The USCG has proposed new regulation as outlined below:
DP Crew Proficiency/33 CFR 140.315 proposed regulation:
DP system training requirements.
a. The Dynamic Positioning Operator (DPO) must receive training and practical experience in the operation of the dynamic positioning (DP) system and its components. The content of training and experience must include all provisions of paragraph
(b) of this section, and the following:
(1) The DP system components, including the control station, power generation and management, propulsion units, position reference systems, heading reference systems, environmental reference systems, and external force reference systems, such as hawser tension gauges.
(2) The range of routine DP operations, as well as the handling of DP faults, failures, incidents, and emergencies, to ensure that operations are continued or terminated safely.
(3) The type and purpose of documentation associated with DP operations, such as operational manuals, Failure Modes and Effects Analysis (FMEAs), and capability plots.
b. To be qualified to operate a DP system, the Dynamic Positioning Operator, Qualified (DPOQ) must have—
(1) Completed training that provides an introduction to the functions and use of a DP system;
(2) Completed 30 days of DP system training on board a vessel equipped with a DP system, including training on the design, components, related and integrated shipboard systems, system redundancy alarms, and warnings for that specific vessel’s DP system;
(3) Demonstrated thorough knowledge of the DP system operating manual for the specific vessel on which the DPOQ will serve, including procedures for shifting the DP system between all normal operational modes and emergency procedures. A DPOQ who will serve on a vessel engaging in Critical Outer Continental Shelf (OCS) Activities must also demonstrate thorough knowledge of the industrial mission, including the Critical Activity Mode of Operations, and either the Activity Specific Operating Criteria or Well Specific Operating Criteria as defined in 46 CFR 62.10-1.
(4) Demonstrated a fundamental understanding of the specific DP system’s FMEA and its implications; and
(5) Demonstrated familiarity with the vessel’s specific DP system, including participating in a walkthrough of the design and mechanical features with the DPO, to include at a minimum—
i. Power generation;
ii. Power distribution;
iii. Thruster units and associated equipment;
iv. Power management/logic; and
v. DP system control interfaces and related electronics and computer functions.
c. DPOs and DPOQs must carry the original copy of their DP system record of training or be able to provide such a copy to a requesting authority within 48 hours of the request.
d) The Coast Guard will accept company letters, course completion certificates from a training institution, letters or course completion certificates from the DP system manufacturer, or certification from an industry-accepted organization as proof of DP system training.
e) The owner or operator of a U.S.-documented seagoing vessel using a DP system to maintain station must maintain a copy of each DPO and DPOQ training record in accordance with 46 CFR 15.1107.
f) All onboard DP system training must be documented in each mariner’s record of training in accordance with 46 CFR 15.1107.
g) The master, officers in charge of a navigational watch, and DPOs must be familiar with the characteristics of the vessel and the specific equipment fitted on it prior to operating the equipment as required in 46 CFR 15.405. This familiarization must include reading the DP system equipment and operations manual, DP system incident reports, FMEAs, and any documented history of the DP system. The familiarization must be documented.
The referenced USCG proposed regulation text and definition will be changed somewhat before it is put into legislation. However, presently, some of the concerns many have had in the past and still today are being addressed. It poses the questions; does the DPO know how to operate the operator stations and peripheral equipment on his/her vessel? How does this DPO respond to situations of potential or elevated risk exposure? How well do the personnel in “support departments” understand the situations and verbally expressed urgency of a predicted or ongoing event? The rapid expansion of vessel fleets, in deep-water operations, over the past five years created a demand for personnel, which were new to this industry, region and type of operations. There have been accelerated programs for personnel and advancements of personnel who may not have had the opportunity to be exposed to real-world scenarios, giving them a good understanding of the full scope of the action/reaction consequences. Now, this downturn of the O&G industry, persons have been furloughed or beyond to sustain business models. I can’t help but to think that this may be a perfect opportunity to train and certify those who are, perhaps, in need of assistance to become proficient in their skill. There will, undoubtedly, be an upturn in this sector and the demand for qualified personnel will be great. Will those people be there when called upon, or will we be forced to repeat the past by accelerated programs and promotion of persons not proficient in their skill? Through experience, we would suggest to use this time to train personnel.
Training programs have been developed and are readily available. How often do we conduct table-top discussions as “training” sessions? How effective are those sessions? Management personnel are seeing the value and effectiveness of group scenario training. Bridge Emergency Management courses have increased the crew’s awareness and proficiency. Why don’t we take this training to the next level by including engineering departments, electrical and mechanical, personnel as well? This will create a working relationship of trust by means of effective communication and understanding of actions to be taken, or avoided, during critical activities. The same can be said for the Bridge crew and Drilling crew. How many times have operations been slowed, stopped or has a close-call or near-miss occurred due to miscommunication or a misunderstanding? Crew proficiency evaluation and training will open the lines of communication and provide an understanding of operations versus actions and how they affect associated departments. Interdepartmental collaboration will provide for a well rounded and efficient crew, which would exceed most parts of the training the USCG has proposed in the forthcoming 33 CFR 140.315 regulations. This training ideally can take place in a controlled classroom environment or onboard a vessel in standby status to benefit most from the exercises.
What are your thoughts on this? How can companies find ways to meet the proposed regulation with the limited funds available?