reference (i)
OOC Guidance: Fixed Platform Means of Escape
1
Regulatory Background & Intent
The United States Coast Guard (USCG) under 33 CFR 143.101 outlines required means of escape from
fixed offshore platforms. These requirements cover manned and unmanned OCS facilities with the intent
to provide offshore workers at least two means of escape from a fixed platform in the event of an
emergency. The intent of the regulation is not to have stairways or ladders that extend into the water, but
to enable accessibility to a personnel landing or level closest to the water surface. These escape paths
must be free of obstructions and maintained in a safe condition at all times.
2
Means of Escape
There are two categories for means of escape, primary and secondary.
2.1
Primary Means of Escape (PME)
A primary means of escape must be a fixed stairway or a fixed ladder of metal construction, which is
accessible from the uppermost deck level that contains living quarters or that personnel occupy
continuously, to each successively lower working level and then to the personnel landing.
2.2
Secondary Means of Escape (SME)
A secondary means of escape can be either the same as a primary means or portable, flexible ladders,
knotted man ropes or other devices approved by the OCMI that extend from the uppermost working level
to or beyond the elevation of the personnel landings.
For single well caissons, a Secondary Means of Escape (SME) can be jumping from the work deck if it
is: (a) no more than 20-feet by 20-feet (or 400 square feet) in size, and (b) no more than 20-feet above
mean low water.
3
Requirements for Means of Escape
3.1
Manned OCS Fixed Platforms
Each manned OCS fixed platform must have at least two Primary Means of Escape.
3.2
Unmanned OCS Fixed Platforms
Each unmanned OCS fixed platform must have at least one Primary Means of Escape. When personnel
are on board, you must also have at least one Secondary Means of Escape in addition to the one
Primary Means of Escape.
3.3
Functional Demonstration (Drills)
The USCG or designee may require personnel to demonstrate adequate and functional primary means
of escape. This functional demonstration may include the movement along the escape path(s) to the
personnel landing.
This functional escape demonstration does not include entering the water or demonstration of
Secondary Means of Escape. Equipment associated with Secondary Means of Escape is subject to
inspection upon request of USCG or their designee.
www.offshoreoperators.com
January 2017
OOC-G-2017-1
reference (i)
EXAMPLE: Manned Fixed Platform
2 PME
PME - Stairs
PME - Stairs
Personnel
Landing
Personnel
Landing
EXAMPLE: Unmanned Fixed Platform
1 PME, 1 SME
SME – Ladder &
Knotted Rope
PME - Stairs
Personnel
Landing
www.offshoreoperators.com
January 2017
OOC- -2017-1
reference (a)
reference (a)
reference (b)
COMDTINST 16000.7B
USCG Marine Safety Manual, Vol. II: Materiel Inspection
SECTION G: OUTER CONTINENTAL SHELF ACTIVTIES
CHAPTER 5: Procedures Applicable to Fixed OCS Facilities or Platforms
6. Lifesaving/ Firefighting Equipment
a. Variances. BSEE consults with the local OCMI to determine suitable options,
temporary measures or restrictions during the repair or replacement of required
firefighting equipment and lifesaving appliances. BSEE initiates this process with
the local OCMI. In cases where the owner/operator contacts the Coast Guard
directly, BSEE shall be notified immediately.
b. Approval process. The Coast Guard shall continue to approve equipment for use
on fixed offshore facilities and publish the list of approved equipment in the
Federal Register and COMDTINST M16714.3 (Series) in accordance with 33
CFR 140.15(b). The Coast Guard shall also notify BSEE of any newly approved
equipment and provide training as needed.
7. Catwalks – Manned Platforms
33 CFR 143.101 (c) requires all manned OCS facilities be provided with at least two
primary means of escape extending to the water. 33 CFR 143.101 (a) defines primary
means of escape as fixed stairways or ladders of metal construction. For OCS facilities
that are connected to adjacent facilities by bridges, or catwalks which allow free access
from one facility to another, the catwalk may serve as one of the primary means of escape
provided:
a. The catwalk leads to another location that provides a primary means of escape
extending to the water, and
b. There is a sufficient amount of primary lifesaving gear per 33 CFR 144.01-1 or
144.01-15 at this alternate location to accommodate 100% of the personnel
onboard the manned facility if they cross the catwalk and egress to the water via
this alternate escape route.
8. Single Well Caissons – Unmanned Platforms
33 CFR 143.101(d) requires unmanned OCS facilities be provided with one primary
means of escape and, when personnel are onboard and one secondary means of escape for
every 10 persons onboard. In the case of small single-well caisson type facilities, the
primary means of escape is usually a fixed ladder from the topside structure (work deck)
to the waterline. Since the work deck on these platforms is typically very small, a worker
cannot become trapped far from the primary escape route. Furthermore, the risk to
workers attending these facilities is quite low because there is usually very little
processing equipment onboard, plus the limited frequency and duration in which
personnel visit these facilities further lessens the risk. Taking all this into consideration, a
G5 - 6
CH-1
reference (b)
COMDTINST 16000.7B
USCG Marine Safety Manual, Vol. II: Materiel Inspection
SECTION G: OUTER CONTINENTAL SHELF ACTIVTIES
CHAPTER 5: Procedures Applicable to Fixed OCS Facilities or Platforms
single-well caisson type facility must have one primary means of escape but will not be
required to have a secondary means of escape, even when workers are on the platform,
provided:
a. The work deck is no more than 20 ft x 20ft (or 400 square feet) in size, and
b. The work deck is no more than 20 ft above mean low water.
9. Swing Ropes and Knotted Man Ropes
A primary means of escape shall be installed to meet the requirements in 33 CFR
143.101. A secondary means of escape shall be constructed and installed to the
satisfaction of the cognizant OCMI. Item (8) of Fixed Platform Inspection Program,
CCGD8INST 16711.1 (series) is the recommended standard for construction and
maintaining man ropes and swing ropes. Particular attention should be given to man
ropes and swing ropes due to weathering of the ropes and the dangers that are
encountered when using these devices.
Man ropes should be replaced immediately if there is any evidence or wear, dry rot,
mildew or ultraviolet deterioration. Swing ropes are subject to all the same considerations
as man ropes.
G5 - 7
CH-1
September 18, 2015
Eighth Coast Guard District OCS Division – OCMI 13th Floor, Room 1341 500 Poydras Street New Orleans, LA 70130 Attn: Captain Reynolds reference (c)
Dear Captain Reynolds, One of our member companies brought to my attention a recent effort by the Coast Guard’s OCS National Center of Expertise (OCS NCOE) to train Coast Guard and BSEE personnel on aspects of inspecting fixed offshore production platforms. The company representative I spoke with expressed some concern regarding information that was passed by the Coast Guard concerning escape/egress ladders. Specifically, that escape/egress ladders must extend below the water and no longer terminate above the surface of the water. The reasoning behind this was to provide access out of the water should someone fall in. As you know, the regulatory intent of egress ladders is to provide a means off of the platform in case of emergency and there are no specific requirements to provide access back onto a platform via a fixed ladder. This very issue was the subject of further clarification by your office (then Captain Dan Ryan) back in June 2003. That letter is attached for your reference as well. It has also come to my attention that BSEE may start to actively enforce this “requirement” based on the information passed in the training. I am concerned that information related to matters of interpretation of inspection issues, no matter how well-­‐intended, may create unnecessary regulatory constraints for our members and could result in costly modifications for items that are not required by regulation or policy. As I’m sure you can well appreciate, the level of oversight the Coast Guard provides on fixed offshore platforms has largely waned since granting the authority to BSEE (then MMS) to inspect these structures on behalf of the Coast Guard in 2002. Since that time, there has been varying levels of interaction between the agencies with regard to the level of training the Coast Guard was to provide so that BSEE could better understand the items and systems under the purview of the Coast Guard. Further exacerbating this effort has been the continual loss of expertise of both Coast Guard and BSEE personnel as they rotate into and out of their respective positions. While we welcome any effort the Coast Guard undertakes to help train BSEE in aspects of fixed platform inspections, we have concerns about the level of oversight or involvement that may or may not be provided by the actual regulatory authority which, in this case, is your office as the OCMI. Our understanding of the role of the OCS NCOE is that they support and advise the OCMI but they do not represent the OCMI and they do not necessarily have any OCMI authorities vested within their structure. If I have mischaracterized that relationship, please let me know. LOUISIANA OFFICE
One Lakeway-3900 N. Causeway, Blvd., Suite 700,
Metairie, Louisiana 70002
(504) 934-2159 Office / (504) 455-0868 Fax
TEXAS OFFICE
10777 Westheimer Rd., Suite 700
Houston, Texas 77042
(713) 589-6710 Office / (504) 455-0868 Fax
reference (c)
In order for any effort to succeed that provides updated training on the aspects of items under Coast Guard jurisdiction on fixed platforms, it should have engagement and input from the industry. The OOC has the resources and historical perspective that can assist you with closing any perceived gaps in policy or regulation for fixed platform inspections. Some of these have been captured in legacy District Eight instruction letters; others may only be evident in letters to individual companies. Before any further training or development of jobs aids the Coast Guard may be working on to aid BSEE in fixed platform inspection, I respectfully request a meeting with you and representatives of the OSC NCOE. I would like to ensure that we move forward in manner that takes into account established regulation and policy guidance. Thank you for your consideration. Respectfully submitted,
Evan H. Zimmerman
Executive Director
Offshore Operators Committee
c.c.:
Mr. Lars Herbst, BSEE GOMR
LOUISIANA OFFICE
One Lakeway-3900 Causeway, Blvd., Suite 700,
Metairie, Louisiana 70002
(504) 934-2159 Office / (504) 455-0868 Fax
TEXAS OFFICE
10777 Westheimer Rd., Suite 700
Houston, Texas 77042
(713) 589-6710 Office / (504) 455-0868
reference (d)
reference (d)
reference (e)
reference (e)
reference (e)
reference (e)
reference (e)
reference (e)
reference (e)
reference (e)
reference (e)
reference (e)
reference (e)
reference (f)
Title 33-Navigation and Navigable Waters
§ 142 01
terpret or apply sec 4 87 Stat 462 43 U S C
1333
SOURCE §§ 142 01 to 14120 contained in
CGFR 56-4 21 F R 902 Feb 9 1956
Sec
§ 142 01
Application
The provisions of this part shall apply
to all artificial islands and fixed structures located on the outer continental
shelf
§ 142 05 Inspection requirements
The Officer in Charge Marine Inspection, will perform or have performed
the inspections of artificial islands or
fixed structures within his area of jurisdiction to determine that the requirements in this subchapter are met These
inspections will be at such time or times
as he may deem necessary
§ 142 10 Scope of inspections
In the inspection of an artificial island
or a fixed structure, the person assigned
will inspect the lifesaving appliances
firefighting equipment, emergency equipment observe emergency drills (if necessary) and otherwise satisfy himself
that all provisions of the regulations in
this subchapter have been complied with
and that the emergency equipment is in
good condition and satisfactory in every
respect
§ 142 15 Deficiencies
Any deficiency will be reported to the
owner The owner shall have the deficiency corrected as soon as practicable
Any equipment required by the regulations in this subchapter found to be deficient or unsatisfactory by the person
performing an inspection will be condemned
Such condemned equipment
shall be repaired or replaced as soon as
practical Condemned lifesaving or firefighting equipment which cannot be
satisfactorily repaired, shall be so mutilated that it cannot be used for the purpose for which it was originally intended
§ 142 20 Authority to perform inspec.
tions
Persons assigned to this work may at
any time lawfully inspect an artificial
island or fixed structure
PART 143-CONSTRUCTION
ARRANGEMENT
Subpart 143 01-General
Sec
143 01-1
143 01-5
Application
Scope of requirements
Page 312
AND
Sub ipart 143 05-Means of Escape
143 05-1
143 05-5
143 05-10
Types
Manned platform
Unmanned platform
Subpart 143 10-Personnel Landings
143 10-1
143 10-5
Manned platforms
Illumination
Subpart 143 15-Guards and Rails
143 15-1
143 15-5
Floor or deck areas and openings
Catwalks and stairways
AUTHORITY
§§J143 01-1 to 143 15-5 Issued
under sec 633 63 Stat 545 14 U S C 633
Interpret or apply sec 4 67 Stat 462, 43
U S C 1333
SoURCE §§ 143 01-1 to 143 15-5 contained
inCFGR56-4 21F R 902 Feb 9 1956
Subpart 143 01-General
§ 143 01-1 Application
The provisions of this part apply to
all artificial islands and fixed structures
§ 143 01-5 Scope of requirements
No requirements are established with
respect to the construction and arrangement of artificial islands and fixed structures except as necessary to comply with
safety requirements contained in this
subchapter
Subpart 143 05-Means of Escape
§ 143 05-1 Types
Means of escape shall be fixed stairways or fixed ladders They shall be
constructed of metal and shall extend
from the platform to the surface of the
water at the low range tidal mark
§ 143 05-5
Manned platform
At least two means of escape shall be
provided for each manned platform
§ 143 05-10
Unmanned platform
At least one means of escape shall be
provided for each unmanned platform
Subpart 143 10-Personnel Landings
§ 143 10-1
Manned platforms
Sufficient personnel landings shall be
provided on each manned platform to
assure safe access and egress When due
to special construction personnel landings are not feasible then suitable transfer facilities to provide safe access and
egress shall be installed
§
143 10-5
Illumination
The personnel landings shall be provided with satisfactory illumination
reference (e)
Chapter I-Coast Guard
The minimum shall be one-foot candle
of artificial illumination as measured at
the landing floor and guards and rails
Subpart
143 15-Guards
and
Rails
§ 143 15-1 Floor or deck areas and
openings
(a) Except for helicopter landing
decks which are provided for in paragraph (b) of this section, and areas
not normally occupied, the unprotected
perimeter of all floor or deck areas and
openings shall be rimmed with guards
and rails or wire mesh fence The guard
rail or fence shall be at least 42 inches
high
The two intermediate rails shall
be so placed that the rails are approximately evenly spaced between the guard
rail and the floor or deck area Promded,
That if a toe board is installed then one
of the intermediate rails may be omitted
and the other rail placed approximately
half way between the top of the toe board
and the top guard rail
(b) The unprotected perimeter of the
helicopter landing deck shall be protected with a device of sufficient strength
and size as to prevent any person from
falling from such deck
§ 143 15-5 Catwalks and stairways
Each catwalk and each stairway shall
be provided with a suitable guard rail or
rails as necessary
PART 144-LIFESAVING APPLIANCES
Subpart 144 01-Manned Platforms
See
144 01-1
Life floats
14401-5
Location and launching of life
floats
144 01-10 Equipment for life floats
144 01-15 Alternates for life floats
144 01-20 Life preservers
144 01-25 Ring life buoys
144 01-30 First-aid kit
144 01-35 Litter
144 01-40 E m e r g e n c y communications
equipment
Subpart 144 10-Unmanned Platforms
144 10-1
Life preservers
144 10-5
Ring life buoys
144 10-10 Other lifesaving appliances
AurHoarry if 144 01-1 to 144 10-10 issued
under sec 633 63 Stat 545 14 U S C 633
Interpret or apply see 4 67 Stat 462 43
U S C 1333
SoUsCE if 144 01 to 144 10-10 contained in
CGFR 56-4 21 F R 903 Feb 9 1956 except
as otherwise noted
§ 144 01-15
Subpart 14401-Manned Platforms
§ 144 01-1 Life floats
Each manned platform shall be provided with at least two approved life
floats The life floats shall have sufficient capacity to accommodate all persons present at any one tume
§ 144 01-5 Location and launching of
life floats
The life floats shall be distributed in
accessible locations and mounted on the
outboard sides of the working platform
in such a manner as to be readily
launched
§ 144 01-10 Equipment for hfe floats
(a) Each life float shall be provided
with a painter This painter shall be a
manila rope or equivalent, not less than
2% inches in circumference and of a
length not less than three times the distance from the low water line to the deck
or place where the life float is stowed
(b) An approved electric water light
shall be provided for each life float The
water light shall be attached to the life
float by a lanyard not less than one
fathom nor more than two fathoms in
length The water light shall be
mounted in a bracket so that when the
life float is launched the water light will
pull free of the bracket
(c) Two paddles shall be provided for
each life float The paddles shall not be
less than five feet nor more than six
feet long The paddles shall be stowed
in such a way that they will be readily
accessible from either side of the life
float when in the water
§ 144 01-15 Alternates for life floats
(a) Approved lifeboats, approved life
rafts or approved inflatable life rafts
may be used in lieu of approved life
floats for either all or part of the capacity required When either lifeboats or
life rafts are used approved means of
launching will be required Inflatable
life rafts when used, shall be distributed and mounted as required for
life floats under § 144 01-5
(b) The equipment required for a
lifeboat is a bailer boat hook bucket,
hatchet, lantern, life line two life preservers, matches full complement of
oars and steering oar painter, plug, and
rowlocks, of the same type, kind and
character as required for lifeboats carried on vessels engaged in navigating
bays sounds and lakes other than the
Great Lakes, and rivers
Page 313
reference (g)
detached fuel tank. Therefore, until
recentlY there ·was no need for any
ventilation requirements for fuel tank
compartments in outboard motorboats as
fuel tanks were integral with the motors
and carried outside the hulls of the
vessels.
93. The autho1ity to prescribe regulations . regarding uninspected vessels
<motorboats) is inR.S. 4405, as amended,
4462, as amended, and secs. 8, 1'7, 54
Stat. 165, as amended, 166, as amended;
46 U.S.C. 375, 416, 526g, 526P· .
ITEM IX-ARTIFICiM. IstANDS AND
665
FEDERAL REGISTER
Tuesday, January 28, 1962
by changing the second entry under the
Percent column headed "Heat-damaged
kernels" to read ".5".
[9 CFR Part 201 l
REGULATIONS UNDER PACKERS AND
STOCKYARDS ACT
Notice That Ame ndments to Registration and Bonding Regulations and
Related Regulations Are Under
Consideration
F'IxED .
..,...n
On Sep~embe1· 28, 1961, w.t:re was
STRUCTURES ON THE OUTER CONTINENTAL published
m the FEDERAL REGISTER (26
Sm:tF
F .R. 9136), a. notice that consideration
94. It is proposed to amend 33 CFR was being given as to whether certain
143.05-1, 143.05-5, and 143.05-10 regard- regulations under the Packers and
ing emergency means of escape from Stockyards Act (9 CFR Part 201) should
artificial islands and fixed structures. be amended or revised in view of the
These proposals were initiated as a re- changes in current marketing conditions
sult of the recommendations by the Ma- and the 1958 amendment to the Act
i·ine Board of Investigation which inves- which extended the scope of the Act in
tigated an e:>.'Plosion and fir~ on the certain respects. The notification in"Offshore Platform Timbalier Block 134- vited any interested persons whet wished
01," Gulf of Mexico, July 26, 1959, with to do so to submit proposals with respect
' loss of life. It was the opinion of the to changes in §§ 201.10 to 201.13, inBoard as a result of the casualty that elusive, concerning registrations, and
present regulations regarding means of §§ 201.29 to 201.34 inclusive, concerning
escape required clarification. The Board market agency and dealer bonds <9 CFR
determined that in this casualty there 201.10-201.13, 201.29-201.34).
was only one means of escape from the
Recommendations which have been
quarters level to the rig floo1· but that received from interested persons, 1!
there were two fixed stairways from: the adopted, may require changes or revirig floor to the surface of the water. sions in regulations other than those
Since the terminology of the oil industry specified in the notice of September 28,
describes the platform as the structure 1961. SpecificallY those regulations
on which the drilling rig and equip~ent which may reqUlre changes are §§ 201.69,
are placed, this platform bad two means 201.60, 201.61, 201.66, 201.67, 201.68,
of escape. Therefore, the purpose of this 201.79, and 201.81, concerning certain
p1·oposal is to amend regulations so that trade practices and services of persons
two means of escape are required from subject to the Act (9 CFR 201.59, 201.60,
each level to the surface of the water. 201.61, 201.66, 201.67, 201.68, 201.79, and
These.proposals were con:iidered and en- 201.81).
dorsed by the National Offshore OperAny interested person who wishes to
ations Panel at its meeting on February submit proposals and the reasons there7, 1961, at Washington, D.C.
for, or comments with respect to these
95. The authority to prescribe regula- regulations .may do so by filing them
tions regarding artificial islands and with th~ ?~ector, ~ackers and Sto?k.
....,_., 63 stat yards D1vis1on, Agricultural Marketing
fl."ted structures is m sec. ".,,,.,
· Service, United States Deparbnent of
545; 14 u.s.c. 633. These regulations Agriculture, Washington 25, D.C., not
interpret or apply sec. 4, 67 Stat. 462; later than 30 days after publication
43 u.s.c. 1333.
hereof in the FEDERAL REGISTER. The
Dated: January 12, 1962.
time for :filing proposals with :respect to
§§ 201.10-201.13 and 201.29-201.34 1s
[SEAL]
J. A. HmsHFIELD,
hereby extended for the same period.
Vice Admiral, U.S. Coast Guard,
Copies of the present regulations may be
Acting Commandant.
obtained on request from the Director.
[F.R. Doc. 62-731; Flled, Jan. 22, ·1962; If it is decided after consideration of all
a:so a.m.J
proposals and comments received pursuant to this notice and consideration of
all other relevant matters that the regulations should be amended a notice of
proposed rule-making will be publlshed
in the FEDERAL REGISTER setting forth any
Agricultural Marketing Service
specific proposed amendment.s. At that
C7 CFR Part 26 l
time all interested persons will have an
opportunity to submit their views on such
GRAIN SORGHUM
proposed amendment.s.
Official Grain Standards of the United
Done at Washington, D.C., this 17th
States; Notice of Proposed Rule · day of January 1962.
Making
CLARENCEH. GIRARD,
DEPARTMENT OF AGRICULTURE
Correction ·
In F .R. Doc. 62-368 appearing at page
409 of the issue for Saturday, January
13, 1962, the t'!lble in § 26.653 is c0rrected
Director,
Packers and Stockyards Division.
[F.R.
Doc.
62-'l07; Flled, Jan. 22, 1962;'
8:46 a.m.J
Agricultural Stabilization and
Conservation Service
[ 7 CFR Part 1064 1 l
[Docket No. A0-23-A20 and A0-23-A22]
MILK IN GREATER KANSAS CITY
MARKETING AREA
Decision on Proposed Amendments to
Tentative Marketing Agreement
and to Order .
Correction
Doc. 61-12366, appearing at
page 12710 of the issue for Friday, December 29, 1961, the following words
should be inserted immediate].y preceding the signature of James T. Ralph:
"Signed at Washington, D.C., Decembe1·
22, 1961.".
In
~.R.
DEPARTMENT OF LABOR
Wage and Hour Division
[ 29 CFR Part 541 l
EXECUTIVE, ADMINISTRATIVE AND
PROFESSIONAL EXEMPTIONS
Notice of Proposed Rule Making
Section 13(a) U> of the Fair Labor
Standards Act of 1938 <29 u.s.c. 213(a)
(1) ) • proVides an exemption from the
minimum wage a.nd overtime requiremen~ of the Act for any employee employed in a bona fide executive, administrative, or professional capacity. The
Administrator of the Wage and Hour and
Public contracts Divisions of the Deparbnent of Labor is authorized t-0 define and delimit these terms. The regulations established pursuant to this
authority are contained in 29 CFR Part
541. These regulations provide, among
other things, that no person shall be
considered a bona fide executive 1f he
is paid less than $80 a week on a salary
basis ($55 a week if employed in Puerto
Rico or the Virgin Islands> • and that no
person shall be considered a bona fide
administrative or professional employee
1! he is paid less than $95 a week on a
salary or fee basis ($70 a week if employed in Puerto Rico· or the Virgin
Islands). These regulations also contain special provisions for such employees who are paid $125 a week or more.
The widespread increases in wage and
payroll levels which have ta.ken place
since these salary tes~ were established
in Feb111a.ry, 1959, indicates that consideration should be given to further
changes of these rates.
According~. notice 1s hereby given of
proceedings to be held on Monday,
March 26, 1962, at 10 o'clock a.m., in
Conference Room B, Departmental
Auditorium, Constitution Avenue, between 12th and 14th Streets NW., Washingt-0n, D.C., before Hearing Examine1·,
Clifford P. Grant, at which time interested persons may submit oral data,
views, or arguments on the following
question: What, if any, changes should
be made in 29 CFR 541.Hf>. 541.2 Ce) ,
and 541.3(e) with respect to the level
~Formerly
Part 913.
reference (h)
reference (h)