USCG Publishes Offshore Fire, Explosion Guidelines

As part of its continuing response to the Deepwater Horizon incident, the U.S. Coast Guard's notice of recommended interim voluntary guidelines concerning fire and explosion analyses for MODUs published in the Federal Register

The Federal Register Friday published the U.S. Coast Guard's (USCG) notice of recommended interim voluntary guidelines concerning fire and explosion analyses for mobile offshore drilling units (MODUs) and manned fixed and floating offshore facilities engaged in activities on the U.S. outer continental shelf.

This notice is part of the Coast Guard's continuing response to the explosion, fire and sinking of the MODU Deepwater Horizon in the Gulf of Mexico April 20, 2010.

The "Report of Investigation into the Circumstances Surrounding the Explosion, Fire, Sinking and Loss of Eleven Crew Members Aboard the Mobile Offshore Drilling Unit (MODU) Deepwater Horizon in the Gulf of Mexico, April 20-22, 2010," and related Commandant's Final Action Memo, dated Sept. 9, 2011, contain a number of recommendations for outer continental shelf safety improvements that are presently beign evaluated for further regulatory action. Recommendations 1D, 1E, 2B, 2C, 2E and3A in the report urged the Coast Guard to evaluate the need for fire and explosion risk analyses to ensure an adequate level of protection is provided for accommodation spaces, escape paths, embarkation stations and structures housing vital safety equipment from drill floor and production area events.

To implement the recommendations, the Coast Guard is considering a future rulemaking to address fire and explosion risk analyses for MODUs and manned fixed and floating offshore facilities engaged in outer continental shelf activities. Comments would be invited in connection with such a rulemaking.

Currently, there is no requirement in the current outer continental shelf regulations, in Title 33 of the Code of Federal Regulations, that requires a fire and explosion analysis that would implement the recommendations from the report. Furthermore, while Section 9 of the 2009 International Maritime Organization MODU Code contains some recommendations on the parameters of fire and explosion risk analysis, we believe that some recommendations are not sufficiently specific to adequately and consistently address these recommendations from the report on their own.

The entire notice of recommended interim voluntary guidelines is available at https://www.federalregister.gov/articles/2014/05/02/2014-10010/outer-continental-shelf-units-fire-and-explosion-analyses.