Guideline for Offshore Floating Facilities (GOFF) - [Ikhwan] - 2020.pdf

© 2020 Petroliam Nasional Berhad (PETRONAS)
All rights reserved. No part of this document may be reproduced in any form possible, stored in a retrieval system, transmitted and/or disseminated
in any form or by any means (digital, mechanical, hard copy, recording or otherwise) without the permission of the copyright owner.
Guideline for Offshore Floating Facilities
(GOFF)
DOSH, MARDEPT & PETRONAS
Briefing Pack
03.03.20
M. Ikhwan B. M. Akhir (MPMPOMAsset Assurance)
Internal

© 2019 Petroliam Nasional Berhad (PETRONAS) |
Content
SECTION 1: INTRODUCTION
SECTION 2: AGENCIES INVOLVED AND LEGISLATIVE REQUIREMENTS FOR
FLOATERS
SECTION 3: MANAGING HEALTH, SAFETY, ENVIRONMENT AND SECURITY RISKS
SECTION 4: MANAGING ASSET INTEGRITY AND RELIABILITY
SECTION 5: MANAGING INCIDENTS RELATING TO FLOATING FACILITY ACTIVITIES
SECTION 6: TRAINING AND COMPETENCY REQUIREMENTS
SECTION 7: HSE CASE
SECTION 8: MISCELLANEOUS
SECTION 9: CONCLUSION
01.
02.
03.
04.
05.
06.
07.
08.
09.
04
09
13
15
30
33
37
41
43
Internal

Objectives
• To brief relevant parties on the implementation of the Guideline for Offshore Floating
Facilities (GOFF)
• To provide guidance on the legal requirements in managing HSSE matters onboard
floaters that are operating in Malaysia waters.
• To present demarcation of roles and responsibilities of the respective agencies.
Internal

SECTION 1: INTRODUCTION
Internal

Introduction
• In general, an Offshore Floating Facility is an Oil & Gas asset that can be relocated
from field to field following completion or depletion of Oil & Gas reserves.
• The Offshore Floating Facilities are designed to cater for Production, Storage and Off
loading. Some may cater for Production only (i.e. TLP, Semi-FPS, SPAR, etc.)
• As Offshore Floating Facilities have vessel characteristics and sea-going features,
these assets fall under the purview of several Government agencies:
a) Department of Occupational Safety and Health (DOSH).
b) Malaysia Marine Department (MARDEPT)
Internal

Introduction
• With the involvement of several Government agencies, there are overlapping scope,
roles and responsibilities. Therefore, GOFF clearly defines and demarcate the roles
and enforcement scope of each agency, enhancing the existing legal framework.
• GOFF will guide the Petroleum Arrangement Contractors (PACs), Asset owner and
Service providers in meeting the minimum regulatory requirements for operating
floaters within Malaysia waters.
• GOFF is applicable for Malaysia Upstream Oil & Gas industry and shall be read
together with:
a) OSRMS (Offshore Self Regulation Management System)
b) PPGUA (PETRONAS Procedure & Guideline for Upstream Activities)
Internal

Introduction
• On 3rd February 2020, GOFF was launched by DOSH, MARDEPT & PETRONAS and
was made effective with a one (1) year grace period.
• Therefore, all Offshore Floating Facilities operated by PACs are subject to audit by
DOSH & MARDEPT after the grace period.
Internal

Offshore Floating Facilities
Figure 1 – Types of Offshore Floating Facilities
Internal

SECTION 2: AGENCIES
INVOLVED AND LEGISLATIVE
REQUIREMENTS FOR
FLOATERS
Internal

Related Agencies
• In general, there are two (2) levels of agencies or authorities that provide the
legislative requirements for floaters:
1) Primary Level:
i. Department of Occupational Safety and Health (DOSH),
ii. Malaysia Marine Department (MARDEPT) and
iii. Petroliam Nasional Berhad (PETRONAS)
2) Secondary Level:
i. Department of Environment (DOE)
ii. Civil Aviation Authority of Malaysia (CAAM)
iii. Department of Fisheries (DOF)
iv. Malaysia Maritime Enforcement Agency (MMEA)
v. Malaysian Communication and Multimedia Commission (MCMC)
Internal

Element 1 - Policy and Strategic Objectives
Element 2 - Organizational Structure and Responsibilities
Element 3 - Planning and Implementation
Element 4 - Measure System Performance
Element 5 - System Performance and Management Review
Element 6 - Audit
Malaysia Offshore Statutory and Regulatory Context
Occupational
Safety and Health
Act 1994
(Act 514)
Petroleum (Safety
Measure) Act
1984
(Act 302)
Petroleum
Development
Act 1974
(Act 144)
P.U(A) 106;
Factories and Machinery
(Exemption to Petroliam
Nasional Berhad) Order
2013
Factories and
Machinery Act 1967
(Revised - 1974)
(Act 139)
PETRONAS Procedure and Guideline for Upstream
Activities (PPGUA)
Offshore Self Regulation Management System
(OSRMS)
Petroleum Arrangement Contractor
Health, Safety, Security and Environment Management System
Asset Integrity and Reliability Management System
Petroleum
Arrangement
Contract
* Enforce by;
Department of Safety and Health (DOSH) Petroliam Nasional Berhad (PETRONAS)
Vol 3 Health Safety, Security and Environment
Vol 6 Field Development and Project Governance
Vol 7 Drilling and Well Operation
Vol 8 Production and Operation Management
Vol 11 Others
Merchant Shipping
Ordinance 1952
Malaysia Marine Department
Internal

PPGUA Vol. 11, Section 11 – Marine Management
• Offshore Support Vessel (OSV):
AHT, AWB, DSV, FCB, etc.
• Mobile Offshore Unit (MOU):
MODU, MOPU, FPSO, FSO, etc.
Internal

SECTION 3: MANAGING
HEALTH, SAFETY,
ENVIRONMENT AND
SECURITY RISKS
Internal

HSSE Management
This section elaborate on the management of Health, Safety, Security and Environment
(HSSE) risks. It also covers social, security, aviation and process safety management as
these are considered as risk to the business.
i. Occupational Health and Safety Risk Management
ii. Social Risk Management
iii. Environmental Risk Management
iv. Health, Safety and Environmental Management System
v. Security Management
vi. Process Safety Management
vii. Aviation Safety Management
Internal

SECTION 4: MANAGING
ASSET INTEGRITY AND
RELIABILITY
Internal

Management of Certificated Machinery
• The requirements for managing asset integrity and reliability for all PETRONAS
Offshore Facilities operating in Malaysia are spell out in the OSRMS in response to
P.U.(A) 106 (Exemption to Petroliam Nasional Berhad) Order 2013.
• All PA Contractors, Asset owners and Service Providers shall establish a structured
system for managing their asset integrity and reliability.
• The system established could be tailored according to PA Contractors’, Asset owners’
and Service Providers’ need, however, it shall incorporate these six (6) key elements:
i. Policy and Strategic Objectives
ii. Organisation Structure and Responsibilities
iii. Planning and Implementation
iv. Measure System Performance
v. Review System Performance
vi. Audits
Internal

• P.U.(A) 106 (Exemption to Petroliam Nasional Berhad) Order 2013
28 March 2013:
The Minister Of Human Resources exercise his power makes an order under Section 55(3) of FMA
1967 give exemption to all offshore machinery owned by PETRONAS. The Order titled “Factories and
Machinery (Exemption to Petroliam Nasional Berhad) Order 2013” with eight (8) conditions. The
conditions of exemption are highlighted in the paragraph 3 of the Order.
*Notes:
1. Section 19 – Certificate of fitness.
2. Section 36 – Installation of machinery.
Act
Regulation
Order
Code of practice
Guideline
Internal

2013 – FMA1967; P.U(A) 106 2013 – OSRMS 2020 - GOFF
Certificated Machinery “owned”
by PETRONAS only.
Certificated Machinery regulate
by DOSH & MARDEPT
Certificated Machinery
regulate by DOSH only.
Focusing on Self Regulation
specified in P.U(A) 106,
exemption conditions
OSR expand to
floaters with clear
demarcation
Internal

• Element 3.1 of the OSRMS requires PA Contractors, Asset owners and Service
Providers to assure the integrity and reliability of its certificated machinery at the
offshore installation.
• In the context of OSRMS, certificated machinery refers to equipment that have been
identified in FMA 1967 requiring certificate of fitness (CF) such as:
i. Pressure Vessels.
ii. Steam boilers.
iii. Hoisting machines.
Internal

• FMA 1967; P.U.(A) 106 Order 2013 have given conditional exemption to PETRONAS
to self-manage the certificated machinery owned by PETRONAS.
• Hence, PETRONAS had introduced its own approach in managing the certificated
machinery through OSRMS:
 OSRMS, Appendix B (Part 1), covers the full life cycle of the PV and boilers.
 OSRMS, Appendix B (Part 2), covers hoisting machines.
• Based on the approach mentioned PA Contractors, Asset owners and Service
Providers are accountable and responsible to ensure all requirements specified in
OSRMS, Appendix B are adhered to.
Internal

• However, the exemption of P.U. (A) 106 Order 2013 and the requirements specify in
OSRMS, Appendix B does not apply to rental PV, Boilers and Hoisting machines.
• Hence, the owner of the rental PV, Boilers or Hoisting machines is required to hold a
valid CF and the relevant PA Contractor shall submit a list of rental equipment to
PETRONAS (MPM) prior to operating the rental certificated machinery in any of
PETRONAS facilities operated by the PA Contractor.
Internal

• In order for PETRONAS to self-manage its own certificated machinery, OSR Inspector
shall undertake the assurance task on asset Integrity & reliability related to the
machinery.
• PETRONAS has set out the requirement, competency framework, role and
responsibilities of the OSR Inspector in OSRMS, Appendix C which consists of five (5)
parts:
 Part 1 – Detailed on the commissioning and authorization of the OSR Inspector.
 Part 2 – Overview of the OSR competency framework.
 Part 3 – Elaboration of the roles and responsibilities of the OSR Inspector.
 Part 4 – OSR Inspector duties.
 Part 5 – Code of ethics that need to be conform by the OSR Inspector.
Internal

• While for rental certificated machinery, the owner must obtain a valid CF from the
relevant authorities.
• However, due to the Class Rules, GOFF had demarcate the CF as per below:
 CF for PVs and boiler for Topside process facilities will be under jurisdiction of
DOSH.
 Cargo Handling Machinery and Gear Certificates for Hoisting machines will be
under jurisdiction of MARDEPT.
• As reference, there are three (3) Orders under DOSH with regards to CF for
Certificated Machinery:
a) P.U.(A) 106 – Exemption to PETRONAS, 2013
b) P.U.(A) 179 – Exemption on CF for Hoisting Machine, 2015
c) P.U.(A) 261 – Exemption on CF for UPV, 2017
Internal

* Topside Process Facilities
Factory & Machineries
Acts 1967
Certificated Machinery on
Pressure Vessels
Steam Boilers
Hoisting machines
DOSH
MARDEPT
DOSH
Merchant Shipping
Ordinance 1952 and
Class Rules
Machinery on Offshore Floating
Facilities
* Hull & Marine system
Pressure Vessels
Steam Boilers
Hoisting machines MARDEPT
MARDEPT
MARDEPT
As per GOFF, Hoisting machines
on Offshore Floating Facilities are
regulated by MARDEPT
Internal

Follow P.U.(A)
106: Exemption to
PETRONAS
Asset owned by
PETRONAS
CF (EIAC) by
OSR inspector
Follow DOSH
process
Asset not owned
by PETRONAS
CF by
DOSH inspector
PV & Steam Boiler for
Topside Process
Facilities
* Topside Process Facilities
Factory & Machineries
Acts 1967
Pressure Vessels
Steam Boilers
Hoisting machines
DOSH
MARDEPT
DOSH
CF (Cargo Handling Machinery and Gear
Certificates) for Hoisting machines on Offshore
Floating Facilities shall be issued by Classification
bodies recognised by MARDEPT
Internal

Area / Equipment Applicable Law/Regulation Responsible Authority
Pressure vessels & Boiler (in Topside process
facilities)
• Factories and Machinery Act 1967 DOSH
Hull & Marine System (inclusive of Pressure
vessels and Boiler for marine operations)
• Merchant Shipping Ordinance 1952
• Merchant Shipping Ordinance (amendment) 2016
• Class Rules
MARDEPT
Pipeline & Riser • Petroleum Safety Measure Act 1984
• Petroleum (Safety Measures), (Transportation of
Petroleum by Pipelines) Regulations 1985
DOSH
Floater Storage tank (Crude, LNG, etc) MARDEPT
Hoisting Machines / Lifting Equipment
• Class Rules
MARDEPT
Accident Reporting (inclusive of Personnel,
Certificated Machinery & Floater)
• Occupational Safety and Health Act 1994
• Occupational Safety and Health (Notification of Accident,
Dangerous Occurrence, Occupational Poisoning and
Occupational Disease) Regulations 2004
DOSH
• Class Rules
MARDEPT
Demarcation of Authority as per GOFF
Internal

Demarcation of Authority as per GOFF
Lifting Equipment (LE)
Pressure Vessel (PV)
Hull & Marine system
MARDEPT
DOSH
Reference:
Internal

Classification
• Classification is a form of design and construction oversight carried out by a
classification society in accordance with the published Class rules and guidelines of
the selected classification society.
• The classification process may consist of:
i. Review and approval of technical submissions in accordance with relevant
class rules.
ii. Physical confirmation of manufacture & fabrication.
iii. Physical confirmation of assembly or installation of components or finished
item in accordance with approved drawings and details.
iv. Physical confirmation of subsequent testing as required by the rules and
associated issuance of documents attesting to the degree of compliance with
the requirements of the classification society.
Internal

Classification
• Classification society is a non-governmental organisation that establishes and
maintains technical standards for construction and operation of marine vessels and
offshore units.
• Classification society is responsible for classification of all offshore units where the
society workforce validates the design and calculations of the offshore units.
• The following classification bodies have been recognised to act on behalf of
MARDEPT for the surveys and certifications:
i. American Bureau of Shipping (ABS)
ii. Bureau Veritas (BV)
iii. Det Norske Veritas Germanischer Lloyd (DNVGL)
iv. Lloyd's Register of Shipping (LRS)
v. Nippon Kaiji Kyokai (ClassNK)
vi. Korean Register of Shipping (KR)
vii. China Classification Society (CCS)
viii. Indian Register of Shipping (IRS)
ix. Registro Italiano Navale (RINA)
x. Ship Classification Malaysia (SCM)
Internal

SECTION 5: MANAGING
INCIDENTS RELATING TO
FLOATING FACILITY
ACTIVITIES
Internal

ACCIDENT REPORTING
Operation Crews
Marine crews
(Seafarer with valid COC)
PETRONAS
DOSH MARDEPT
Accident
Reporting
(by PAC)
PETRONAS
Employee
exempted from
OSHA 1994,
Section 3
Employee
under OSHA
1994
Note:
1. OSHA 1994 requires an employer to notify the nearest DOSH office on any accident, dangerous occurrence, occupational poisoning and
occupational disease that has occurred in the place of work.
2. NADOPOD 2004 provides further requirement and information on the notification method, procedure and process to be followed by the
employer and the medical practitioner in pursuant to the requirements of OSHA 1994, section 32.
3. PETRONAS also requires PA Contractors to notify on any incidences that occur on floating facilities as per PPGUA, Section 1.6 of
Volume 3: Health, Safety, Security and Environment
4. Marine incidents in relation to hull, machinery and marine crew (Seafarer with valid COC) shall be reported to MARDEPT by notifying the
Marine Operation Division via email at bom@marine.gov.my.
Internal

ACCIDENT REPORTING
Topside Process Facilities
Ship Hull & Marine system
PETRONAS
DOSH MARDEPT
Accident
Reporting
(by PAC)
PETRONAS
Note:
1. OSHA 1994 requires an employer to notify the nearest DOSH office on any accident, dangerous occurrence, occupational poisoning and
occupational disease that has occurred in the place of work.
2. NADOPOD 2004 provides further requirement and information on the notification method, procedure and process to be followed by the
employer and the medical practitioner in pursuant to the requirements of OSHA 1994, section 32.
3. PETRONAS also requires PA Contractors to notify on any incidences that occur on floating facilities as per PPGUA, Section 1.6 of
Volume 3: Health, Safety, Security and Environment
4. Marine incidents in relation to hull, machinery and marine crew (Seafarer with valid COC) shall be reported to MARDEPT by notifying the
Marine Operation Division via email at bom@marine.gov.my.
Internal

SECTION 6: TRAINING AND
COMPETENCY
REQUIREMENTS
Internal

Training
• Operational and marine crews are required to be trained based on their work tasks.
• Due to the uniqueness of the offshore floating facility operations (i.e. marine,
operations), PA Contractors, Asset owners and Service Providers are required to:
i. Determine the necessary competency;
ii. Ensure the competency program is conducted;
iii. Ensure, where applicable, the necessary actions to acquire and maintain the
competency are taken and evaluate the effectiveness of the actions taken for
these two types of crews.
• The competency requirements and framework (i.e. Training Matrix) must be available
to both the asset integrity and reliability management system (i.e. AIR-MS) as well as
safety and health management system (i.e. HSE-MS).
• PA Contractors and Service Providers shall oblige to all relevant Authority
requirements pertaining to the competency of their personnel (i.e. Crane operator,
OSR inspector, Seafarers, etc.).
Internal

Training
Table 2 – General Floater Roles & Responsibilities
No Roles Responsibilities Authority
1 Offshore Installation
Manager (OIM) or
Person in Charge
(PIC)
A competent person appointed by the owner as the Person
in Charge, who has complete and ultimate command of the
unit and to whom all personnel on board are responsible.
Department of
Occupational
Safety and Health
(DOSH)
2 Maintenance
Supervisor and
Technician
Responsible and trained to maintain mechanical, electrical,
instrumentation and communications equipment. The
Maintenance Supervisor on some floater may also be
referred to as the Chief Engineer, Technical Section Leader
and Rig Mechanic.
3 Production
Supervisor and
Technician
Responsible to operate and handle hydrocarbon process
facilities and production operations
4 Operation and
Services
Responsible for all other activities necessary for and
efficient offshore operation. This include personnel
dedicated to logistical, crane and material handling,
helicopter operation, material, and catering etc.
5 Marine Crew
(Seafarers)
Responsible for all activities related to floater operation,
including propulsion, thruster and ballasting operations,
maintenance of vessel stability, monitoring of mooring loads,
deck loading, and station keeping. May comprise the OIM,
Barge Supervisor, Ballast Control Operator and
Maintenance Supervisor as well as other Deck and Engineer
of Officers, Radio Operators and rating defined in STCW
Convention as amended.
Malaysia Marine
Department
(MARDEPT)
Internal

Training
• PPGUA, Volume 11: Others, states that all marine crews shall meet the competency
requirement as per Standard Training Certification for Watchkeeping 1978 as amended
and recognised by MARDEPT.
• DOSH also specifies the OSH competency requirements for personnel in DOSH
website www.dosh.gov.my.
Internal

HSE Case
• HSE case is a document that addresses safety impact in throughout the life cycle
phases of the facilities.
• The HSE case must demonstrate that all Major Accident Hazards (MAH) have been
identified and controlled, mitigation and recovery measures are provided or
implemented and emergency response plans in relation to those MAH have been
prepared.
• PA Contractors, Asset owners and Service Providers shall comply with PPGUA,
Volume 3: HSE when executing its operations.
Internal

• Safety case requirement regulated following the 1988 Piper Alpha disaster in the
North Sea. Piper Alpha resulted in 167 deaths and substantial financial losses to the
UK industry and Government.
• Management of safety is the responsibility of the operator and not the regulator.
HSE Case Background
167 deaths
1.7 billion
1976 1988
Internal

HSE Case Contents
Identify Major Accident Hazards (MAH)
Describe the Risk & Control
Reduce the Risk to ALARP level
Establish Emergency Responses Plan (ERP)
Establish Performance Standard for SCE
HSE Case
Note:
1. ALARP – As Low As Reasonably Practicable
2. SCE – Safety Critical Equipment
Internal

SECTION 8: MISCELLANEOUS
Internal

Miscellaneous
• For an Asset Integrity and Reliability (AIR) system to be successfully implemented,
the system requires some basic management system components. These components
are considered crucial for effective implementation.
Planning &
Control
Management
of Change
Performance
Monitoring
Assurance
Records &
Documentation
AIR-MS
Internal

SECTION 9: CONCLUSION
Internal

Conclusion
• In conclusion, GOFF clearly defines the roles and enforcement scope of DOSH,
MARDEPT and PETRONAS.
• The enhancement of the existing legal framework for floaters has been discussed with
special attention given towards the management of certificated machinery, i.e. process,
responsible approving Authority.
• PA Contractors, asset owners and Service Providers shall refer to this guideline in
meeting the minimum regulatory requirements.
• Apart from this guideline, PA Contractors, Asset owners and Service Providers shall
also comply with the requirements stipulated in OSRMS and PPGUA.
• Compliance with these guidelines will ensure that all activities related to floating
facilities can be conducted in a proficient, prudent, safe and effective manner.
Internal

Thank you for your passion!
Internal

For any enquiries related to GOFF
kindly email to:
Ikhwan_akhir@petronas.com.my
Internal

Guideline for Offshore Floating Facilities (GOFF) - [Ikhwan] - 2020.pdf

Recommended

Recommended

More Related Content

Similar to Guideline for Offshore Floating Facilities (GOFF) - [Ikhwan] - 2020.pdf

Similar to Guideline for Offshore Floating Facilities (GOFF) - [Ikhwan] - 2020.pdf (20)

Recently uploaded

Recently uploaded (20)

Guideline for Offshore Floating Facilities (GOFF) - [Ikhwan] - 2020.pdf