IMO MODU Code update nears completion, formal adoption; IADC set to provide companion document in early 2010

After a nearly five-year effort, the International Maritime Organization (IMO) is expected to adopt an updated version of the IMO MODU Code next month. Almost every section of the Code for the Design and Construction of Mobile Offshore Drilling Units, or MODU Code, has been affected.

Major changes touch on areas such as fire safety, electrical equipment in hazardous areas, helidecks, means of access, single-compartment flooding and jacking system standards for jackups, and training. The new Code is expected to apply to units whose construction begins on or after 1 January 2012.

IADC, represented by vice president – offshore technical and regulatory affairs Alan Spackman, has been involved since the beginning. In March 2005, the association began working with the Liberian, Marshall Islands and Vanuatu registries to develop amendments to bring the MODU Code in line with current needs and to improve consistency with the Safety of Life at Sea and Load Line Conventions.

The parties brought together a working group of drilling contractor representatives, classification societies, flag State and other government agencies and oil companies.

During this process, members of the working group were asked to identify “problem areas” and concerns with the previous editions of the MODU Code. IMO Assembly resolutions and MSC circulars and resolutions were reviewed, as were IACS recommendations, unified requirements and unified interpretations relevant to MODUs in order to identify provisions that should be incorporated into the revised Code.

A year later, the groups jointly submitted an extensive proposal for amendments to the Code to the IMO Ship Design and Equipment Subcommittee (DE) for consideration. The Subcommittee subsequently formed a correspondence group, a drafting group and another working group to consider and refine various proposals and documents in order to finalize a draft Code for adoption by the IMO Assembly in November/December 2009.

The 2009 MODU Code includes hundreds of changes from the 1989 Code. Those interested in developing a detailed understanding of the changes are encouraged to purchase the “Companion to the Code for the Construction and Equipment of Mobile Offshore Drilling Units,” which will provide a comparison between the two versions. IADC is currently preparing this document, which should be available for purchase in early 2010. A free copy of the companion document will be provided to the sustaining member of each IADC offshore drilling contractor member company.

Below are highlights of some of the major changes in the Code:

• Expanded guidance on casualty investigations, with Coastal States encouraged to submit findings.
• Means of access for inspection and maintenance.
• Minimization of hazardous substances in design and construction (e.g., asbestos prohibited) and facilitation of identification, removal and recycling of hazardous materials at end of life.
• Residual stability after single compartment flooding for self-elevating drilling units (SEDUs).
• Effective drainage and removal of sediments from ballast and preload tanks and associated piping systems – in accordance with the Ballast Water Management Convention.
• Standards for machinery, control systems and alarms for elevating systems on SEDUs.
• IMO’s personnel training standards for mobile offshore units are incorporated by reference.
• Maintenance of life-saving appliances harmonized with SOLAS requirements.
• Added standards for lifting and hoisting appliances.
• New guidance on number and distribution of portable fire extinguishers.
• Added qualification standards for recognized organizations, including relevant rules and experience.
• Bow height relief for SEDUs under the 1988 Load Line Protocol.
• Update and incorporation of IEC standards for electrical equipment in hazardous areas.
• Significantly modified standards for helideck design to conform to revised ICAO standards, as well as anticipated amendments to ICAO standards.
• Two-tier system for helideck design maintained.
• Revised helideck firefighting to conform to CAP 437.
• Helideck visual aids IAW ICAO and CAP 437.

In 2010, IADC will continue to work with flag States and recognized organizations to interpret non-mandatory language within the new MODU Code.

National regulations will also have to be updated to reflect the new Code. For example, the US Coast Guard regulations currently reference the 1979 Code.

A new work program item for the DE Subcommittee to align the requirements of SOLAS and the MODU Code with the most recent amendments to the ICAO Convention will be addressed as well, although for MODUs, it is not expected that any further changes will be significant.

Documentation related to the revision of the MODU Code can be found on IADC’s website under the Offshore Committee at www.iadc.org.