
Improved planning
FOI compliance – lessons learned and tools for the future
Detailed Risk Based Inspection Management plan approved by Class
equivalent to:
Periodical Class Hull Structures Inspection regime
Machinery Class Planned Maintenance Scheme
Existing Flag State Certification regime
Overall facilities Verification scheme
Flag State approval required
Risk Based class – compliance but shifting the focus to critical areas
Feed in Lessons learned and
identified key focus areas
FOI compliance – lessons learned and tools for the future
Already Class approved and in common use:
Widely recognised for (external) OIWS
Internal ballast tanks – moving from experimental to implementation stage
Experimental/one-off use inside cleaned cargo tanks (not successful
so far)
Can we improve on current manual intervention and get better, more
accurate data?
ROVs
FOI compliance – lessons learned and tools for the future
Drones
Experimental use for inaccessible areas, but how
about tanks?
For tank inspection, same considerations as for ROVs,
but additionally:
Lighting of internal structures.
Intrinsically safe where not gas free
Station keeping
Load capacity vs size and duration
LR initiatives:
- GTC Singapore JIP
- Guidelines for Drones and ROVs use
FOI compliance – lessons learned and tools for the future
Operations crew to take photographic/video evidence on behalf of the surveyor, or remote monitoring from shore base:
The competence of the operations crew
Guidance from surveyor still required
Challenges for live data streaming
Ops crew support limited to items with visual examination
Managing Big Data
Other methods?
Jeff Baker
Offshore Business Development Manager, Australasia
Lloyd’s Register Marine and Offshore
1st Floor, 503 Murray Street, Perth.
T +61 (0)8 9318 7317
E jeff.baker@lr.org
Lloyd’s Register and variants of it are trading names of Lloyd’s Register Group Limited, its subsidiaries and affiliates.
Copyright © Lloyd’s Register International. 2017. A member of the Lloyd’s Register group.
www.lr.org
Thank you for your attention.
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