Regulation concerning amendments to the Regulations on evacuation and life-saving appliances on mobile offshore units and the Regulations on radiocommunication equipment for Norwegian ships and mobile offshore units

The consultation
The proposal was circulated for review from 20 December 2023 to 21 March 2024. The NMA has received two consultative statements. The statements from the consultative bodies and the NMA's comments have been included in the consultation matrix, which is attached to this circular (available in Norwegian only).

Comments to the amendments to the Regulations of 2 February 2016 No. 90 on evacuation and life-saving appliances on mobile offshore units

To section 2
The reference in section 2 (a) to the SOLAS Convention has been updated to the current consolidated version.

To section 5
This amendment is editorial. The parenthesis referring to "(Risk analyses Regulations)" has been removed.

To section 6
The NMA has observed that the level of detail in the muster lists varies. Additionally, more detailed information may be available in other documents on board. The amendment to section 6 is in line with the practical application of the provision, and the muster list requirements now provide more comprehensive rules on what must be included in the muster list.

To section 16
The provision is repealed, and the relevant requirement have been transferred to the Regulations of 1 July 2014 No. 955 on radiocommunication equipment for Norwegian ships and mobile offshore units section 7.

To section 21
The pulling power requirement in the third paragraph (b) has been amended and no longer applies to free-fall lifeboats.

To section 28
This provision is repealed, and the relevant requirement have been transferred to the Regulations of 1 July 2014 No. 955 on radiocommunication equipment for Norwegian ships and mobile offshore units section 7 with a few minor linguistic changes..

To section 34
Based on the consultative statement from the Norwegian Ocean Industry Authority, the NMA has revised the first and second paragraphs of section 34 after the consultation. With these amendments now in place, the distinction between training and drills will be clearer. These amendments have also resulted in a change to the numbering of paragraphs within this section. The amendments made after the consultation are to provide a clear distinction between training and drills, and in the NMA's assessment, neither the scope nor the content of the amendments indicate that a new public consultation is required.

The former first paragraph has been repositioned as the second sentence of the first paragraph with linguistic changes. The former second paragraph is now the last sentence of the first paragraph, where a lingusitic change has been made, and a complete reference to the Regulations of 22 December 1993 No. 1239 on risk analysis for mobile offshore units has been included. 

In the first and second sentences of the second paragraph, training has been explained in more detail. In the Regulations of 22 December 1993 No. 1239 on risk analysis for mobile offshore units, section 16 fifth paragraph currently requires that the company's training manual must contain training programmed that have been developed on the basis of the defined accidents. It is the same training programme we now refer to in the second paragraph.

The former ninth paragraph has been moved to the last sentence of the second paragraph.

The former third and fourth paragraphs are no longer applicable. Both provisions wll become redundant following the amendments to the first and second paragraphs.

In the third paragraph (a), the NMA has taken feedback from the Norwegian Ocean Industry Authority into account. In the third paragraph (b), the NMA has replaced the word "tilsier" with "tillater" in the Norwegian version.

Following the consultation, the NMA has changed the requirement in the fifth paragraph from "shall" to "should", aligning with the wording of the first paragraph.

To section 36
In the first sentence of section 36 first paragraph, there is a requirement for the maintenance programme to satisfy SOLAS Regulations III/20 and III/36. Now, a reference has also been included in this provision to SOLAS Regulation III/3.25. In the third and fourth sentences of the first paragraph, it is specified that there is no requirement to launch lifeboats when the unit is offshore. Lifeboat launching should only be carried out under satisfactory conditions and after a risk assessment. The NMA believes that these amendments will reduce the risks to personnel and equipment and prevent reduction in lifeboat operational capacity during drills and maintenance activities. Following the consultation, the NMA has replaced the word "tilsier" in the fourth sentence with "tillater" in the Norwegian version.

The requirement in the fourth paragraph for maintenance to be carried out in accordance with the manufacturer's instructions has been removed, as maintenance is now covered by the SOLAS reference in section 36 first paragraph.

The requirement in the sixth paragraph for lifeboats to undergo testing every five years to the same extent as an installation test has been repealed. This was a specific Norwegian requirement, and experience shows that it is sufficient to carry out an installation test once.

Comments to the individual amendments to the Regulations of 1 July 2014 No. 955 on radiocommunication equipment for Norwegian ships and mobile offshore units

To section 7
Relevant requirements in the Regulations of 2 February 2016 No. 90 on evacuation and life-saving appliances on mobile offshore units sections 16 and 28 have been moved to section 7 second to fifth paragraphs, with some linguistic amendments. The requirement for radiocommunication equipment to be wheel-marked is specified in the Regulations of 30 August 2016 No. 1042 on marine equipment, Appendix IV. Regarding the requirement in section 28 fourth paragraph for VHF and SARD to be wheel-marked, there is therefore no need to specify this in the Regulations of 1 July 2014 No. 955 on radiocommunication equipment for Norwegian ships and mobile offshore units.

The reference to the MODU Code has been updated, maintaining the original content.

To section 8
The reference in section 8 has been updated and now refers to section 7 first paragraph.

The attachment "Excerpts from MSC/Circ. 561" is repealed, as it is no longer applicable. 

Administrative and financial implications
The regulatory amendments clarify existing requirements and are not expected to result in significant financial or administrative consequences for the authorities or the industry. Information provided to the NMA indicates that annual and five-year surveys are already carried out by authorised service providers on board Norwegian mobile offshore units. The transfer of distress communication equipment requirements from the Regulations of 2 February 2016 No. 90 on evacuation and life-saving appliances on mobile offshore units to the Regulations of 1 July 2014 No. 955 on radiocommunication equipment for Norwegian ships and mobile offshore units, constitutes technical amendments.

Attachment:

• Consultation matrix (available in Norwegian only)