The deadline is December 9th for industry and the public to comment on a Coast Guard proposal to create a SEMS rule for vessels that work in the oil and gas industry.   At last check, there were only five comments on the public docket, almost all of them against the proposal (and at least one of them not for polite company).

Coast Guard inspectors on the job

This is an Advanced Notice of Public Rulemaking, meaning the Coast Guard will still need to go through more steps if it really wants to require  SEMS on offshore vessels like MODUs, OSVs, liftboats, crewboats  and construction vessels.   However, many in industry believe there will eventually be some kind of SEMS regulation for vessels.   For boats that already have  International Safety Management (ISM) plans, the simplest solution would be an appendix that adds the parts that are in SEMS but not ISM.   For them the worst case scenario would be if they had to adopt ISM and SEMS as two separate plans.

Domestic service vessels that do not have ISM have much more to worry about.  Without any safety management system, they would have a hard time bridging to SEMS.   We are advising clients and working with them to develop a safety management system internally so they are prepared if the Coast Guard moves forward with a SEMS approach.   

You can (and should) read the Coast Guard proposal here.  The Coast Guard says it may affect 2200 vessels.

In the meantime, there is another Coast Guard proposal out that is a bit of a mystery.   On October 25th, the Coast Guard sent a proposal to the White House for review titled  Training of Personnel and Manning on Mobile Offshore Units and Offshore Supply Vessels Engaged in U.S. Outer Continental Shelf Activities.    However, there was no explanation of what that might cover or when the Coast Guard hopes to have it out.

If your company needs help creating a safety management system, contact us.

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