Legislation
IMCA is active world-wide and at a regional level in representing its members to governments and regulatory bodies, lobbying for fair, workable, effective regulations on behalf of its members and monitoring and reporting on regulatory developments for its members.
While often carrying out this work through monitoring and liaison via member representatives, IMCA is also represented on a number of joint government-industry committees and other relevant bodies. Not least of these is having observer status at the International Maritime Organization (IMO). IMCA also participates in joint work with other relevant trade associations in areas of common interest.
Recent activities on this front are summarised below.
Links to National Regulatory Information Sources
IMCA's SEL Committee undertook a major expansion of the links section of this website, to include links to the websites of governmental websites containing information on offshore regulations. The first phase of this work is already live here on this site. Feedback on material already covered and that which members would find useful is welcomed.
Recent Issues
Safe Transfer of Personnel by Basket on the UK Continental Shelf
When UK regulators became concerned about the personal safety of offshore personnel being transferred by basket, IMCA's SEL Committee, in conjunction with the North Sea Chapter of the International Association of Drilling Contractors (IADC), set out to show that such transfer methods could be carried out safely and that they were indeed the most appropriate way of transferring personnel offshore in certain circumstances.
Guidelines issued in March 2001 were aimed at aiding risk assessment and the development of appropriate procedures for the safe transfer of personnel using personnel transfer baskets. They note that all means for personnel transfer have a unique hazard/risk profile and should be assessed separately, extending to the particular conditions on each occasion of use and the wishes of the personnel being transferred. These were subsequently referenced by the Health & Safety Executive (HSE) in its revised safety notice on the topic as reflecting good industry practice. It was noted on publication, however, that due to different established working arrangements in other geographical locations, the guidelines are not viewed as being necessarily applicable for global application.
Copies of the guidelines are available on request from IMCA.
US Coast Guard Letter of Compliance Rules
IMCA has provided comments to the US Coast Guard during the consultation period on proposed new rules for operations on the Outer Continental Shelf (OCS). IMCA has called for the Letter of Compliance (LOC) requirements to be based, to the maximum extent possible, on universally accepted standards as implemented through international institutions, such as the International Maritime and Labor Organizations, IMO and ILO.
For matters not covered by such international conventions, IMCA hopes the Coast Guard will consider a vessel classed with a recognised or other reputable classificaiton society where a competent person has certiifed that safety-critical elements of operational equipment comply with relevant international or industry standards.
IMCA also suggested that confined space entry requirements applied to foreign-flag vessels should be restricted to requiring the vessel to have procedures covering control of entry, atmospheric testing, permit to enter and relevant training/ information/ instruction to personnel involved.
EU Working Time Directive
IMCA members were provided with regular briefing on developments on this key issue over a number of years, from the original directive to the finalisation of specific regulations regarding 'Seafarers' and 'Other Work at Sea'. Monitoring of and reporting back to members on such developments is an important area of IMCA's work.
Publications
Application of UK Safety Case Legislation
IMCA has produced detailed new guidance to assist with the appropriate implementation of the UK Safety Case regime/guidance, designed largely for fixed platforms and rigs, to the specialist vessels operated by IMCA's members and, in particular, to those involved in well servicing operations.
Prepared for IMCA by Poseidon Maritime, "Application of UK Safety Case Legislation to Specialist Vessels - Well Servicing" (IMCA S&L 005) is designed to reduce the problems faced by contractor members when applying fixed platform regulations/guidelines to their specialist vessels. It also compares the ISM Code requirements with those from the UK Health & Safety Executive's health and safety management document HS(G) 65.
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