|Date reported||22 July 2015|
|Concern title||Operator’s procedure for awarding of contracts|
The concern related to the operator’s procedure for awarding contracts to move sub-sea infrastructure.
|Industry / Operation affected||Marine: Shipboard operations|
|Concern subject type||Marine: Ship operations|
The reporter expressed a safety concern relating to the auditing of vessels conducted by [operator] when awarding contracts to move offshore rig sub-sea infrastructure.
The reporter advised that [operator] had contracted a number of vessels to assist in the moving of an offshore rig. This work consisted of the movement of the rig itself and the recovery of the pre-laid anchors.
The reporter advised that one of the vessels contracted had not worked with the other vessels before this operation. The organisers gave this vessel a significant role in the operation.
During the course of the operation, it became apparent that the vessel was significantly slower than the other vessels involved. On further questioning, it became clear that the vessel master and crew did not have the required experience for the operation. This resulted in significant communication problems between the crews of the different vessels, and placed the crew of the vessel in question, in dangerous situations.
A full audit of the safety management systems and the application of the operator’s published safety requirements should have discovered these issues prior to the operation.
Reporter comment: It is my opinion that lack of understanding and inexperience in the offshore industry is once again on the increase and if not corrected it may well lead to yet more fatalities.
Operator's response (Operator 1)
No specific details are provided of the vessel or date/timeframe the subject of the allegations. We are therefore unable to provide specific details of inspections that were conducted.
We have a rigorous inspection process for the mobilisation of vessels that assist in our petroleum operations. Our corporate guidelines apply to vessel inspections prior to mobilisation. The process of inspection of vessels prior to mobilisation is described below.
Our corporate standard has a requirement for all vessels to have a valid Offshore Vessel Inspection Database (OVID) and Offshore Vessel Management and Self-Assessment (OVMSA) entry in the system. An additional supplementary inspection is conducted in the Australasia business unit (ABU) which involves the checklist for the type of vessel and is made up of additional local requirements and lessons learnt. A vessel is nominated for a particular scope of work. We commission an inspection through the oil companies international marine forum (OCIMF) OVID website based on the capability of the vessel. The vessel is inspected by an accredited third party OCIMF OVID inspector. This inspection is validated on the OCIMF website by us as the OCIMF member.
An ABU checklist inspection for the type of vessel will also be conducted if required by operating guidelines.
The vessel operator provides their initial comments within 14 days. This response is to the findings of the ABU checklist and is assessed by the marine team. An updated list of pending items is then passed back to the vessel operator. Once the operator has published their initial comments, we then rate the vessel in the internal risk based database, which holds records of the vessel’s history and has pre-set ratings for items identified in the OVID inspection.
ABU action tracking register is the internal tracking tool used to monitor close-outs of all deficiencies from an ABU checklist inspection and the internal database is utilised to track vessel operator responses to OVID inspection queries. If the [operator] marine authority is not satisfied with the response to the OVID and ABU checklist findings, the vessel will not be given clearance to mobilise.
[Operator] also conducts inductions for all new crewmembers and for replacements as applicable.
Prior to any rig moves being conducted, the team organises a pre-rig move meeting, which is attended by:
- vessel operators involved in the rig move
- contractor representatives who provide the moorings when we utilise pre-lays
- the contractor that provides the positioning system, and
- any [operator] upstream personnel from [location 1] and [location 2] that have vessels in the area relevant to SIMOPs, and [operator] marine logistics team representatives.
The rig contractor provides the rig move procedure.
If a vessel is new to working on our petroleum operations, the vessel master will be given support to operate at the pace necessary in order to complete the task safely. The experience has been that vessels new to a task (such as rig move) will operate more slowly in order to complete the task safely, but will be able to operate faster as familiarity and experience is gained. All personnel are empowered to stop the work if they are concerned about an unsafe condition.
We conducted Joint OVMSA Verification & Assessments on a number of vessel operators last year at their offices and these reports are held in the OVIS system.
Since August 2013, we have conducted 174 vessel inspections and information on vessel inspections is available in our database.
Regulator's response (Regulator 1)
National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) has reviewed the report and notes, in the first instance, that while the subject refers to ‘contracts to move sub-sea infrastructure’ the report itself is concerned with anchor handling and towing associated with the [operator] Mobile Offshore Drilling Unit. Clause 3 of Schedule 3 to the Commonwealth Offshore Petroleum and Greenhouse Gas Storage Act 2006 explicitly excludes anchor handlers and tugboats from being associated offshore places and hence the vessels that are the subject of this report do not appear to have been within NOPSEMA’s jurisdiction. Further, to the best of our knowledge the [rig] is no longer operating in Commonwealth waters.
Regarding your specific request for a response; based on the above information NOPSEMA does not propose to take any action.
Regulator's response (Regulator 2)
Australian Maritime Safety Authority (AMSA) has considered the implications of the report and proposes to continue to monitor the activities of concern to the reporter, in accordance with and as constrained by AMSA’s port state control and flag state control functions and powers.
AMSA notes that the primary way in which AMSA discharges its responsibilities is to ensure, to the extent practicable, that:
- vessels are constructed, equipped and maintained to meet, and accordingly certified as meeting, applicable international standards
- the operation of vessels is in accordance with, and certified to be in accordance with, international safety management system standards, and
- vessels are manned by seafarers trained and certified in accordance with applicable international standards.
However, this can only be done when the vessels are subject to the regulatory regime administered by AMSA. We note this matter was also raised in the NOPSEMA response.
Foreign flagged vessels are only occasionally subject to the regulatory regime administered by AMSA, depending on their geographical location.
That said, AMSA has no substantial basis on which to doubt that the vessels, their operations and their manning do not continue to meet, and are certified as meeting, the applicable international standards.
In the absence of specific detail of the actual vessels or about the alleged ‘dangerous situations’ referred to by the reporter, it is difficult for AMSA to identify what regulatory powers, if any, might be available and appropriately exercised in response. AMSA will nonetheless continue to monitor the activities in question, in accordance with and as constrained by AMSA’s port state control and flag state control functions and powers.
It is also relevant that AMSA regulate ships, the seafarers on board those ships and the operators of those ships. We do not regulate charterers or their activities. In this regards, AMSA finally notes that it has no power to veto or otherwise intervene in the commercial arrangements that [operator] and other entities make in order to meet their capability requirements. If entities use vessels that are constructed, equipped, maintained, operated and manned in accordance with applicable international standards, and certified accordingly, AMSA has no basis on which to require anything more or to prevent the use of those vessels by those entities.