In order to maintain their international statutory certification, disconnectable FPSOs and FSUs have had to leave the riser at 5-yearly intervals to undertake renewal surveys in drydock. The down-time and lost production associated with these surveys results in their cost being much greater than for a comparable trading tanker. AMSA has long been concerned about the effect of these dockings on FPSO operations and has approved a performance-based inspection (PBI) regime for one Australian FPSO that enables it to remain on the riser for extended periods without drydocking. The presentation will outline the studies undertaken by the owner to satisfy the classification society and AMSA that the vessel is capable of continued safe operations over this extended period between dockings while continuing to meet classification society and statutory requirements.

1. AMSA Acceptance of Performance-Based
Inspection Regimes on FPSOs
Rob Gehling & Alex Schultz-Altmann
Ship Inspection & Registration
AMSA, Canberra

2. About AMSA
VISION - Safe and clean seas, saving lives.
MISSION - Ensuring safe vessel operations, combatting marine
pollution, and rescuing people in distress.
VALUES:
Professional –act with integrity and pragmatism in our approach
Collaborative –value and respect others and cooperate to
achieve our objectives
Dedicated – committed to MISSION and responsive to needs of
customers and stakeholders
Accountable –take responsibility for decisions and actions.

4. AMSA’s Safety Jurisdiction
• s.640 of the Offshore Petroleum and Greenhouse Gas Storage
Act 2004 dis-applies the Navigation Act 2012 from an offshore
vessel when that vessel is within the definition of “facility” under
cl. 4 of Sch. 3 of OPGGSA.
• FPSOs are subject to the Navigation Act 2012 at other times
such as on delivery/docking voyages to and from the operating
location or when they have dropped the riser to manoeuvre
away from the site in severe sea/weather conditions.

6. • Navigation Act 1912’s special treatment of offshore vessels and
units is discontinued
– Now subject to the same application criteria as other ships apart from
dis-application under OPGGSA
– Non-disconnectable cannot be treated as fixed platforms when not
“facilities” under OPGGSA
• So Navigation Act 2012 applies whenever OPGGSA dis-
application is not in force
– Delivery voyages including non-propelled vessels
– Docking voyages
– Release from riser to avoid severe weather/sea
Navigation Act 2012

8. Disconnectable FPSOs - 1
• FPSOs are required to have valid international safety
certificates whenever subject to Navigation Act 2012
• SOLAS and Load Line
• SOLAS reg. I/10 requires inspection of the outside of the
ship’s bottom twice in any five-year period
• Relevant survey guidelines Res. A.1104(29) and A.1049(27)
specify bottom inspections to be in drydock except that
alternate inspections (every second one) may be in-water
• Effectively requires drydocking every 5 years, which is generally
disruptive to FPSO operations
• Particularly in the final years of field life

9. • AMSA has long recognised this docking problem
• Note to 7.8 of Marine Order 60 (Floating Offshore Facilities)
provides for AMSA to accept in-water bottom inspections on
FPSOs if conditions are met
– but of doubtful legal effect in over-riding a Convention provision
• AMSA was active at IMO in development of MARPOL FPSO
Guidelines MEPC.139(53) providing some relaxation regarding
surveys, and MSC-MEPC.2/Circ.9 which urges Administrations
to take a pragmatic approach to the application of Convention
requirements to FPSOs
• The latter has not yet been incorporated into Marine Orders
Disconnectable FPSOs - 2

11. A Solution
• For the FPSO OKHA, AMSA has approved a Performance-
Based Inspection regime which pragmatically achieves equivalent
survey outcomes to the statutory bottom inspection provisions of
SOLAS and the Enhanced Survey Programme for oil tankers
• Based on an extensive study of the vessel’s current structural integrity and
predicted corrosion
• Vessel surveyed on-location and not required to leave riser for drydocking
while class society rules are complied with
• Equivalence issued under existing Marine Order 60.
• Similar studies initiated for a second FPSO to translate to PBI
Scheme

12. FPSO Lifeboat Safety
• FPSO problems extend beyond bottom survey to lifeboat drills
• AMSA recognises that davit-launched lifeboats may not be
readily and safely retrieved at sea but are still required by
SOLAS to be manoeuvred in the water each 3 months
• Safety of personnel in lifeboat is primary
• Equivalent arrangement involving enhanced maintenance
checks and annual assisted boat launching now issued for two
FPSOs – again this is a performance-based regime
• AMSA open to discussion with operators of other FPSOs
otherwise still subject to 3 month requirement

14. • AMSA is in the initial stages of reviewing MO.60
• It is proposed that MO.60 will be merged with MO.47 (MODUs)
• Some safety measures of the MODU Code are more
appropriate to the configuration and operation of FPSOs than
the corresponding traditional ship requirements
– eg. fire protection, escape, life-saving appliances
• PBI regimes to be alternative to 5-yearly docking cycles
Revision of Marine Order 60 - 1

16. • New MO will also cover other floating facilities (eg. FLNG, CPF)
when under the Act and may provide for voluntary maintenance
of safety certification when Act is dis-applied
– FLNGs to be subject to technical requirements of International Gas
Carrier Code
• Industry will be fully consulted
• Schedule is subject to drafting priorities but the new MO is
intended to be in place later this year
Revision of Marine Order 60 - 2

18. • Current and proposed actions by AMSA in relation to
application of statutory requirements to FPSOs are in
accordance with AMSA Values
– Professional – integrity, pragmatism
– Collaborative – value, respect, cooperation
– Dedicated – responsive, committed to Mission (ensuring safe vessel
operations, combatting marine pollution, and rescuing people in distress)
– Accountable – take responsibility
Conclusion

19. Any questions?