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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 I he no risk ropulsiori choice for high speed craft. Waterjets to match 100 to 3,000kW; over 20,000 installations; a worldwide distribution network and factory-based field service team Waterjets Are Our Business 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 Commander USCG Ret. He can be reached by contacting the Havnen Hamilton-Jet The Waterjet Specialists C.W.F HAMILTON & CO. LTD. P.O. BOX 709 CHRISTCHURCH NEW ZEALAND PHONE +64 3 348 4179 FAX +64 3 348 6969 E-MAIL:marketing@hamjet.co.nz Authorised Distributors Worldwide EUROPE Denmark Finland France Germany Italy Netherlands Norway Portugal Spain Sweden United Kingdom ASIA Hong Kong India Indonesia Japan Korea Malaysia Philippines Singapore Sri Lanka Thailand OCEANIA Australia Tahiti United Arab Emirates Oman Kuwait Egypt Israel South Africa AMERICAS British Colombia Nova Scotia Ontario Florida Washington Wisconsin California Massachusetts Maryland Louisiana Panama Brazil Colombia Argentina Chile Group of New Orleans, (800) 493- 3883 or (504) 394-8933. His orga- nization can assist you with ship- yard or other representation, pro- ject management, training, techni- cal procedure or policy manuals, as well as accident analysis and expert witness. Circle 273 on Reader Service Card COMING IN DECEMBER IN MR/EN... REAT VESSEL'S OF 1997
