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NOVEMBER 2017 NEWSLETTER TABLE OF CONTENTS 2018 OMSA Membership Renewal 2 Message from OMSA President 2 OMSA PAC Activities 2 OMSA Staff Email Change Update 3 Last Chance to Respond! OMSA 2018 Meeting Survey 3 Save the Date: OMSA Year End Member Call-In, Tuesday, December 19 3 Regulatory Deadlines 3 US Coast Guard (USCG) News 4 Federal Regulatory Review 6 Cybersecurity News 7 National Maritime Center News 8 Federal Advisory Committee News 9 Other News 10 International News 12 Follow OMSA on Social Media 12 OSVDPA Accredits Florida Training Provider 13 OSVDPA Membership Enrollment Now Open 13 TBD: 2018 OMSA Meetings & Events Calendar -- Newsletter Sponsor: Advanced Logistics, LLC 15 OMSA Newsletter Sponsorship Opportunities 16
Transcript
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NOVEMBER 2017 NEWSLETTER TABLE OF CONTENTS

2018 OMSA Membership Renewal 2 Message from OMSA President 2 OMSA PAC Activities 2 OMSA Staff Email Change Update 3 Last Chance to Respond! OMSA 2018 Meeting Survey 3 Save the Date: OMSA Year End Member Call-In, Tuesday, December 19 3Regulatory Deadlines 3 US Coast Guard (USCG) News 4 Federal Regulatory Review 6 Cybersecurity News 7 National Maritime Center News 8 Federal Advisory Committee News 9 Other News 10International News 12 Follow OMSA on Social Media 12 OSVDPA Accredits Florida Training Provider 13 OSVDPA Membership Enrollment Now Open 13 TBD: 2018 OMSA Meetings & Events Calendar -- Newsletter Sponsor: Advanced Logistics, LLC 15 OMSA Newsletter Sponsorship Opportunities 16

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2018 OMSA Membership Renewal Notice By: Ashley Smith

Membership renewal for 2018 has begun! The company ACCOUNT HOLDERS/BILLING PERSON has

received the notice to complete the online renewal process. If you have questions on who your company account

holder is, please let me know. As a reminder, OMSA Membership runs from January 1 – December 31.

OMSA membership renewal is ONLINE and the invoice is auto-generated. Thank you in advance for your

attention to this matter. Please don’t hesitate to contact me with any additional questions or concerns!

Message from OMSA President

By: Aaron Smith

We know the end of the year is always a busy and stressful time. The professional challenges of budget season

intersect with the personal stress and rewards of the holidays. Additionally, it always seems that this time of year

is always more active on the political and policy fronts than it should be. 2017 doesn’t seem to be any different.

Specifically, it seems that Congress may (or may not) be considering sweeping changes to federal tax laws, multi-

billion-dollar disaster relief bills, changes to immigration rules, and bills intended to keep the government funded

through next September. In addition, the Louisiana State Legislature is trying to figure out how it will address

budgetary hole expected to be more than a billion dollars next year. In all of these efforts, OMSA is working to

ensure that the offshore marine industry is not adversely impacted. If you see something that OMSA should be

doing, please let Richard, Ashley, Ben, or myself know, we are here to help and want to ensure we are providing

a value to you and your organization.

Toward that end, thank you to everyone who responded to Ashley’s survey about meetings. We received a

tremendous response and great input. We are now analyzing the responses and will be adapting the meeting

schedule and format in accordance with the great input received. If you have other ideas about how meetings can

be improved, please do not hesitate to let us know.

Again, the OMSA staff thanks all OMSA members for their continued involvement. We look forward to serving

you in 2018.

OMSA PAC Activities

By: Aaron Smith

This month, the OMSA PAC made a contribution to U.S. Representative John Garamendi (D-CA). Rep.

Garamendi is the Ranking Member on the Coast Guard Subcommittee and a stalwart Jones Act supporter. Court

Ramsay of Aries Marine and Aaron Smith delivered the contribution. During the presentation, OMSA and

Representative Garamendi discussed how OMSA could make more inroads with the Democratic Caucus.

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OMSA Staff Email Change Update

By: Ashley Smith

The OMSA staff have new email addresses. Please make the necessary updates.

[email protected]

[email protected]

[email protected]

[email protected]

Last Chance to Respond! OMSA 2018 Meeting Survey By: Ashley Smith

As we look to confirm our Meetings and Events for 2018, we recognize that there are a number of challenges

facing the OMSA membership, including condensed schedules and expanded responsibilities amongst your

staff. It is for this reason we are reaching out to you today.

OMSA is considering a major change in our meeting format – going from quarterly meetings (with committee

breakouts) to two conference-style meetings (general meeting/breakout session) for Spring and Fall. In this new

format, we would have the committees meet separately from the general conferences. Before we move forward

with anything, we ask that you please take a moment of your time to complete this very short, nine-question

survey.

Click here to start the brief survey!

Your feedback is invaluable! Thank you for taking the time to complete this. Please let me know if you have any

additional questions or concerns.

Save the Date: OMSA Year End Member Call-In, Tuesday, December 19 By: Ashley Smith

Please mark your calendars on Tuesday, December 19th at 10:00 am CST for the OMSA Year End Member Call-

In. Complete details, including call-in number and agenda, will be sent a few days prior.

If there are any items you would like the OMSA Staff to specifically note on the call, please email me directly.

Regulatory Deadlines

By: Richard Wells

12/18/17: EPA sVGP effective (commercial vessel less than 79 feet),

01/01/18: IMO Polar Code effective date for Existing Ships (at next renewal or intermediate SOLAS

Certificate survey),

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01/01/18 DOT drug testing rule effective date (See details in Other News below)

01/01/18: EU MVR CO2 monitoring begins for ships over 5,000 GT operating in EU ports,

07/01/18: IMO Polar Code STCW training effective date (Delayed from January 1 by MSC),

07/20/18: All existing towing vessels must comply with Subchapter M requirements, and

07/22/19: USCG Towing Vessel one quarter of existing tugs require Certificate of Inspection.

U.S. Coast Guard (USCG) News

By: Richard Wells

USCG Waivers for Hurricane Response: OMSA has continued working to allow OSVs, crewboats, and other

appropriate vessels to assist in the Puerto Rican recovery efforts. Most recently, OMSA exchanged letters with

RDML John Nadeau requesting expanded waivers to allow workboats to participate in these efforts. As seen by

the USCG letter, the USCG believes there are adequate cargo vessels available to carry necessary relief cargo to

Puerto Rico and did not grant a blanket waiver. They are willing to consider case-by-case waivers, if needed.

Prior to OMSA’s latest exchange of letters, the USCG issued three policy documents (see links and descriptions

below) addressing waivers for vessels and crewmembers wishing to assist in hurricane recovery and restoration

voyages to Puerto Rico or the U.S. Virgin Islands (USVI). These policy documents were the result of the OMSA

membership and OMSA staff reaching out to the USCG offering the resources of the OMSA membership to assist

our fellow citizens. Specifically, this is one of the letters sent to the USCG which sought to secure a waiver from

the USCG Seventh District’s (Miami) has long-held policy which dictated that only a cargo ship certificated for

an international voyage may carry cargo from the U.S. mainland to Puerto Rico or USVI.

In response to OMSA’s effort, the following policy letters were issued:

• Hurricane Relief Vessel Guidance PL 17-06 addresses what vessels can be used and the process for

requesting any waivers.

• PL 17-06 Change One was issued soon thereafter clarifying the waiver process.

• MMC PL 02-17 was issued clarifying appropriate relaxations for OSV credentialed mariners to serve aboard

hurricane relief vessels.

All policies will expire on January 31, 2018, unless extended or cancelled earlier.

Based on those waiver requests the OMSA staff is aware of, it appears the following factors yield a more likely

waiver approval:

• A signed contract from a Puerto Rico or USVI entity for transportation or vessel-related services (this

factor is almost a “must have”);

• A specific request from the territorial government or FEMA for that vessel or service (a “nice to have”

that has been found to yield results);

• Evidence that the need the vessel will fill is not and cannot be filled by an available cargo vessel

certificated under 46 C.F.R. Subchapter I,

• Stating the OSV seeking the waiver is immediately available;

• Stating that the vessel will be staffed with a three-watch crew for the voyage(s); and

• Stating the OSV has unique capabilities or features that a cargo ship cannot fulfill.

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It is worth noting, these factors seem to be helpful in securing a positive response from OSV’s seeking

Subchapter I waivers. OMSA is not aware of any waivers that have been granted allowing Subchapter I vessels to

deliver and transfer fuel, or other combustible liquids.

Additionally, the OMSA staff reminds OMSA members that appeals of any denied waiver requests are allowed.

To appeal a denied waiver request, send an appeal request in writing (either mail or email) to:

Commandant (CG-CVC),

U.S. Coast Guard, Stop 7501

2703 Martin Luther King Jr Ave., SE,

Washington, DC 20593-7501

But mail or email the appeal to:

Commander (dp),

USCG Seventh District

Brickell Plaza Federal Building

909 SE 1st Avenue

Miami, FL 33131-3050

The appeal must state the reason(s) you believe the waiver denial is incorrect. See 46 C.F.R 1.03-25 and 46

C.F.R. 1.01-15 for appeal process references and details.

NVDC U.S. Build Determination Guide: The NVDC posted a policy guidance document entitled “Review

Criteria for Steel Weight Components WRT U.S. Build and Foreign Rebuild Determinations.” This guide

explains how the Coast Guard’s Naval Architecture Division reviews various steel components with respect to the

definitions of “hull” and “superstructure” under USCG regulations. The Review Criteria are key to the NVDC’s

determination of whether a vessel may receive a Certificate of Documentation with a Coastwise Endorsement to

operate in the Jones Act trade. Naval Architects and shipyard personnel are urged to study this document.

USCG Fire Extinguisher Recall Alert: The USCG issued Safety Alert 12-17 to inform mariners of a recall of

certain models of Kidde brand fire extinguishers. Nearly 40 million extinguishers involving 134 different models

have been recalled. The extinguishers were manufactured between January 1, 1973 and August 15, 2017,

including models that were previously recalled in March 2009 and February 2015. The extinguishers were sold in

red, white, and silver cylinder colors and are rated as either ABC or BC. OMSA comment - it is likely that these

extinguishers are also located in company office kitchen areas, home kitchens, and recreational vessels/vehicles.

This product recall involves two styles of Kidde disposable fire extinguishers: Plastic handle fire extinguishers

and plastic push-button fire extinguishers. This recall does not include Kidde Professional or Badger branded fire

extinguishers. Units with metal handles/valve assemblies are not included in the recall.

Read the full announcement on the Consumer Product Safety Commission website.

Who to Call in USCG with Manning Questions: The OMSA staff reminds members and mariners that

questions regarding vessel manning or credentials required for a particular vessel should be directed to the local

OCMI, not the National Maritime Center (NMC). Any questions on vessel manning or credentials required should

only be directed to the local OCMI’s Prevention Department.

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USCG Website links: The USCG recently completed the migration of all web sites to a new, more secure server.

As a result, many questions and comments from the maritime community were submitted asking how to navigate

the new sites. Please click here for a list of updated web addresses for some of the industry-focused USCG web

sites vessel operators visit the most.

USCG Documented Vessel Change of Address Reminder: The National Vessel Documentation Center

(NVDC) issued a notice reminding stakeholders of USCG documented vessels of the requirement to submit a

change of address to NVDC within 10 days, of the address change of the managing owner of the vessel as

required by 46 CFR 67.113(e).

Notify NVDC of any change by using one of the following methods:

1. E-mail the request to: [email protected],

2. Fax the request to: (304) 271-2541, or

3. Annotate the new address on the CG-1280 Certificate of Documentation renewal notice (at the time of

renewal) before returning it via fax or mail.

Include the Official Number, both the old and new address, and owner name and phone number.

No third-party address change requests will be acknowledged or honored by the USCG.

Award Nominations for Excellence in Maritime Security Sought: The USCG has set January 31, 2018 as the

deadline to submit nominations for the Rear Admiral Richard E. Bennis Award for Excellence in Maritime

Security. This award recognizes outstanding achievements and contributions of the maritime community with

regards to implementation of Maritime Transportation Security Act requirements and other maritime security best

practices in safeguarding our nation’s marine transportation system. Any marine transportation related

organization owning, operating, or otherwise managing vessels; waterfront facilities; fleeting areas; or other entity

engaged in maritime operations subject to Coast Guard maritime security regulations from January 2016 through

December 2017 is eligible. Award nomination process and further details may be found by clicking here.

Federal Regulatory Review

By: Richard Wells

Reducing Regulations: President Trump issued an executive order on Reducing Regulation and Controlling

Regulatory Costs. Among other things, it calls for the repeal of two regulations for each new one published and

directs that the total incremental cost of new regulations shall be no greater than zero, unless otherwise required

by law. Each agency is rolling out their process for suggesting regulations to be modified or repealed separately

and the OMSA staff will advise the OMSA membership when relevant agency requests are available and when

appropriate ask you to submit comments to the regulators. Notable reviews include:

USCG Process: The U.S. Coast Guard (USCG) accepted public comments for 90 days. OMSA submitted

these comments. This considerable submission was only possible due to the active participation from OMSA

members. Thank you for submitting the regulatory headaches you were experiencing and suggested solutions

for how these issues could be affected.

The USCG has also tasked all their Federal Advisory Committees (FACAs) to make suggestions on the

ongoing regulatory review process. To date, the FACAs listed below have begun working on regulatory

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review. As additional groups begin working, they will be added to this listing. It would be very helpful to

have the relevant committee submit OMSA member concerns to the USCG in addition to that same

suggestion coming from your company and from the OMSA staff during the public comment period noted

above. To have a staff member placed on the advisory committee working group roster, please email the name

and email address of the participants to the contacts below:

• NOSAC diving regulations review: Patrice Delatte [email protected],

• NOSAC OSV regulations review: Chad Fuhrmann

[email protected],

• MERPAC 46 C.F.R. Parts 11 and 12, deck credential regulations review: Warren

Sanamo, [email protected],

• MERPAC 46 C.F.R. Parts 11 and 12, engineer credential regulations review: Rosemary

Mackay, [email protected], and;

• MERPAC 46 C.F.R. Part 15, manning regulations review: Ira Douglas,

[email protected].

If you participate in any of these committees, please help OMSA ensure that these committees’

recommendations are palatable for OMSA members, mariners, and vessels.

CBP Process: The U.S. Customs and Border Protection (CBP) has published a formal request in the Federal

Register, with the deadline to submit suggestions of December 11, 2017. When submitting your concerns to

OMSA, please include the citation in the Code of Federal Regulations (such as: 46 C.F.R. 15.1101(a)) and

suggest answers for relevant questions:

1. Are there CBP rules or reporting requirements that have become outdated and, if so, how can they be

modernized to better accomplish their objective?

2. Are there CBP rules that are still necessary, but have not operated as well as expected such that a

modified, or slightly different approach at lower cost is justified?

3. Are there CBP rules that unnecessarily obstruct, delay, curtail, or otherwise impose significant costs

on the secure flow of legitimate trade and travel to and from the United States?

4. Does CBP currently collect information that it does not need or use effectively?

5. Are there regulations, reporting requirements, or regulatory processes that are unnecessarily

complicated or could be streamlined to achieve statutory obligations in more efficient ways?

6. Are there rules or reporting requirements that have been overtaken by technological developments?

Can new technologies be leveraged to modify, streamline, or do away with existing regulatory or

reporting requirements?”

OMSA members may participate by either emailing your suggestions to Richard Wells or by commenting

directly at this link, and then clicking the blue “Comment Now!” button.

Cybersecurity News

By: Richard Wells

US-CERT Alert on Cyber Attacks on Energy Sector: The United States Computer Emergency Readiness

Team (US-CERT) has published this document warning about confirmed cyber-attacks on the energy sector. The

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link is very technical, but the bottom line is that the energy sector is under active cyber-attack. This may be a

good time to remind all your computer users to cast a skeptical eye on emails apparently coming from your

business partners with attachments or links, especially “Bit.ly” links or shortened/obscured links. This

information was passed to those OMSA member Company Security Officers (CSO) that are registered with

OMSA. If you are a CSO and did not get this information directly from OMSA, please email your name and

email address to [email protected] asking to be added to the CSO email list.

Key Cyber Questions and Challenges: The US Coast Guard issued a bulletin highlighting five key cyber

questions and challenges facing the maritime industry. Cyber systems are prevalent in maritime operations. There

is an ever-increasing amount of cyber influence in lifestyles and work. The Marine Transportation System (MTS)

uses cyber systems in all aspects of operations. With the convenience and improved performance offered by

technology come continually-evolving questions and challenges. Cyber threats are real and pose considerable

risks requiring attention and action at all organizational levels.

Below are five key cyber questions and challenges facing the maritime industry and how you can begin assessing

and reducing risk:

1. How much should I invest in cybersecurity and cyber risk management?

2. We have a closed system with an air gap between our network and outside influences. Am I still at

risk?

3. What are the greatest threats to my cyber systems?

4. I think our organization is the victim of a cyber-attack or incident. Who can I notify? Reports of

suspicious activity or a breach of security, and incidents affecting physical security or including a pollution

event should be reported to the NRC at 1-800-424-8802.

5. We need to address cyber risks in our organization, where do we begin?

For the USCG answers to these questions, please click here.

National Maritime Center News

By: Richard Wells

NMC Performance Report: The USCG National Maritime Center (NMC) released their Merchant Mariner

Credential (MMC) Performance Report for October. The number of applications in processing decreased to 1,635

(the lowest level in two years). Average total gross processing time decreased to 41 days. Click here for full

details.

NMC Med Cert Performance Report: The NMC is also reporting their performance issuing mariner medical

certificates. Currently, they report 15 days gross and 8 days net processing time, on average. Full details are here.

NMC Examination Review Groups Members Sought: The USCG is commissioning a working group to

review existing and new examination questions for accuracy, and review the accuracy and availability of

examination references, length of examinations, and the use of standard technologies in administering, scoring,

and analyzing examinations. The group specifically needs:

• Representatives from Coast Guard-approved training providers,

• Credentialed Deck officers or ratings,

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• Credentialed Engineering officers or ratings, and

• A Human Performance Technology representative.

Cover letters expressing interest in participating in the work group should identify which membership category

the party seeks consideration for. Résumés with supporting experience should be attached to the cover letter.

Requests should reach the Coast Guard on or before November 10, 2017, via-mail to:

[email protected], full details are here.

Federal Advisory Committee News By: Richard Wells

NOSAC Meeting in Houston: The National Offshore Safety Advisory Committee (NOSAC) and its working

groups, will meet at the following location, date, and times to discuss issues related to OSV and offshore

operations safety:

Location: USCG Sector Houston/Galveston

13411 Hillard Street

Houston, Texas 77034

Dates: Tuesday, December 12, 2017 and Wednesday December 13, 2017

Times: On Tuesday, December 12, 2017, the Safety Management Systems on Vessels Engaging in

Well Intervention Subcommittee will meet from 10 a.m. to 11:30 a.m., immediately

followed by the Regulatory Review Subcommittee which will meet from 11:30 a.m. to 5

p.m.

On Wednesday December 13, 2017, the full Committee will meet from 8 a.m. to 6 p.m.,

and will include the previously separate meeting of the Coast Guard Industry Day Forum

from 11:30am - 3:30pm primarily focused on MODU and offshore rig topics. Please note

the new later ending time.

Items of note that NOSAC will address include:

• Progress report from the Subcommittee on Safety Management Systems on Vessels Engaging in Well

Intervention Activities.

• Progress report from the Regulatory Review Subcommittee.

• Outer Continental Shelf Industry Focus Forum (Former Industry Day).

• Presentations on the following topics:

o USCG Regulatory Status Update;

o USCG Cyber Security Initiatives update;

o Maritime Administration Update; and,

o Bureau of Safety and Environmental Enforcement Update.

Preregistration for NOSAC is NOT required, but a government issued picture identification (driver’s license or

passport) is required to satisfy building security. Preregistration for the Industry Day meeting IS required and can

be made here. For full details please click here.

NMSAC Cyber Conference Call: The National Maritime Security Advisory Committee (NMSAC), will meet

via telephone conference call at the following date and time to review and discuss the results of the ‘‘Navigation

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and Vessel Inspection Circular 05–17; Guidelines for Addressing Cyber Risks at Maritime Transportation

Security Act Regulated Facilities’’ task. This teleconference is open to the public.

Date: Thursday December 14, 2017

Time: Noon to 1:30 pm (Central Time)

To participate via teleconference, dial 1–202–475–4000; the passcode to join is 764 990 20#. Additionally, if you

would like to participate in this teleconference via the online web format, please log onto

https://share.dhs.gov/nmsac/ and follow the online instructions to register for this meeting. If you encounter

technical difficulties, contact Mr. Ryan Owens at (202) 302–6565.

Other News

By: Richard Wells

DOT Drug Test Rule Published: As a reminder, the Department of Transportation (DOT) drug testing rules

apply to all USCG-regulated mariners as well as commercial truck drivers. As such, the OMSA staff recommends

all vessel operators contact your vendors providing your USCG required drug testing program to ensure they will

be in full compliance by the deadline.

The DOT published a final rule effective January 1, 2018, that will add testing for four semi-synthetic opioids

(i.e., hydrocodone, oxycodone, hydromorphone, oxymorphone). Some common names for these semi-synthetic

opioids include OxyContin®, Percodan®, Percocet®, Vicodin®, Lortab®, Norco®, Dilaudid®, Exalgo®. In

addition, the testing for MDEA is ended, but testing for MDA will be added. Click here for a rule summary.

sVGP Reminder: Those OMSA members with vessels less than 79 feet in length will need to comply either with

the EPA sVGP (Small Vessel General Permit) or the VGP (Vessel General Permit) not later than December 18,

2017. If you have larger vessels currently under the VGP, it may be easier to cover all your fleet with the same

permit, rather than having two permit systems to manage. Details are available here for sVGP or here for VGP to

assist in compliance. If using the VGP, each vessel must select one of the two applicable options to secure

coverage under the VGP. The electronic NOI becomes effective seven days after completing the EPA electronic

form, so to have coverage by December 18, 2017 you need to begin the EPA multiple step registration process no

later than late November.

USCBP Clearance Clarification: The OMSA staff contacted the local Customs and Border Protection (USCBP)

staff to assist an OMSA member. The following information was provided by CBP and it may also be helpful to

other OMSA member’s operations (questions in black, responses in red).

If a U.S.-flag vessel is bringing cargo to a U.S.-flag vessel not attached to the Sea floor but outside

the 3-mile limit, is this a coastwise or foreign voyage? If a vessel transports merchandise outside

territorial waters to an unattached vessel, the vessels must make entrance and clearance with CBP

upon arrival back into port.

If a non-U.S. flag pipelay barge is laying pipe outside the 3-mile limit (the pipe is in contact with

both the barge and the OCS seabed) and a U.S.-flag vessel transfers merchandise to the barge is

this a coastwise or foreign voyage? If a pipelaying vessel is attached and laying a pipeline, it is a

coastwise point. No entrance required by the support vessels.

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Is it still the current CBP view that; if the MODU was preparing to drill, CBP considers the

MODU as attached, even if still free floating? A MODU is a MODU regardless if it is in the

drilling mode or not. If the MODU is in the drilling mode it must be supported by Jones Act

qualified vessels, since the MODU is considered attached, a coastwise point. If the MODU is

unattached (free floating), it must be supported by U.S. flag vessels that possess a “Registry”

endorsement. These vessels must enter and clear with CBP, since they are transporting

merchandise to an unattached MODU.

What type of voyage or operation (particularly those noted above) requires the shipper or

transporter of the cargo to make a Customs declaration or other report to CBP? Vessels that

transact business with another vessel while outside territorial waters.

Additional information CBP provided:

19 C.F.R. 4.3 Vessels required to enter; place of entry.

(a) Formal entry required. Unless specifically excepted by law, within 48 hours after the arrival

at any port or place in the United States, the following vessels are required to make formal

entry:

(1) Any vessel from a foreign port or place;

(2) Any foreign vessel from a domestic port;

(3) Any vessel of the United States having foreign merchandise on board for which entry

has not been made; or

(4) Any vessel which has visited a hovering vessel as defined in 19 U.S.C. 1401(k), or

has delivered or received merchandise or passengers while outside the territorial sea.

(CBP added this red text to the regulation text quotation.)

Related to Offshore Drilling and the term “attached,” please see below:

For periods immediately prior to, during, or at the conclusion of exploration for or exploitation of the resources of

the Shelf, “attachment” for purposes of enforcement of the vessel laws would be recognized in the following

circumstances:

(a) platforms or production facilities attached to the seabed by any means;

(b) the drill stem is inserted into the seabed;

(c) the support or anchoring system is in place, but the drill stem is not yet inserted into the seabed;

(d) Mobile offshore drilling units (“MODU”) (drill ships, semi-submersibles and jack-up rigs) are deemed

“vessels,” as that term is used in Part 4 of the CBP Regulations and are subject to the requirements in the

laws and regulations administered by CBP which are applicable to conventional vessels. [Definition: 46

U.S.C. 2101(15a), states that a “’mobile offshore drilling unit’ means a vessel capable of engaging in

drilling operations for the exploration or exploitation of subsea resources.”]

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(1) A mobile offshore drilling unit, while in waters subject to U.S. jurisdiction, must comply with

all the usual requirements applicable to vessels (i.e. requirements pertaining to report of arrival,

entry and clearance). The requirements would depend on whether the mobile rig is documented as

a vessel of the United States, vessel of foreign registry, or undocumented vessel.

(2) Mobile offshore drilling units which come to rest at a geographical “point” on the high seas

outside U.S. territorial waters over the Outer Continental Shelf are not required, for CBP purposes

only, to Enter from or Clear to a foreign port, unless that point, where they come to rest, is an

artificial island or fixed structure erected on the Shelf. [See HQ 111329 (Dec. 5, 1990); HQ

112611 (June 23, 1993)]

(3) When the offshore drilling unit (or rig) is secured for drilling operations, or otherwise engaged

in oil drilling activities on the Outer Continental Shelf, the CBP and navigation laws, including

coastwise transportation requirements are fully applicable for the duration of such operations. [HQ

115134 (Sept. 27, 2000)]

International News By: Richard Wells

IMO BWMC Ratifications: The International Maritime Organization (IMO) Ballast Water Management

Convention (BWMC) has been ratified by the following nations in 2017 and will go into effect for them in 2018;

Portugal, Jamaica, Malta, Argentina, Madagascar, Honduras, Greece, Bahamas, Singapore, Australia, UAE, Saudi

Arabia, and New Zealand. The U.S has not indicated an intent to ratify the BWMC.

Follow OMSA on Social Media

By: Ashley Smith

OMSA has updated its social media presence in order to keep our membership updated and make sure our voice

is heard!

• Click here to follow OMSA on Facebook.

• Click here to follow OMSA on Twitter.

• Click here to follow OMSA on LinkedIn.

For additional questions or concerns, please contact me directly at [email protected].

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OSVDPA Accredits Florida Training Provider By: Ben Berson

The OSVDPA recently announced that it accredited Resolve Maritime Academy to conduct OSVDPA classes and

assessments.

Resolve becomes the fourth OSVDPA-Accredited Training Provider, joining The Marine Training Institute

(TMTI) in Gray, Louisiana; Kongsberg Maritime, with facilities in Houston, Texas and St. Rose, Louisiana; and

GE Marine in Houston, Texas.

Resolve Maritime Academy’s Director, Denise Jones, said, “Resolve Maritime Academy is very proud to have

received accreditation as an OSVDPA Training Provider. Working through the accreditation process gave us

good insight into the emphasis the OSVDPA scheme puts on safety, training, competency, and industry. We

found that OSVDPA’s principles align quite well with our own training philosophy which is to improve

competencies by applying leading-edge simulation, improving behavior, and communication by focusing on

training and teamwork and incorporating individual assessments to measure competencies enhancing safety and

enabling career development. We look forward to our new role training the offshore industry in dynamic

positioning training under the OSVDPA DPO Certification Scheme.”

For more information on OSVDPA Training Provider Accreditation, please click here.

Questions regarding the OSVDPA can be directed to the OSVDPA Administrator, Ben Berson, at

[email protected] or (504) 528-9414.

OSVDPA Membership Enrollment Now Open

By: Ben Berson

The OSVDPA is currently accepting applications for both Individual and Corporate Memberships for the 2018

calendar year. OSVDPA Members have access to OSVDPA news, updates, and materials before they are released

to the broader public, member-only opportunities to speak with the OSVDPA staff and its Board of Directors, and

the ability to be a Member Representative to the OSVDPA Technical Advisory Council (TAC).

The OSVDPA is also accepting nominations and votes from OSVDPA Members to elect Membership

Representatives to the TAC. As the Membership Representative to the TAC, this individual will be included in all

TAC correspondence and will also be invited to every TAC meeting as a full participant.

Additionally, Captain Robert “Bobby” Moyer’s op-ed, “Why I Became a Member of the OSVDPA”, was recently

published in the October issue of Marine News magazine. Captain Moyer, a working DPO who holds an

OSVDPA Class A DPO Certificate and is also an OSVDPA Qualified on Board Assessor (QOBA), is the current

Individual Membership Representative to the TAC and will be seeking re-election for the upcoming year. We

encourage all of you to take a few minutes to read Captain Moyer’s words on why he chose to become more

involved in an ever-changing industry.

Details on the fees associated with OSVDPA Membership ($65.00 USD for Individuals and $500.00 USD for

Corporations) as well as additional membership information and applications can be found on the OSVDPA’s

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website by clicking here or by reaching out directly to the OSVDPA’s Administrator, Ben Berson, at

[email protected] or (504) 528-9414.

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Industry Leader in Providing Real-TimeMarine and Logistics

Management Information

Advanced Logistics knows that the delivery and use of real-time in-formation is a competitive necessity, SAMM is a web-enabled and interactive electronic vessel management system optimized for the offshore oil and gas workboat industry.

SAMM™ Satellite Assisted Marine Management• Electronic Logs• Fuel & Lube Management• Voice & Email Communication• Engine Hours• Crew Management• Vessel Activities• Commodity Tracking

• Vessel Status Reports• Safety Reporting• Electronic Signatures• Customer Charge Code Application• GPS Mapping – Shore Side Application• Interactive Shore Application

• Subsistence Reports• Utilization Reports• Passenger Reports• Audit Reports• Search Features• SMS Documents & Forms Library

Preventer is an add-on module to SAMM that provides automated, company-specific preventive maintenance procedures, safety inspections and any other maintenance or inspection routines required on a vessel.

PREVENTER™ Preventive Maintenance• Calendar & Hourly Based Actions• Work Orders• Field Requisitions• Shipyard Work Orders & Field Requisitions• Assist with SMS Compliance• Assist with Coast Guard and ABS Inspection

2014 W. Pinhook Road Suite 310Lafayette LA, 70508337.232.4699337.232.4991 fax337.232.4273 (24/7 technical support)

www.al-llc.com

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OMSA Newsletter

Sponsorship Opportunities

$250 per Newsletter OR $2000 for the Year

(12 Newsletters) Includes your company logo & contact details at the end of the Newsletter in our

Thank You Sponsor Page.

$400 per Newsletter OR $3000 for the Year

(12 Newsletters) Includes your company logo & contact details on every page, in addition to a special

feature at the end of the Newsletter in our Thank You Sponsor Page.

$500 per Newsletter OR $4000 for the Year

(12 Newsletters) Includes your company logo & contact details on every page, in addition to a one page

feature in the Newsletter.

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