On 14 June, the Coast Guard issued its Supplemental Notice of Proposed Rulemaking (SNPRM) to follow up on the original Notice of Proposed Rulemaking (NPRM) it issued back in 2014. This original NPRM was never completed as a final rule where its initial purpose was to account for, and make more consistent, the marine casualty reporting requirements currently found in the Shipping regulations in the 46 Code of Federal Regulations (CFR) and the Outer Continental Shelf (OCS) regulations currently found in 33 CFR. Because offshore operations are an amalgam of conventional “underway” vessel activities (eg. crewing and supply/support vessel employment, etc.) and industrial activities performed by MODUs and offshore production facilities, these operations are currently subject to two sets of Coast Guard regulation found in entirely separate titles of the CFR (33 and 46). Superseding the original 2014 NRPM effort, this SNPRM contains much of the original 2014 intent to update 1982-era regulations to reflect the profound technological advancements experienced on the OCS since that time. The SNPRM also aims to harmonize casualty reporting requirements that apply to U.S. and foreign Floating Offshore [production] Facilities (FOFs), MODUs, and other vessels dedicated to OCS service.
IADC, the Offshore Operators Committee, the Center for Offshore Safety, and API are conducting a joint review of this proposal. This joint trades group recognizes the opportunity to provide ample comment where considerable efficiencies may be gained by improving upon existing marine casualty reporting requirements. This joint group is in the process of formulating its recommendations for submittal to Docket for this rulemaking. As the public comment period was due to close on 12 September 2023, this comment period will be extended for an additional 60 days to allow for further consultation with the National Offshore Safety Advisory Committee (NOSAC) at its next meeting on 13 September 2023. Interested parties are encouraged to comment as they are inclined to do so. Additionally, members of the respective associations participating in this joint effort may engage in forthcoming meetings by contacting their association representatives. IADC members may contact Jim Rocco at jim.rocco@iadc.org for more information or to express interest in directly participating in the joint association meetings.
