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Here are some answers to our most heard questions:

Will There Be Additional Attendances by the USCG?

Yes, from the proposed rules, USCG attendance on board DP vessels during trials may be required. 30 days notice will need to be given to the USCG.
However, We believe that the experience of USCG could be questioned, as the requirement and knowledge needed is not something that the USCG currently has.

What is the Impact in Terms of Added Visits / Inspections That Operators Will be Facing?

Currently, DP trials are sometimes being requested by charters (Oil majors), etc. to comply with their own quality and safety requirements.
The USCG rule change intends to augment and replace individual client’s requirements, to add consistency and uniformity to the assurance process of the DP systems.

We do not foresee additional inspections of the vessels due to this rule if previously the owner / operator was carrying out DP trials annually.

What is a FMEA (Failure Modes and Effects Analysis)?

This can also be known as a FMECA. The “C” adds criticality to the study. Throughout this website FMEA is used to mean both FMEA and FMECA.

The FMEA is a study of the vessel systems relating to DP as designed for the vessel. This includes thrusters, power distribution, DP system, reference sensors and so on. This is normally carried out whilst the vessel is in the process of being built and is a mostly desktop study, with some visits to the vessel, to check that the design will accomplish the worst case failure design intent (WCFDI) from the architects. (for example DP class, identify ways to increase redundancy and fault ride-through, identify mistakes on the drawings etc.) This is sent to class for conditional approval prior to any tests or delivery of the vessel.

This initial study should be updated on conclusion of the FMEA Proving Trials as below.

What are the FMEA Proving Trials?

The FMEA proving trials (sometimes referred to as FMEA Trials Program) are created as part of the initial FMEA study. This is to prove that the systems are functioning as per the FMEA study. This checks that the shipyard didn’t cross any wires, mistakenly put all the pumps on one switchboard and failures are as expected per the drawings and specifications from the builder / vendors / owner. This should also be sent to class for approval prior to the tests being carried out.

The FMEA proving trials, once completed, are then used to update the FMEA to an “as built” document and submitted to class for final approval. This is a reference document for the crew on board for any failures they experience to know what the consequences are, can help with trouble shooting and so on. Best practice is for this document to be a “living” document that is updated as changes are carried out on board, normally by way of addendums or similar until the fifth anniversary when they can be integrated into the document fully for class approval and new FMEA Proving trials carried out.

What are the Annual DP Trials?

The Annual DP Trials are a set of tests to prove normal operations and the maintenance of the system over the last year or so, the annual trials should be carried out +/- 3 months from the date the FMEA proving trials were completed. (Industry best practice, IMCA guidelines) and will not include all tests from the FMEA proving trials, unless on the fifth anniversary when no changes have been made to the systems. (IMCA and MTS guidelines available for this too) Depending on client / class / operator requirements the document can be very robust or very poor.

We Already Have an FMEA and do DP Trials etc. Do we Need to Repeat Them to be Issued a DPVAD?

The USCG is not yet clear on this point. It is anticipated that the vessels current documentation will suffice, provided it is up to date and the operator meets all of the requirements.
The DPSAO will need to carry out a document review prior to issuing a DPVAD for the vessel. It would be up to the owner / operator to select their preferred DPSAO.
Most companies in the GoM already comply with the majority of these requirements and will be minimally affected.