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MCA – HS-OSC Code – a well-timed step forward for the offshore wind farm industry

On 9th May 2017, the Maritime & Coastguard Agency published the result of its consultation on a new Code for High Speed Offshore Service Craft (HS-OSC) with a revised Code. This Code applies to vessels under 500GT carrying less than 60 persons and is intended to provide equivalency to the International Convention for the Safety of Life at Sea 1974 (SOLAS) requirements in terms of personnel safety, ship construction, equipment and operation for, primarily, vessels operating as crew transfer and offshore support vessels in the UK offshore wind farm industry.

Photo courtesy of 4C Offshore and Dalby Offshore

Typically, such vessels have been operating up to now in accordance with UK Workboat Code in case they are under 24 metres in load line length. If over that length then the position has been more complicated with either compliance with the relevant provisions of SOLAS Chapter V or with the High Speed Craft (HSC) Code required – in either case more arduous than the UK Workboat Code requirements.

However, the baseline position has been that UK regulations and SOLAS allow a “cargo ship” to carry up to 12 passengers in addition to the crew. The HS-OSC Code changes the fundamentals by allowing a category of persons onboard described as “Industrial Personnel” of which the vessel may carry up to 60 (or 36 if under 24 metres in load line length).

The HS-OSC Code sits under the HSC Code so it applies to offshore service craft that are also high speed craft. The key to the new Code are the requirements for coming under the definition of Industrial Personnel – they are that the Master ensures that such persons:

  • are engaged and on board for transport or accommodation for the purposes of offshore industrial activities;

  • are able bodied and meet appropriate medical standards

  • have received basic safety training, according to relevant industry standards

  • have an understanding of the layout of the ship and the handling of the ship's safety equipment before departure from port (e.g. through a safety briefing); and

  • are equipped with appropriate personal safety equipment suitable for the risks to safety such personnel are likely to experience on the forthcoming voyage (e.g. immersion suits).

It should be noted that the ability to carry 12 passengers remains – so to reach the maximum number of persons for a vessel over 24 metres in load line length, 12 could be passengers and 48 Industrial Personnel.

One important wrinkle is that Industrial Personnel are crew for the purposes of the Maritime Labour Convention so standards of accommodation for crew as set out therein are applicable to them (with the exception of enclosed sleeping berths) but not it would seem to those categorised as “passengers”, although how one differentiates the accommodation on a small vessel is questionable.

It is too early to say how this new Code will affect the windfarm industry in the UK though the first windcats are currently being registered on the basis of the Code. With a new raft of offshore windfarm construction sites in more distant waters in the offing, this Code may make it easier and more profitable to operate the kind of large crew transfer/support vessels that such sites will need – so perhaps it is a well-timed development.

The content of this article is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content herein.

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