USCG Policy Letter: DP MODU Systems, Personnel and Training

**captmrb** · January 9th, 2012, 09:11 AM

This letter is out for comment in the Federal Register. Attachment 1478

I think the most significant part will be if the USCG adopts the language considering DP vessels as Underway and no longer 'On Location.' This would influence mariner manning levels within companies operating in the GoM that don't keep a full compliment of licensed mariners onboard. It would also require Masters to hold DP operator certificates which hasn't been a requirement before and leaves a loophole for companies to hire non-DP background Masters to oversee DP vessels. The inspection criteria will just be another person witnessing what client audit teams and ABS/DNV already want to see.

You can view the Federal Register docket and comment here. Comments are due by 30 January 2012.

**cjdudek** · January 13th, 2012, 07:15 AM

Here is another document that may be of use regarding DP. This is a MTN from the Marine Safety Center on plan approval for vital systems related to DP MTN.02-11.2011.12.15.Review%20of%20Vital%20System%20Automation%20and%20Dynamic%20Positioning%20S.pdf

**c.captain** · January 13th, 2012, 07:57 AM

welcome to the forum lieutenant, very glad you've joined...you will be a most knowledgable and valued asset to the discussions here regarding MODUs and other GoM mariner/vessel related issues

here I am c.captain but you know me better as cptnb1

I am going to not comment here yet on this proposed Policy Letter (btw, I didn't think a Policy Letter required Federal Register Notice?) but don't like hearing that non DP certified masters will still be allowed to command DP MODUs.

**cjdudek** · January 13th, 2012, 08:12 AM

So my ninja technique did not work.... I firmly believe in helping the crews offshore and am here to provide any assistance as none of this is a secret.

**c.captain** · January 13th, 2012, 08:14 AM

Originally Posted by cjdudek

So my ninja technique did not work.... I firmly believe in helping the crews offshore and am here to provide any assistance as none of this is a secret.

You're not a very good Ninja with that username...might I suggest ModuGuru if it's not too late to change it?

**cjdudek** · January 13th, 2012, 08:31 AM

Yea, I went back and noticed that, regardless here to help and maybe being public may be easier for all, anyway don't know how to change. I understand your statement regarding the Master and the word "should" can be tricky and I will suggest a change of that word. Is that your issue?

**c.captain** · January 13th, 2012, 08:42 AM

Originally Posted by cjdudek

Yea, I went back and noticed that, regardless here to help and maybe being public may be easier for all, anyway don't know how to change. I understand your statement regarding the Master and the word "should" can be tricky and I will suggest a change of that word. Is that your issue?

Since I haven't had the chance to read the proposed letter I can't say specifically but from the first post announcing this Policy Letter talks about a "loophole" I was just making a general comment that I am not in favor that such loopholes be left in the final letter. I will comment on the proposed letter here tonight and willof course be filing a formal comment to the docket as well.

**cjdudek** · January 13th, 2012, 08:46 AM

Awesome, mariners are affected by this policy therefore it is imperative you provide imput. If you have any questions, please feel free to ask.

**captmrb** · January 13th, 2012, 11:33 AM

Originally Posted by c.captain

Since I haven't had the chance to read the proposed letter I can't say specifically but from the first post announcing this Policy Letter talks about a "loophole" I was just making a general comment that I am not in favor that such loopholes be left in the final letter. I will comment on the proposed letter here tonight and willof course be filing a formal comment to the docket as well.

c.captain,
That's just poor wording on my part... I was saying that the current requirements had a loophole. I believe the proposed changes in the letter will close the hole, in the Gulf of Mexico at least.