When is a ship not a ship?

10th March 2020

When is a ship not a ship?

Initial Report

Outline:

A report was received from an engineer, with 10 years’ experience on the same vessel, who was concerned about changes to the vessels’ status and the potential consequences.

What the reporter told us:

The vessel was built in 1997 and has always been registered in the same flag state – even when the name was changed the flag state remained the same. The vessel was purpose built for its role as a Floating Production and Storage Unit (FPSU) but has always been recognised and registered as a motor ship with multiple engines. As such it always had a Minimum Safe Manning Document (MSMD) and was crewed to STCW requirements with regards to certificates of competency and numbers.

Further dialogue:

A few years ago, the owners took a corporate decision to move away from the requirements to have  STCW certificated personnel onboard by applying for an exemption to the MSMD. This was granted by the flag state for a 5-year period which expired in 2019, but since that date neither a MSMD nor an exemption has been displayed. When asked, the flag state advised that the vessel did not need either as it was not self-propelled, (which came as a surprise to the reporter who had spent 10 years maintaining and running the engines and thrusters which are frequently used for heading control and on more than one occasion prevented a potential disaster when elements of the mooring arrangements failed in heavy weather). Instead the flag state issued a letter stating the vessel should be manned in accordance with IMO Res.1079.

IMO Res.1079 deals with manning requirements for Mobile Offshore Units (MOU). Flag states usually publish their own guidance based upon IMO resolutions but so far, the flag state in question has not done so.

There is a common argument that, as the vessel comes under HSE regulations (as an installation), the flag state rules do not matter. However, HSE regulations do not deal with manning requirements and the vessel is still floating and needs to be maintained to class requirements. It seems the IMO have long recognised the need for the manning on MOU’s to be regulated, as all over the world these vessels seem to fall into a grey area between HSE regulations and flag state rules.

CHIRP Comment: 

  • This is a confusing problem that is also a global issue because these specialised vessels are in service all around the world.
  • There are numerous vessels that fit into this category in the offshore industry from MODU’s to FSU/FPSO’s. What they have in common is that their respective flag states appear to have technical definitions that allow them not to be treated as a ship in the STCW definitions. Instead, their watchkeepers must have qualifications under the flag state definition, such as “MODU Master” and/or “OIM” qualifications. This even applies to MODU’s using dynamic positioning, if they remain in the same location.
  • A problem arises if they have to transit to another location, whereupon crew certification might dictate that the unit is towed. If they transit under their own propulsion, they would require STCW certification.

 

Reports Ends.

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