The Director of Commercial Regulation and Standards announced in the Federal Register the publication of the Office of Operating and Environmental Standards (CG-OES) Policy Letter 01-22, Determination of Whether a Floating Outer Continental Shelf Facility (FOF) is a Vessel, and the Office of Merchant Mariner Credentialing (CG-MMC) Policy Letter 01-22, Merchant Mariner Credential Endorsements for Service on Floating Outer Continental Shelf (OCS) Facilities. The policies announced in the policy letters were effective as of February 4, 2022
CG-OES Policy Letter 01-22 provides guidance for Officers In Charge, Marine Inspection (OCMIs) in determining if an FOF is a vessel or a non-vessel due to a Supreme Court ruling which altered the evaluation of characteristics in determining what is a vessel. As a result of these changes non-vessel FOFs will no longer receive a traditional vessel Certificate of Inspection (CG Form 841). Instead, non-vessel FOFs will receive an FOF COI that will contain the same information as the traditional COI. Additionally, CG-MMC Policy Letter 01-22 details the changes made to credentialing since personnel serving on non-vessel FOFs will no longer be required to hold Merchant Mariner Credentials. In association with these changes, the Coast Guard is canceling USCG District 8 Policy Letter 08-2001, Licensing Requirements for Personnel on Non-Self Propelled Floating OCS Facilities.
CG-MMC Policy Letter 01-22 is available on the Office of Merchant Marine Credentialing Policy Website, and CG-OES Policy Letter 01-22 is available on the Office of Operating and Environmental Standards Website. Both are also available by searching docket number USCG-2020-0049 using the Federal eRulemaking Portal at https://www.regulations.gov.
Mariners and other interested parties should contact the Office of Operating and Environmental Standards (CG-OES) at (202) 372-1410 or the Office of Merchant Mariner Credentialing (CG-MMC-2) at (202) 372-1206.