Manning, licensing and training issues are extremely important in the deepwater regulatory area of the Gulf of Mexico.  We have been intimately involved with the development of the current licensing standards for SPARs and Tension Leg Platforms (TLPs).  These issues are not governed by law or regulation, but by USCG policy.  Involvement at the early stages of any deepwater project needs to have expert advice concerning such aspects of the process as compliance strategies and tactics in dealing with maritime regulators.

Licensing policies for FPSOs have not yet been developed by the Coast Guard.  In all probability, these manning policies will be developed within the Gulf of Mexico (8^th Coast Guard District), rather than by CG HQ in Washington DC.

The development and implementation of methodologies to comply with USCG regulations is critical to any deepwater project.  Some of the issues developed by the Havnen Group and nurtured through the approval process include:

	Manning levels
	Training matrices for marine personnel
	Development of Safety Drawings
	Development of Coast Guard Required Operations Manuals
	Development of Emergency Evacuation Plans
	Development of Oil Spill Response Plans
	Development of Shipboard Oil Pollution Emergency Plans
	Liaison with the USCG on a host of issues, technical and non-technical.
	Representation before the USCG can be critical to a project.  It is important that the USCG understand they are dealing with serious people, who take care to protect their personnel and deal with all maritime concerns appropriately.

Understanding US federal maritime law and regulations is critical to the efficient development of a project.  The Havnen Group excels in these areas of expertise.

Overcoming Coast Guard non-acceptance or non-approval of specific systems and equipment is a difficult process.  There is a formal appeal process, however we encourage customers to seek much more informal methods of mitigation wherever possible.  The Coast Guard regulatory maritime heritage literally goes back to the 1840’s, and should be understood if one expect to succeed in dealings with the USCG. 

The Havnen Group has been involved in the development of tension leg platform and SPAR development projects in the Gulf of Mexico over the past seven years.

	BP Amoco
	Oryx
	Kerr-McGee
	Exxon
	Vastar