OMSA’s members should want to be a part of a great, not just a good, organization. What’s the difference? You can tell good associations and great associations apart by the way they represent their members on the issues that count. Good associations can win big battles. They pull out all the stops, they throw all their weight behind an issue and they often come away with a victory. However, that victory comes with a high cost. Even good associations can exhaust themselves, limit their ability to take on new challenges, and find themselves without the resources to fight more than one battle at a time.

On the other hand, great associations win consistently and can juggle a number of initiatives at the same time without letting any one issue fall through the cracks. Each success creates opportunities for new successes. These associations share some common traits: They are organized. They have processes in place to address issues. Above all, the association and its members all pull together. They coordinate, they cooperate and they take advantage of their collective strength.

OMSA’s members have a right to expect a great association. The times we are in demand it. The changes that have taken place in Congress and federal agencies, like the Coast Guard, present our industry with enormous challenges that only a great association can meet. How are we going to achieve that?

First, we have revamped our communications system so that we can reach out to the entire membership, quickly and effectively. As a part of that process we have added a monthly e-mail update so that we can inform you of important issues and get your feedback as we develop our positions and strategies.

Second, we have made some organizational changes that will help us focus on educating the new Congress on our industry and the issues that matter to us, such as the Jones Act. Our goal is to tell our story to the newly elected members of Congress, a daunting task when you consider that, in Louisiana alone, nearly half of the delegation is newly elected.

Third, we are starting a new process which allows us to prioritize our issues to make sure that the association is focused on the things that really matter to our members. More on that later in this newsletter.

Finally, we want to lock in our process for dealing with issues to make sure that members are actively involved as we identify issues, develop and execute our strategy and then communicate the results back to the membership. Member involvement is the key to making sure we are coordinated, focused and are using all of our combined strength to solve industry problems. That’s what it takes to be a great association.

Beginning this year, OMSA is instituting a new process for prioritizing the issues that the association will focus on during the course of the year. Under this process, the Board of Directors voted on a priority list at its January meeting and the members were briefed on the priority list at the full membership meeting. Based on their input, the priorities for 2005 are:

• Defense of the Jones Act – OMSA must continue its fight to close loopholes which threaten U.S. flag vessel operators in the Gulf of Mexico.
• Addressing Licensing Problems - Mariners in the offshore sector face a number of problems, ranging from the complexities of the STCW licensing regime to the difficulty in acquiring the sea time to become a Master on a liftboat. At the same time, the Coast Guard is embarking on a ten year process to modernize the licensing regulations, a process in which OMSA must be an active participant.
• Update to the OMSA Safety Orientation Program – Now that OMSA has updated its safety program and made it consistent with customer-driven safety requirements, such as SafeGulf, the program must be put into practice for several thousand mariners.
• SOLAS Applicability for Vessels Operating Foreign/Domestic – Recent Coast Guard interpretations of SOLAS requirements threaten to make it impossible for some OMSA members to compete internationally. The Association will work with the Coast Guard to resolve this conflict.
• USCG Security Requirements – As the OMSA security program enters its second year, the association will work to help members meet their requirements for security audits, exercises and additional crew training.
• Towing Vessel Inspection Regulations – OMSA members who operate currently uninspected towing vessels will be actively involved in the Coast Guard’s efforts to develop inspection regulations for that sector.
  

For additional information on any of these events, contact Lillie Licciardi, OMSA Manager of Member Services.

April
Monday April 11th and Tuesday April 12th
OMSA will co-host the Offshore Logistics Conference with the International Association of Drilling Contractors.

Monday April 25st
OMSA will host its 15th Annual Louisiana Golf Classic at the Chateau Golf & Country Club in Kenner, LA. Information bulletins will be sent out the first week of March.

Tuesday April 26nd
OMSA will host its 2nd quarterly membership meeting at the Hilton New Orleans Riverside, New Orleans, LA. Notices will be sent out the 2nd week of March.

June
The 6th Annual Cajun Tropics Fishing Rodeo will be held in June (Grande Isle), at a date to be determined. OMSA is soliciting volunteers for the fishing rodeo committee. Contact Lillie if you are interested.

July
Thursday July 21, 2005
Membership Meeting
Hilton New Orleans Riverside, New Orleans, LA.

October
Tuesday October 25, 2005
OMSA Lone Star Golf Tournament
Wildcat Golf Club, Houston, TX.

Wednesday October 26, 2005
Membership Meeting
OMNI Houston Hotel, Houston, TX.

December
Friday December 9, 2005
Christmas Dinner Dance
Hilton New Orleans Riverside, New Orleans, LA.

Customs Service Closes Jones Act Loophole
OMSA has won a significant victory in the effort to close loopholes in the Jones Act. On January 18th, Customs and Border Patrol responded to an OMSA request that the agency rule on the question of whether foreign anchor handling vessels can set and retrieve certain types of mooring systems. The Customs letter states very clearly that only U.S. flagged anchor handling tugs can be used in setting the mooring systems when the mooring systems are transported from a U.S. port out to a wellhead site.

As background, a series of Customs rulings over the past 15 years had opened the door for foreign vessels to set and recover anchors from offshore drilling rigs and production platforms. In seeking a ruling, OMSA argued that the technology and approach to mooring offshore structures has changed over the past decade and the process should be reviewed by Customs. Specifically, as the mooring process has become more complex, the mooring systems are commonly designed and pre-built on land, frequently using sophisticated suction pile anchors. The mooring systems are then transported out to the lease site and deployed. OMSA argued that this was a definite change from the process used in the past in which anchors were kept on the rigs and deployed at the scene by anchor handling vessels.

Customs agreed. Its ruling letter states:

“An Anchor Handling towing supply vessel (AHTS) is subject to the coastwise merchandise statute (46 U.S.C. app. 883) when transporting a suction pile anchor and mooring assembly either directly or for any part of such transportation between a U.S. port or other coastwise point and the site of an exploratory wellhead on the OCS for resource exploration, development or production…As such the use of a foreign-flagged vessel for this purpose would violate section 883.”

Closing this loophole and enforcing the Jones Act restrictions in the Gulf of Mexico is one of OMSA’s key priorities. Now that the ruling is out, members who learn of any foreign-flag vessels engaging in anchor handling on the Outer Continental Shelf are urged to contact OMSA with the information.

Table of Contents

The membership honored outgoing OMSA Chairman Milt Rose, Seacor Marine Inc., at the January OMSA Board meeting. Mr. Rose served as Chairman for 2003 and 2004. During that time, he oversaw OMSA’s successful initiative to close loopholes in the Jones Act created by foreign lease financing. During that period, OMSA also initiated its security program and training initiative. Finally, Mr. Rose was directly involved in the Presidential transition in the association.

At their January meeting, OMSA’s members elected the following Officers and Board members for two-year terms:

Officers:

• Chairman – Brandt Dufrene, Oceanic Fleet
• Vice Chairman – Steve Dick, Tidewater
• Secretary/Treasurer – Todd Hornbeck, Hornbeck Offshore Operators

Board members:

• Milt Rose, SEACOR Marine
• MJ Cheramie, L&M Boatruc Rental
• Laney Chouest, Edison Chouest Offshore
• Peter Fortier, Superior Energy Services
• Steve Dick, Tidewater
• Otto Candies, III, Otto Candies

In a separate action the Board named Ogden Thomas, Cross Group, to fill the remainder of the term of Robert Thompson, who resigned from the Board.

OMSA’s Board of Directors welcomed newly-elected Senator David Vitter (R-LA) at its meeting on January 12. During his three terms as U.S Representative for Louisiana’s First District, Vitter was a friend to the maritime industry in general and the OMSA membership in particular. In November, he won election to the Senate, replacing retiring Senator John Breaux. As Senator, Vitter will serve on the Commerce, Science and Transportation, which has authority over most maritime issues, including the Coast Guard and the Jones Act. He will also serve on the Environment and Public Works Committee. In meeting with the OMSA Board, Senator Vitter spoke with a high degree of expertise on the Jones Act and the importance of that law to the U.S. maritime industry.

OMSA members may be able to count on two well-placed advocates in Congress this year. On Wednesday, February 2nd, the House Transportation Committee named Representatives Gene Taylor (MS-D) and Charles Boustany, Jr. (LA-R) to the Coast Guard and Maritime Transportation Subcommittee. The Committee has oversight on a number of important maritime issues. For Instance the Committee is responsible for initiating the Coast Guard Authorization Bill.

Representative Gene Taylor is a veteran House member from Gulfport. Taylor is one of only a handful of Members of Congress with hands-on experience in the United States Coast Guard and has been a longtime friend to the offshore sector. Representative Boustany is a freshman Congressman from the Southwestern corner of Louisiana, including Lafayette. A number of OMSA members have operations within his district.

OMSA staff members were recently quoted in Workboat Magazine. In the December Workboat Magazine Top 10 News Stories of 2004 OMSA Vice President Ken Parris was quoted saying “We believe that in the late spring or summer of 2005 the Coast Guard will likely begin boarding vessels and visiting with company security officers to ensure that security exercises of sufficient scope and detail have been held and/or planned.” In the same issue OMSA President Ken Wells was quoted describing OMSA’s success in getting Congress to close the Lease-Finance loophole as “…a big victory.” Mr. Wells as also quoted in regard to the association’s fervent support and defense of the Jones Act saying “Our message to foreign operators is you mess with the Jones Act, you will deal with OMSA.”

OMSA has released its newly updated and revised Safety Training Program.

The OMSA Safety Training Program is fully compliant with and accepted as equivalent to the requirements of the SafeGulf participants. OMSA will begin Train-the-Trainer classes to update current users of the New Hire Safety Orientation program to the new OMSA Safety Training Program, and add new participants starting February 23rd to February 25th. Look for signup sheets in your email or contact Ken Parris for times and locations.

In 1993, OMSA created a basic safety orientation program to member companies a means to give newly hired crewmembers an approved introductory course in offshore safety. In early 2004, OMSA members recognized a need to update the program to reflect changes in safety training. The advent of SafeGulf, a mandatory safety orientation adopted by some offshore oil producers, became an additional reason to perform this update.

Members of the OMSA safety committee identified areas, which should be added to the OMSA program and provided sample lesson plans. Based on their input, the original chapters have been reorganized and expanded, adding materials not previously incorporated into the OMSA Safety Training Program curriculum. These changes track the requirements found under SafeGulf. Additionally, all original modules have been reviewed and improvements have been made where necessary, increasing the expected presentation time but allowing the training to be presented in one day.

Implementation: OMSA is targeting three groups of mariners with its revamped safety program:

1. Newly hired crewmembers – New hires that are not covered by STCW will go through the new orientation program in its entirety, which is estimated to take eight hours to complete. The program may be taught all at once as part of a new hire orientation program or over time as part of regular on-board safety training using approved instructors.

2. Newly hired crewmembers under STCW – New hires who are also taking the STCW Basic Safety Training Program will have the option of adding that portion of the OMSA orientation program, covering only those areas which are not already covered in more depth by STCW Basic. This is estimated to take an additional four to six hours to complete.

3. Existing crewmembers – These employees will be provided with review materials and allowed to test out of the program. The process will allow employers to conduct the review and test out procedure on board the vessel. It will also allow the employer to spread the process over a period of time as a part of regular safety meetings.

Distribution: New instructor materials, slides of modules (in PowerPoint format) and tests are distributed free of charge to existing accredited instructors. This includes training institutions, safety and training companies and vessel operators which have completed instructor training. Instructors who are already accredited will be offered a short refresher session to assist them in teaching the new material. Instructors not currently accredited will receive materials after they have completed a ‘train the trainer’ session conducted by OMSA.

Note: The OMSA Safety Training Program is only available to OMSA members. Due to security concerns, agreements with the SafeGulf participants, record keeping and audit requirements, the barcode cards required by SafeGulf can only be issued to employees of OMSA member companies (Regular or Associate).

Audit: OMSA will audit the program based using a tiered approach. Under this approach, entities that are already audited will not be seen as priority target for audits. This group includes

• Training institutions and private providers who are already undergoing routine audits of their training programs by the Coast Guard.
• Companies that inform the association that their use of the OMSA program is a part of their International Safety Management System (ISM) program and are therefore subject to ISM audit.
• Companies that train under STCW requirements are subject to Coast Guard audit.

For the remaining vessel operators (who train in-house and do not fall under STCW or ISM), OMSA will use either staff or outside contractors to perform audits.

Database: OMSA will collect and share with SafeGulf the following information: trainee name, OMSA provided ID number and picture in digital format to meet the SafeGulf program data requirements. The precise procedure for accomplishing this will, to some extent depend on the as yet to be developed SafeGulf database system. OMSA will provide a bar code sticker with each card to allow for their use with scanners.

On February 10th OMSA members, supported by OMSA Vice President Ken Parris and President Ken Wells, attended public hearings in New Orleans where the Coast Guard accepted public testimony on their project to develop regulations for the inspection of towing vessels. At the hearing and a similar meeting in Washington, OMSA and its members presented consistent points that:

• The towing industry may be the most diverse group of vessels the Coast Guard has ever tried to bring into a common inspection regime.
  • This regulatory process will affect everything from offshore tugs moving multi-million dollar oilrigs in the Gulf of Mexico to fleet boats working in ice on the Illinois River.
  • The potential for unintended consequences of applying the wrong standard to different modes of towing is immense.
  • This argues for flexibility in inspection criteria.
• The inspection program should take advantage of safety management systems, audited by third parties to the greatest extent possible.
  • ISM should be accepted as one of those safety management systems since
    • It is already accepted by regulation and has been endorsed by the Coast Guard internationally.
    • It is a necessity for vessels operating internationally and it would be counterproductive (and even unsafe) to require two different safety management systems.
  • The Coast Guard should recognize that ISM does not work for all types of towing and that other safety management systems should be accepted.
    • The Coast Guard should develop objective minimum criteria for these other systems so that any entity which decides to create such a system should be able to apply to the Coast Guard for acceptance, much the way approved training courses are handled today.
• Requirements for physical inspections should be limited, given the lack of accidents caused by structural problems.
  • Vessels that are load lined should not be required to undergo another physical inspection.

The Coast Guard has requested written comments to its proposed regulations. The written comments are due to the docket by March 23rd. OMSA has prepared draft comments that any member may review prior to submitting their own comments.

The TSAC committee working with the Coast Guard to develop the towing vessel inspection regulations next meets on March 2nd and 3rd at Coast Guard headquarters in Washington. OMSA members are encouraged to continue participation in the process.

OMSA members operating overseas under “foreign domestic” rules have been hampered by recent changes in Coast Guard interpretations of SOLAS applicability rules and inconsistent application of these interpretations by Coast Guard officials at various overseas locations.

The Coast Guard National Offshore Safety Advisory Committee (NOSAC), at the request of OMSA, has taken on the resolution of this issue as a priority task. The NOSAC committee addressing this issue will hold its first meeting in Houston on March 4th. This is an opportunity for OMSA members to work together, with the Coast Guard, to develop a comprehensive solution/interpretation of SOLAS applicability to U.S. Flag vessels working in overseas locations. Just as with the towing vessel inspection regulations project, member participation in important. The Coast Guard gives the greatest weight to the comments of the people who are most greatly affected by the issue. To become involved, contact Ken Parris for information.

In addition to the national process the Coast Guard inspections office in Rotterdam is continuing to review the issue with the apparent intent of issuing policy that will affect operators in Europe, Africa and the Middle East. MIO Rotterdam held a meeting in December to discuss the issue with a number of interested members. While OMSA does not support a piecemeal approach to solving this problem, MIO Rotterdam has suggested a number of interesting and potentially beneficial solutions to the problem.

OMSA and its members will continue to work closely with Coast Guard headquarters, NOSAC and MIO Rotterdam to resolve issues such as:

• Are offshore workers truly passengers? Many countries whose vessels we compete with say no.
• Can the Coast Guard create a simple system for validating the non-SOLAS repositioning of OSV’s, crewboats and liftboats, so that their “foreign domestic” voyages remain valid?
• In areas where a single offshore area may be operated/supported by several nearby countries, such as is the case in equatorial Africa, is it possible to certificate vessels for multiple country operations?
• Increase the use of tonnage reconciliation letters to better delineate those vessels to which SOLAS does not apply due to their build date.

Coast Guard interpretations of both licensing and STCW requirements may threaten the ability of U.S. mariners to work on offshore support vessels overseas. USCG Policies make it difficult for mariners holding a 100-ton license to upgrade to the 200-ton license needed to operate many vessels overseas. OMSA has held several meetings to try to address this problem.

After consulting with Coast Guard Headquarters to determine if there is a policy work-around that will ease the path to tonnage upgrades for mariners who wish to upgrade from 100 to 200 ton licenses, Coast Guard personnel determined that the issue would be addressed in the licensing regulatory rewrite process that has just started. There is no definite timetable on the regulations re-write. OMSA is currently assessing its options in solving this problem.

OMSA continues to work with the staff at the Coast Guard National Maritime Center (NMC) to alleviate the career advancement problem for liftboat operators created when the NMC issue Policy Letter 09-01. Essentially this policy eliminated the 1-day credit for 1-day worked sea service credit for liftboat personnel while in the elevated mode and replaced it with a 1-day credit for 3-days worked. The practical affect of this change was to increase the time it would take a liftboat operator to qualify for master from 4 calendar years to over 14 calendar years, a proposition which would make it impossible in a practical sense to qualify.

OMSA has been successful in gaining support for the program from the National Offshore Safety Advisory Committee (NOSAC) and the Coast Guard Eighth District has also recommended that the program be used. However, the Coast Guard National Maritime Center (NMC) had taken the position that the program cannot be used to reduce required underway time without a change in the regulations. OMSA is in discussions with the Coast Guard concerning options for putting the program in place in the near term. At this time, the Coast Guard is seeking an internal legal review of the program before determining the best approach for putting it into effect.

Coast Guard Marine Safety Office Morgan City is preparing a comprehensive liftboat inspection policy that will cover many liftboat inspections issues that have arisen such as determining maximum plate wastage. The OMSA liftboat committee, along with other interested parties are preparing technical comments to assist the Coast Guard in finalizing this policy. For additional information contact Ken Parris.

At the urging of Congress, the Coast Guard is increasing its focus on the management of crew fatigue. The Coast Guard Authorization Bill passed by Congress last summer directed the Coast Guard to hold at least one demonstration project to show the viability of the Crew Encourage Management Program, also known as CEMS. CEMS is a coordinated approach to addressing the factors that contribute to crewmember fatigue. Additional information on CEMS can be found on the Coast Guard website, http://www.uscg.mil/hq/g-m/cems.

CEMS is a non-regulatory approach to encouraging crew alertness. However, with the Coast Guard Authorization Bill last year, Congress urged the Coast Guard to look at CEMS as a part of the towing vessel inspection program. Under Section 409 of the bill:

(c) The Secretary may prescribe by regulation requirements for maximum hours of service (including recording and record-keeping of that service) of individuals engaged on a towing vessel that is at least 26 feet in length measured from end to end over the deck (excluding the sheer).
(b) DEMONSTRATION PROJECT- Prior to prescribing regulations under this section the Secretary shall conduct and report to the Congress on the results of a demonstration project involving the implementation of Crew Endurance Management Systems on towing vessels. The report shall include a description of the public and private sector resources needed to enable implementation of Crew Endurance Management Systems on all United States-flag towing vessels.

The clear message from Congress is that either CEMS or a traditional hours of service requirement is likely to become regulation at some point in the future.

Crew fatigue and watchstanding also continues to receive international attention. A UK agency which looks at maritime accidents has released a comprehensive report titled, the Bridge Watchkeeping Safety Study. The study by the Marine Accident Investigations Branch looked at collisions and groundings over a 10-year period. The study concludes that all commercial vessels over 500 gross tons should be crewed with a minimum of a master and two bridge officers. The agency also recommends that the STCW be amended to stress the importance of maintaining a designated lookout on the bridge. The Recommendations are a clear indication of the positions the British will take before the International Maritime Organization.

The latest Coast Guard Authorization Bill requires the Coast Guard to issue regulations requiring all vessels over 400 gross tons to have oil spill response plans. These rules will require OSV’s and any other non-tank vessels over 400 tons (GRT or ITC) to prepare and comply with vessel response plans similar to those of large commercial vessels required after OPA’90. The rules are required to be issued this year.

The Coast Guard is finalizing a Navigation Vessel Inspection Circular (NVIC) which will outline the guidelines for compliance with the new regulations.

Once the NVIC is released, OMSA will analyze it and work with members to implement it.

The Coast Guard has started boarding vessels to request ballast water plans and examine reporting forms. The Coast Guard’s stringent ballast water reporting requirements on vessels operating in U.S. waters went into effect in November 15, 2004. At this time the Coast Guard is focusing on educating vessel operators on the new regulations before launching an enforcement action. Guidance on writing ballast water plans is available from OMSA Vice President Ken Parris.

Coast Guard guidance on ballast water reporting is found in Navigation Vessel Inspection Circular 07-04 (Change1) at http://invasions.si.edu/nbic/news/NVIC_07-04_Ch-1.pdf .

General Ballast Water reporting information and forms can be found at
http://invasions.si.edu/nbic/news.html.

Under current regulations commercial vessels over 65 feet long and tugs over 26’/600 hp will be required to have AIS when operating within VTS zones, including New Orleans, Morgan City, Port Arthur and Houston. Fishing vessels and small passenger vessels have been exempted.

The Coast Guard is now considering regulations to add categories of vessels which will be required to carry AIS systems and whether or not to expand the areas where AIS is required.

The question has arisen as to whether the small passenger vessel exemption was to be applied according to the service as noted on the vessel COI or the inspection chapter to which the vessel was inspected. This is especially important to operators of small OSV’s (utility vessels or liftboats) whose service is not passenger, but which are inspected under Subchapter T, the Small Passenger Vessel regulations. Questions to various MSOs along the Gulf Coast and to Coast Guard headquarters have elicited different interpretations of the regulations. OMSA has requested that the office which initiated the regulations rule on this issue.

The headquarters AIS project officer has indicated that field units have been given guidance that directs them to delay enforcement of AIS on these vessels for 90 days to allow Coast Guard headquarters time to develop policy. OMSA will continue to monitor the progress of AIS requirements.

Background on AIS may be found at http://www.navcen.uscg.gov/enav/ais/default.htm.

The Coast Guard Authorization Act of 2004 essentially requires those vessels subject to the AIS regulations to be equipped with electronic charts. The Coast Guard is required by law to publish implementing regulations by January 2007.

Australia has submitted a request to IMO to update the subdivision and stability guidelines for Offshore Support Vessels. This issue was submitted several years ago and has been monitored by OMSA. The issue has made it onto the IMO agenda this year. The majority of the proposal appears to fall into the category of housecleaning. Three of the proposal’s items could impact our vessel fleets, a requirement for increased bow height, increased reserve buoyancy and 2-compartment subdivision. The consensus of a review of the proposal by OMSA member vessel designers and builders is that the first two items will have minimal impact on our fleets. The crux of the matter is a proposal by Australia to subject Offshore Support Vessels to a 2-compartment subdivision requirement versus the current 1-compartment. In early December the Coast Guard held a meeting in Washington to get industry input on the official U.S. position to the proposal. OMSA was well represented by members and staff. They urged the Coast Guard to not support the Australian proposal. On March 16 the Coast Guard will host a meeting to finalize the U.S. response to the Australian proposal. OMSA staff will continue its close liaison with Coast Guard personnel to ensure that the U.S. response adequately addresses the industry position. Information on this proposal can be found on the Society of Naval Architects Website at http://www.sname.org/committees/tech_ops/O44/activity.html.

OMSA is monitoring a proposal by the International Labour Organization to enact its Draft Maritime Labour Convention. The draft report states that ILO intends to hold a meeting in 2005 to ratify the convention. A review of ILO meetings scheduled for 2005 does not show the issue on any published agenda. Additional information can be
found on the ILO website at http://www.ilo.org/public/english/standards/relm/maritime/index.htm.

The International Marine Contractors Association (IMCA) is attempting to establish its own DP standard for offshore support vessels. The first draft has been published for review. Absent Port State or contractual equipment requirements for specific dynamic positioning equipment the IMCA standard suggests a minimum of DP-1 for offshore support vessels. In January 2003 the Eighth Coast Guard District issued a policy letter concerning the use of Dynamic Positioning as the only means to “moor” an offshore support vessel in deepwater during transfers of hazardous materials. The policy sets minimum performance and equipment standards and allows DP-0 vessels to conduct transfer operations if automatic shutoff valves and quick-disconnect couplings are installed. Harold Wilson of Tidewater, the Chairman of the OMSA OSV committee, is spearheading the OMSA review of the IMCA draft to make sure it conforms to industry practice in the Gulf of Mexico.

The IMO has implemented rules for NOX emissions. These rules have now been ratified and go into effect on May 20, 2005. The rules are retroactive to engines built after January 1, 2000. IMO rules require an IAPP (International Air Pollution Prevention) Certificate for vessels over 400 gross tons. Vessels over 400 gross tons in international service will need to hold an IAPP Certificate in addition to the currently required IOPP (International Oil Pollution Prevention) Certificate. According to an EPA publication these certificates will be issued by the Coast Guard or their designee. An EPA fact sheet on this subject can be obtained by email from Ken Parris at the OMSA offices. Information can also be obtained from the IMO website at www.imo.org in their marine environment, pollution prevention section.

OMSA will continue to monitor the progress of these requirements and keep industry informed.

Vessel operators should take care to ensure that any foreign nationals working offshore comply with U.S. Law. Given the specialized skills involved in offshore work, U.S. vessel operators may find that customers place foreign nationals on board the vessel in non-crew capacities. This can create problems under Coast Guard regulations. According to the Coast Guard a crewmember is any person who performs work on the vessel. In April 2004 the Eighth Coast Guard District issued a policy memorandum on the subject. In short the policy reiterates the law, stating that all persons working aboard a U.S. flag vessel on the Outer Continental Shelf in support of OCS activities must be a U.S. Citizen or lawfully admitted alien (green card holder). In addition, the total number of non-citizen workers (green card holders) cannot exceed 25% of the total. The policy can be found at http://www.uscg.mil/d8/Divs/M/2004%20Policy/Policy%20Ltr%2002-2004.pdf. Vessels such as seismic, anchor handling or construction should use care to insure that any workers provided by third parties are legally admitted aliens and that the total complement of non-citizen workers does not exceed 25% of the total workers aboard.

The United States has been moving toward harmonization of the domestic rules for the transportation of hazardous materials found in 49 CFR with the International Dangerous Goods Code. The Research and Special Programs Administration (RSPA) is making a lengthy (135 page) amendment to hazardous materials (HazMat) transportation regulations in order to maintain alignment with recent changes to the International Maritime Dangerous Goods (IMDG) Code. The amendments came into effect on January 1, 2005, with required compliance delayed until January 1, 2006.

The changes will primarily affect shippers of dangerous goods. Vessel operators should be aware that shippers of hazardous materials regulated by 49 CFR are required to provide you certification in accordance with 49 CFR 172.204 that the hazardous materials being shipped are in full conformance with applicable law and regulation.

The document can be reviewed on the DOT Docket Search at http://dms.dot.gov/search/searchFormSimple.cfm, enter docket number 17036.

The USCG National Vessel Movement Center (NVMC) issued its latest Newsletter. The newsletter discusses some of the most common problems experienced with the advance notice of arrival (ANOA) and notes that both the name and the nation of the last five port calls should be included in the ANOA. While other submittal methods may be used, masters are encouraged to submit their ANOA via the interactive Web site. The NVMC also released a PowerPoint Presentation discussing the ANOA process. The NVMC website is http://www.nvmc.uscg.gov. Most offshore support vessels are exempted from reporting advance notice of arrival.

The U.S. Department of Justice stated that two engineering officers from a foreign flag freighter were each sentenced to two years probation and a fine of $3,000. During a Coast Guard boarding the engineers presented a falsified oil record book to the U.S. Coast Guard indicating that waste oil had been properly disposed of, when in fact it had been pumped overboard at sea.

Table of Contents

OMSA’s Security initiative will have three main objectives for 2005, Audits, Exercises and Plan Updates.

Coast Guard security regulations require that each vessel subject to the security regulations undergo an annual audit. The purpose of the audit is an internal (company) evaluation of the vessel’s compliance with its security plan and a determination as to how well does the vessel’s security plan meet its needs. There is no requirement for the audit to be conducted by an outside third-party, but if it is conducted by company personnel it must be done by someone other than the CSO. The OMSA security committee has formed an Audit Protocol sub-committee to develop an audit procedure for our plans.

Similar to the oil spill exercises that deep draft vessels must undergo each year companies must exercise their vessel security plans. OMSA will conduct wide-scale exercises of all companies participating in the OMSA security plan later this year. The Coast Guard has stated that the exercises must be held between July and December of this year.

OMSA plans to hold a large scale exercise that will allow members to participate in the same room at the same time. Immediately after the completion of the exercise participants will hold what is commonly referred to as a “hot wash”. With the problems encountered in the exercise fresh in everyone’s minds, the exercise participants will create as complete a list as possible of all glitches that occurred. The OMSA and HudsonTrident staff will itemize the list and determine which problems were systemic (plan related) and which were related to an individual company’s plan execution. Those issues that are plan related will be combined with the results of the vessel security audits conducted previously and used as the basis for a plan update. Company specific issues will be addressed with individual company security officers.

Congress had mandated that highly sophisticated identification cards be developed and issued to all transportation workers (truck drivers, vessel personnel, aircraft pilots, longshoremen, etc) by last year. A recent Government Accounting Office report was highly critical of the Department of Homeland Security’s failure to accomplish that requirement.

The Maritime Transportation Security Act (MTSA) of 2002 calls for the Department of Homeland Security (DHS) to issue a worker identification card that uses biological metrics, such as fingerprints, to control access to secure areas of ports or ships. The Transportation Security Administration (TSA), within DHS, initially planned to issue a Transportation Worker Identification Credential in August 2004 to about 6 million maritime workers. The GAO report found that serious issues remained to de addressed before the TSA could move forward with the development and issue of these credentials and that no credible timeline for its accomplishment could be established.

In the future all current mariner identification will be replaced by highly sophisticated identification. When that will be done is uncertain.

The Offshore Marine Service Association (OMSA) is co-sponsoring the Offshore Logistics conference with the International Association of Drilling Contractors. The conference will be held Monday April 11th and Tuesday April 12th at the Hilton Lafayette and Towers. The conference will consist of two days of informative panels discussing areas of interest to the offshore community.

Day One will start out with keynote speaker Richard Healing, Board Member, National Transportation Safety Board.

The keynote address will be followed by the Boats and Vessels panels. Of special note to the industry is the first panel with the Coast Guard discussing vessel security and a presentation on Third Party Boarding Agreements by Shull Autin of Seacor and John Peuler of Peuler & Ernst. These boarding agreements are strongly supported by OMSA members. A representative from Customs and Boarder Protection will be speaking on issues related to electronic cargo reporting.

The second Boats and Vessels panel will include speakers discussing liquid mud circulation and tank cleaning and issues related to pre-slung cargoes.

The afternoon panels will include discussions on fixed offshore facility logistics , offshore construction project logistics and helicopter logistics issues.

Day Two will begin with a keynote presentation by Mr. Lars Herbst of MMS followed by the Shore Base Operations panel and Port Operations panel. Of note on Day Two are presentations by Dave Vizier, Edison Chouest Integrated Logistics Division and Ted Falgout, Executive Director of the Port Commission of the Port of South LaFourche.

Additional panels will discus outsourcing logistics, materials handling, back safety and training programs, pipe loading and the new IADC cargo handling guidelines.

Registration forms and additional information on the many other presentations can be obtained by contacting OMSA or online at www.IADC.org.

OMSA held its Christmas Dinner Dance on Friday, December 10, 2004 at the Hilton New Orleans Riverside in New Orleans. The turnout was good and everyone seemed to be into dancing to the tunes of the band, Forecast. As is the usual case the party started on time and went late.

The 2005 Christmas Dinner Dance will be on Friday, December 9, 2005 at the Hilton New Orleans Riverside in New Orleans. Hope everyone can join us on that date.

Ragen Brown (OMSA), Lillie Licciardi (OMSA), Amanda Hall (Lillie’s Niece), Ellen Hall (Lillies’s Sister) made sure the evening went off without a hitch.

OMSA held its 3rd Annual Lone Star Golf Tournament and membership drive, October 18, 2004 at WILDCAT GOLF CLUB in Houston, Texas.

OMSA wants to thank its Sponsors for making this tournament such a successful event.

Universal Parts & Supply, Inc.
(Barbecue Sponsor)

Bender Shipbuilding & Repair Company, Inc.
(Golf Cart Sponsor)

Front 9 - Hole Sponsors
Sea Mar, Inc.
Jones Walker
Bates Unlimited & Associates
Action Specialties
Rolls-Royce Commercial Marine
Green Marine & Industrial Equipment Company
Oceanwide Maritime Employment
Kongsberg Maritime
Hornbeck Offshore Operators

Back 9 - Hole Sponsors
Tidewater Marine
WorkBoat Magazine
Hudson Trident
Bowen, Miclette & Britt
Lemle & Kelleher
Southern States Offshore, Inc.
VT Halter
Bayou State Marine & Industrial Supply
Offshore Oil Services

Drawing Prizes
American Bureau of Shipping
Rolls-Royce Commercial Marine
Bayou State Marine & Industrial Supply
Cashman Equipment
Dolphin Towing

“Should’ve Gone Fishing” Prize
Canal Barge - 4 Rods & Reels

Ditty Bag Sponsors
American Bureau of Shipping
Bates Unlimited & Associates
Bayou State Marine & Industrial Supply
Green Marine & Industrial Equipment Company
L & M Botruc Rental
Oceanwide Maritime Employment
Rolls-Royce Commercial Marine Inc.

WINNERS
1st Flight – 1st Place
Nick Vanoverdam
Shane Guidry
Jon Holvik
Barry Autin

1st Flight – 2nd Place
Andrew Lipair
Craig Landry
Gary Gifford
Glen Shropshire

1st Flight – 3rd Place
Mike Wilson
Dan Mohr
Alan Vernon
Richard Wood

2nd Flight – 1st Place
Mike Little
Lewis Eaves
Tommy Echols

2nd Flight – 2nd Place
Bill Mahley
Bijan Siahatgar
John Ordonne
Matt Compaux

2nd Flight – 3rd Place
Mark Scairono
Ralph Waguespack
Mark Cairns

Closest to the Hole – Glen Shropshire
Longest Drive – Shane Candies
$500 Drawing - Robert Robertson

We owe many, many thanks to our 3rd Annual Lone Star Golf Tournament Volunteers. With their help, we were able to have such a good tournament.

Suzi Ward – Oceanwide Maritime Employment.Com
Melissa Goodrum – Southern States Offshore, Inc.
Chuck Freeman – International Marine Systems, LLC
Russell Louviere – Devon Energy Production Company, L.P.
Brandt Dufrene – Oceanic Fleet
Danny Moore – Green Marine & Industrial Equipment
Kelly & Todd Reed – Bayou State Marine & Industrial Supply, Inc.

This year’s 4th Annual Lone Star Golf Tournament is scheduled once again at Wildcat Golf Club on October 25, 2005 (Tuesday). Business Meeting will take place at the OMNI Houston the next day, October 26 (Wednesday).

Signet Maritime Corporation
Regular Member (Tugs/Barges)

BSI Marine Contractors, Inc.
Regular Member (Inland Tugs)

Pelican Offshore Services, Co., Inc.
Regular Member (Crewboats/Supply Vessels)

Hercules Liftboat Co. LLC
Regular Member (Liftboats)

C. S. Lift Boats Inc.
Regular Member (Liftboats)

W & O Supply, Inc.
Associate Member (Distributor of pipes, valves & fittings for the marine industry)

AmSouth Leasing
Associate Member (Marine related financing)

Strasburger & Price, LLP
Associate Member (Law Firm)

Engine Monitor Inc.
Associate Member (Manufacture of steering, PLC, monitoring engine control systems)

Table of Contents

We acknowledge and thank the individuals and organizations that have contributed to this newsletter by submitting informative articles and/or granting OMSA permission to reprint material from their publications.

Founded in 1945 Beier Radio has been serving the marine industry in the Gulf of Mexico for over 60 years. Their main office is in Belle Chasse, Louisiana with a service depot in Morgan City, LA.

When you need the latest in technology and someone to make the job happen on time and on budget, contact us. They are ready to provide you with:

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Thank you for 60 Great Years!
1945 to 2005