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IMCA explains the unrealistic proposed US crewing exemption process

Published on 14 March 2022

The International Marine Contractors Association (IMCA) provides the following update to its Information Note (1606) published on March 1, 2022 on H.R. 6728, a proposed amendment to the Outer Continental Shelf Lands Act (“OCSLA”) that would impose burdensome new citizenship-based restrictions on crews of foreign flag vessels that work on offshore energy projects on the U.S. Outer Continental Shelf (“OCS”). This legislation remains under active consideration by the U.S. Congress. 

In order to better understand the adverse impacts of this legislation IMCA explains, from a practical perspective, how this proposed legislation would result in unnecessary and severe administrative burdens without providing any benefits.  

In short, this proposal would disrupt the process under current law which has successfully and efficiently been used for decades to obtain an exemption from U.S. citizenship requirements in order to continue to use the multi-national trained and experienced foreign crew on a vessel when engaged in OCS activities, and replace it with an unnecessary burdensome process that would take several months or more to obtain approval to continue to use the same multi-national crew that is used today aboard these vessels. 

The update, in the form of Information Note 1608 and can be found below.

IMCA Contact

Allen Leatt
Chief Executive