§ 3 Application of maritime regulations in the offshore petroleum activities
As regards mobile facilities registered in a national ship register, and which follow a maritime operational concept, relevant technical requirements in the Norwegian Maritime Authority's regulations for mobile facilities with supplementary classification rules provided by a classification society, or international flag state rules with supplementary classification rules providing the same level of safety, with the specifications and limitations that follow from Section 1 of the Facilities Regulations, can be used as an alternative to technical requirements laid down in and in pursuance of the Petroleum Act. The chosen maritime regulations shall be used in their entirety.
The Petroleum Safety Authority Norway can stipulate additional requirements, based on safety-related considerations.
Section last changed: 01 January 2019
The provision stipulates that relevant technical requirements in maritime regulations can, as a rule, be used as a basis as an alternative to requirements in the petroleum regulations, with the clarifications and restrictions that follow from Section 1, fourth subsection of the Facilities Regulations. For those areas covered by the provision and Section 1 of the Facilities Regulations, the responsible party need not observe the detailed technical requirements in the Facilities Regulations. When reference is still made to maritime standards in the Facilities Regulations, and in appurtenant comments, this is because these standards can also be relevant in areas not covered by this section. When the holder of an Acknowledgement of Compliance chooses to use maritime regulations as a basis, the entering into force of new provisions will follow the regulations of the Norwegian Maritime Authority in the areas covered by Section 3 of the Framework Regulations. According to the regulations of the Maritime Authority, this normally means entering into force at the next certificate expiry. In cases where the Norwegian Maritime Authority and the classification societies have rules on the same when using supplementary class rules as mentioned in the first paragraph, the Norwegian Maritime Authority's rules shall be used.
Use of this section, cf. Section 3, first subsection, presumes that the facility follows a maritime operations concept, has valid maritime certificates, and that the maritime regulations selected for use in pursuance of this section are used as a basis in their entirety.
By class institution as mentioned in the first subsection, is meant the institutions recognized at any time as mentioned in the Norwegian Maritime Authority's Regulations relating to the construction of mobile facilities Section 1 third point: “MOU class institution: Recognized class institution with which an additional agreement has been entered into to carry out control and inspection, etc. of mobile facilities. These institutions are:
- American Bureau of shipping (ABS)
- DNV GL
- Lloyd's Register of Shipping (LR).”
The provision covers use of mobile facilities registered in a national ship register, but is limited to mobile facilities that follow a maritime operations concept, and which are thus not permanently located on the shelf. The provision can e.g. include mobile drilling facilities, well intervention facilities, multi-use facilities and certain types of mobile production facilities. The provision thus does not include facilities resting on the seabed, floating production facilities that are permanently located, storage ships, etc., which is to say facilities that will operate on a field for the entire field life when they do not follow a maritime operations and maintenance philosophy.
Certain types of mobile facilities will be subject to a discretionary assessment as to whether they are covered by the provision or not. It is important in such cases that early contact is established with the supervisory authorities to achieve the necessary basic clarifications.
The provision includes maritime areas such as the hull, stability, anchoring, marine systems, etc.
Section 3 of the Framework Regulations and Section 1, fourth subsection of the Facilities Regulations together continue the overall intentions of the previous Section 3 of the Framework Regulations. The provision was changed to cover the wording of the Norwegian Maritime Authority's regulations following changes after 2007.
According to Section 1, fourth subsection litera d of the Facilities Regulations, any exemptions granted by the maritime authorities in connection with the maritime regulations with supplementary classification rules, shall be evaluated to identify any safety-related consequences for the facilities' planned use in the petroleum activities. If the assessment is that the petroleum activities can be carried out in a prudent manner as regards safety, and the responsible party thus wants to maintain the nonconformities, an overview shall be provided of previously granted exemptions for the mobile facility that are of importance to safety, which shall be submitted to the Petroleum Safety Authority Norway for processing.
For mobile facilities in the petroleum activities that are ISM certified, the responsible party can use the IMO resolution A.741 International Safety Management Code (the ISM Code) as a basis for the part of the management system that is related to maritime operating conditions, cf. paragraph three of the Guidelines relating to Section 17 of the Framework Regulations.
For new mobile facilities that are covered by the provision, means of evacuation for evacuation to sea should be in accordance with requirements in Section 44 of the Facilities Regulations. The same applies to major rebuilding or modifications to existing mobile facilities that are covered by this provision.
As regards utilisation of documentation, including maritime certificates, reference is made to Section 23, first subsection of the Framework Regulations. Reference is also made to the Guidelines for Section 25 of the Framework Regulations, which discuss the use of Acknowledgement of Compliance for mobile facilities (AoC) as documentation.
The ”065 - Handbook for application for Acknowledgement of Compliance (AoC)”, Revision 4 dated 1 January 2011, with any subsequent revisions accepted by the Petroleum Safety Authority Norway, provides the acceptable technical standards for the individual areas on a mobile facility, and also in other areas than those covered by this provision and Section 1, fourth subsection of the Facilities Regulations, and through this also clarifies what constitutes an acceptable interpretation of the technical basis for the various support systems and certain requirements for the working environment. Reference is also made to Norwegian Oil and Gas’ “Handbook for applications for consent for well operations from a mobile facility”, for further guidance on qualification of mobile facilities that are registered in a national ship register, according to the HSE regulations for the petroleum activities.
Reference is made to the Guidelines for Sections 24 and 70 of the Framework Regulations, wherein the relationship to standards in connection with exemptions is discussed.
About the terms vessel and facility
Depending on the activities executed in the petroleum activities, an executing unit is defined as a vessel or facility. The following is a description of the content of the two terms.
Activity that can be carried out by vessels will be where the executing unit is connected to a subsea well or a well on a fixed facility, but does not have primary control of the wells' block valves. The primary control of the well stream (christmas tree or well control equipment connected to the well) is handled by a facility (from control room and/or direct operation of check valves) other than the executing unit. Vessel activity can be carried out by a facility with AoC or a vessel without AoC.
Examples of such activities include pumping of various fluids (gas and liquid) into a well through a christmas tree or to a well valve, for fracking, stimulation, clean-up, etc., while well intervention is taking place (the well intervention personnel handle primary control of the well stream).
The same applies to activities involving maintenance of subsea wells (christmas tree or equipment on the subsea template) or replacement of equipment on subsea wells, where one is not connected to the well, and another facility handles primary control of the well stream.
Activity to be performed by a facility will be where the executing unit is connected to a subsea well with intervention equipment entering the well, and the unit has primary control of the wells' block valves. Primary control of the well stream (christmas tree valves or well control equipment connected to the well) is handled by the executing unit (from control room and/or direct operation of check valves). Surveillance/monitoring of the subsea well's christmas tree can take place at the same time from another facility. Facility activities shall be carried out by a facility with AoC.
Examples of such activities include wireline work and coiled tubing work in subsea wells where the equipment string/components are physically fed through the christmas tree and well control equipment in/out of the well.