Page 31: of Maritime Reporter Magazine (October 1997)

WORKBOAT ANNUAL (Continued from page 26) •Prolongs the life; or •Otherwise so changes the vessel so that it is essentially new.

Rulings of substantial alteration or major conversion could cause an existing OSV to be viewed by the

USCG as requiring compliance with 46 CFR Subchapter L, the new supply boat rules. These rules were once unimportant to the government and took 15 years to produce. Now it appears that they are so important they must be force fed to the offshore industry.

Major conversions are a particu- larly big deal for liftboats, which are considered by the USCG to be

OSVs.

Recently, the USCG has been indicating that modifications which have been routinely accom- plished for the past five or more years would now be major conver- sions and require the application of Subchapter L rather than the standards under which they were originally inspected.

The USCG seems to be ignoring the precedents set since passage of the statutory amendment in 1988 until the end of 1996.

Many vessels, but particularly liftboats, were modified but not considered by the USCG to have undergone substantial alterations and/or major conversions until 1997. If they had, then current standards would have been applied in toto, and they were not.

Most of these precedents were pas- sive, i.e. the question was not for- mally routed through USCG

Headquarters for a determination.

The USCG was nonetheless deeply involved with each conversion of an inspected vessel. All conver- sions were done with approval of individual OCMIs and the USCG's

Marine Safety Center.

Operators of other vessels should be aware that the USCG will apply these rulings to them as well. As time passes, this will become more significant. It means that with each new round of regulatory changes will come a probable round of interpretations forcing owners to modify vessels to the new standards.

Major conversions and substan- tial alterations are hopelessly intertwined. The former being a matter of domestic law and the lat- ter a matter of international agreement.

October, 1997

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It looks as though both will con- tinue to evolve but in the process may cause the marine industry significant and long term harm.

Charley Havnen, is a

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