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PM28 4251-RA-00379913 D
FT CATCHER FPSO FEED
REGULATORY COMPLIANCE PLAN
TABLE OF CONTENTS
1 SCOPE 4
2 ORGANISATION 4
3 RESPONSIBILITIES 4
3.1 Content of the Plan ......................................................................................... 4
3.2 Implementation ................................................................................................ 4
4 HOLD LIST 4
5 REFERENCE DOCUMENTS 5
5.1 Premier Oil Documents ................................................................................... 5
5.1.1 Technical Documents ......................................................................... 5
5.1.2 Bid Bulletins ........................................................................................ 5
5.2 BWO Documents ............................................................................................ 6
5.3 Rules, Regulations, Codes and Standards ..................................................... 6
7 APPLICABLE AUTHORITIES 9
7.1 General............................................................................................................ 9
7.1.1 Coastal State – United Kingdom Continental Shelf ........................... 9
7.1.2 Flag State – Bermuda Ship Registry .................................................. 9
7.1.3 Classification Society – Det Norske Veritas ..................................... 10
7.1.4 Independent Verifying Body ............................................................. 10
7.2 Overall Approval Scheme ............................................................................. 10
11 COMMUNICATION 20
11.1 Communication with Regulatory Agencies/Bodies ....................................... 20
11.2 Communication with Flag State Authorities .................................................. 20
11.3 Communication with Classification Society................................................... 20
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1 Purpose
BW Offshore (BWO) has entered a contract with Premier Oil to carry out Front End Engineering
and Design (FEED) of an FPSO for the Ft Catcher FPSO FEED Project.
The FPSO shall be designed for 20 years of uninterrupted operation (operation life) without need
for dry-docking. The FPSO will be deployed on the Catcher Area fields, located offshore
approximately 200 km east of Aberdeen on the UK sector of the North Sea.
This document presents the approach that will be utilised by BWO to ensure that the FPSO is
designed, constructed and installed in compliance with the relevant regulatory requirements for
this type of unit operating on the UK Continental Self (UKCS).
Objective of the plan is to ensure a well-structured approach for classification and regulatory
compliance of the FPSO intended for UKCS, with minimal uncertainty on compliance issues
during all phases of the project execution.
The objective is also to demonstrate how BWO shall ensure that the Local Governing Authority’s,
Flag State and Class’ in-service inspection can be performed problem free and to the involved
Authorities satisfaction.
This Regulatory Compliance Plan (RCP) is developed in line with the requirements of the Client’s
Basis of Design /1/, Functional Specification /2/ and BWO`s Regulatory Compliance Procedure
/49/.
2 Organisation
This plan applies to BWO’s Catcher project team.
The document shall be enclosed as a Company Provided Document, as part of the Technical
Requisition sent to Suppliers, which manage, design, engineer, construct and deliver assets to
BWO, in order to ensure regulatory compliance.
For "minor" item PO's the RCP will not be included. Any relevant requirements shall be included
in the PO text.
3 Responsibilities
3.1 Content of the Plan
Project Manager in the Catcher project is responsible for the content and the continuous updating
of this plan. The document shall not be altered or omitted without this position’s consent.
3.2 Implementation
All leads and managers in the Catcher project are responsible for the implementation of this plan.
Typical users are BWO engineering team and sub-suppliers; yard, construction, commissioning
and operations personnel.
Regulatory Compliance lead in the project will facilitate and administrate this process.
4 HOLD List
[HOLD 1] DNV GL has prepared a request to Panama via their flag liaison to get
these issues clarified/confirmed
[HOLD 2] Class organisation, as full Class Contract for New Build is not intended to
be signed during FEED
[HOLD 3] Informative References – International Standards – list to be reviewed in
detailed design
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5 Reference Documents
5.1 Premier Oil Documents
5.1.1 Technical Documents
Ref. No. Title Doc. No
/1/ Catcher Development FPSO Basis of Design AB-CT-PD-SP-0034
/2/ Catcher Development Functional Specification AB-CT-PD-SP-0032
/29/ FREE ISSUE EQUIPMENT ( FOR SUBSEA CONTROL) WEIGHT 031 4251-KI-00381604
CAPACITY
/30/ WATER DEPTH AT TURRET CENTRE 032 4251-KI-00381605
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It is BWO’s intention to engage regulatory compliance advisors in the detailed design phase.
Their tasks will i.e. be to:
• Educate engineers in regulations
• Advise engineers on compliance issues
• Review specifications
• Give advice to Suppliers
• Participate in inspections on selected equipment (i.e. metering), as deemed necessary
• Play an active role in application to authorities.
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7 Applicable Authorities
7.1 General
The FPSO will be deployed on the Catcher Area fields, in the UK Sector of the North Sea. Hence,
the FPSO will have to comply with national laws and regulations for offshore installations
operating on the UKCS.
As this FPSO in addition will be self-propelled with the ability to move freely in international
waters, the FPSO will be Flagged (Panama) and classed by a Recognized Classification Society,
DNV GL, hence chosen Flag State and Classification Society’s Rules and Regulations apply.
The following Local Governing Authorities (LGAs) are involved in the approval of the design,
construction and operation of the FPSO.
7.1.1 Coastal State – United Kingdom Continental Shelf
UK Health and Safety Executive
Following the merger of the Health and Safety Committee and the Health and Safety Executive in
2008, the new unitary body Health and Safety Executive were committed to maintaining the
current legal position whereby only duly authorised officials make individual enforcement
decisions.
The Health and Safety Executive mandate includes proposing new legislation to be considered by
the Parliament, and being responsible for the enforcement of the Health and Safety Act and
Regulations. In addition they approve and issue Codes of Practice (ACOPs) and ALARP
Guidelines.
UK Department of Energy & Climate Change
The Department of Energy & Climate Change (DECC) manage the UK energy legacy
responsibility.
UK Maritime and Coastguard Agency
The Maritime and Coastguard Agency (MCA) implements the government's maritime safety policy
in the UK, and works to prevent the loss of life on the coast and at sea.
The MCA provide a 24-hour maritime search and rescue service around the UK coast and in the
international search and rescue region through HM Coastguard and inspect and survey ships to
ensure that they are meeting UK and international safety rules. They also provide certification to
seafarers, register vessels and respond to pollution from shipping and offshore installations.
UK Civil Aviation Authority
The UK Civil Aviation Authority (CAA) enforces regulations concerning the safety of aircraft in
flight, and for the passengers and crew whilst the aircraft is moving under its own power. The
Helideck Certification Agency (HCA) approves the helideck design for operation on behalf of
CAA.
7.1.2 Flag State – Panama Maritime Authority
The Panama Registry is committed to being a high quality shipping register and maritime
authority which main mandate is ensuring that Panama registered ships meet all international
requirements.
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8.1 Precedence
Rules, regulations, codes and standards shall be applied in the following order of precedence.
1) Statutory requirements as defined by the relevant Coastal State and/or other Local Governing
Authorities (LGA)
2) Flag State requirements
3) Classification Society Rules
4) Project specified codes and standards
a) Premier Oil Technical Documents
i) Bid Bulletins
b) BWO project specific requirement
5) BWO’s codes and working standards
In case of conflict; the more onerous requirement with respect to safety shall apply. Where equal
but conflicting requirements arise between the applicable regulations, codes and standards and
the referenced documents, such regulatory conflicts should be brought to the attention of the
Engineering Manager, and a Clarification/DPR shall be issued to Premier Oil in writing.
8.2 Coastal State Requirements – UK Continental Shelf
The governing legislation for FPSO’s will be those of the Local Governing Authority/Coastal State
in the area of operations.
All states have full sovereignty with regard to regulating activities on their continental shelves and
are generally not regulated by international conventions. Matters under UK Coastal State
jurisdiction are unaffected by the Flag of the FPSO.
Figure 8-1: UKCS Scheme below illustrates the hierarchy of the UKCS legislation hierarchy.
UK Continental Shelf -
HSE DECC MCA
Regulatory Bodies
Merch.
Regulations SCR DCR PFEER MAR PSR COSHH
Shipping
The UK Acts and Statutory Instruments are published on the web and are available free of charge
to anyone. A list of UK Coastal State Requirements relevant to the design, construction and
operation of the FPSO is defined in the project.
The Approved Codes of Practice (ACOPs) contain advice on how to achieve the legislative
requirements, and practical advice on compliance. These ACOPs have a special legal status.
UK Health and Safety Executive have produced a suite of operational guidance documents
(ALARP guidelines) which sets out principles and guidelines required by Duty Holders, ref. 8.2.2.
Principles and guidelines are established in order to assist the UK Health and Safety Executive in
its judgements that duty-holders have reduced risk as low as reasonably practicable.
The “ALARP Suite of Guidelines” consists of 6 documents:
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• Assessing compliance with the law in individual cases and the use of good practice
• Policy and guidance on reducing risks as low as reasonably practicable in Design
• Principles and guidelines to assist HSE in its judgements that duty-holders have reduced
risk as low as reasonably practicable
• HSE principles for Cost Benefit Analysis (CBA) in support of ALARP decisions
• Cost Benefit Analysis (CBA) Checklist
• ALARP "at a glance"
The UK Health and Safety Executive and UK Offshore Guidance material describes good
practice. Following these guidelines is not compulsory, but doing so is normally enough to
demonstrate compliance with the UKCS legislation.
It is therefore essential that the disciplines review the UK Health and Safety Executive ACOPs
and Guidelines material, as these may be used to document best practice and ALARP process.
UKCS Guidance material, such as Safety Notes, Offshore Information Sheets, Operations Notes,
Research Reports, and Safety Alerts etc. should be considered in the design and construction as
well as the operation phase. A list of relevant Guidance material can be found in Appendix B.
8.2.1 Relevant UK Offshore legislation
UK legislation applicable to offshore installations in operation on the UKCS can be found in below
Figure 8-2: UKCS legislations applicable to offshore installations, Table 8-1: UKCS Offshore
Legislations and in Appendix A.
Health and
Safety at Health and
Work etc. Act Safety at Offshore Installations
1974 Work, etc. Act Offshore (Prevention of Fire
(Application 1974 (HSWA) Safety and Explosions, and
Offshore Emergency Response)
outside Great Act.1992
Installations Reg. 1995 (PFEER)
(Safety Case) Britain)
Regulations 2005
(OSCR) Reporting of Injuries,
Dangerous
Substances and Diseases and
Explosive Dangerous
Atmospheres Occurrences Reg. 1995
Reg. 2002 (RIDDOR)
(DSEAR)
Offshore Installations
Which and Pipeline Works
Control of
Substances Regulations (Management and
Hazardous to Apply to Administration) Reg.
Health Reg. Offshore 1995 (MAR)
2002 (COSHH) Installations?
Offshore
Equipment and Installation and
Protective Systems Wells (Design and
Intended for use in Construction,
Potentially Explosive etc.) Reg. 1996
Atmospheres Reg. 2001 (DCR)
(ATEX 95) The Pipeline
Safety
Pressure Equipment Regulations 1996
Regulations 1999 (PED) Provisions and (PSR)
The Lifting use of Work
Management of Operations Equipment
Health and Safety and Lifting Regulations 1998
at Work Reg. Equipment (PUWER)
1999 (MHSWR) Regulations
1998 (LOLER)
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The UK regulations most relevant for the design in FEED phase include, but are not limited to, the
following:
Ref. No. Title Year/SI
/57/ The Control of Noise at Work Regulations (NAWR) 2005/1643
/58/ The Control of Substances Hazardous to Health Regulations 2002/2677
(COSHH) with amendments 2004/3386 &
2007/1596
/59/ The Greenhouse Gas Emissions Trading Scheme Regulation, 2012/2788
as Amended
/60/ The Lifting Operations and Lifting Equipment Regulations 1998/2307
(LOLER)
/61/ The Management of Health and Safety at Work Regulations, 1999/3242
with amendments 2006/438
/62/ The Manual Handling Operations Regulation 1992/2793
/63/ The Offshore Combustion Installations (Prevention and Control 2001/1091
of Pollution) Regulations with amendments 2007/938
/64/ The Offshore Installations (Prevention of Fire and Explosion, and 1995/743
Emergency Response) Regulations (PFEER)
/65/ The Offshore Installations (Safety Case) Regulations (SCR) 2005/3117
/66/ The Offshore Installations and Pipeline Works (Management and 1995/378
Administration) Regulations (MAR)
/67/ The Offshore Installations and Wells (Design and Construction, 1996/913
etc.) Regulations (DCR)
/68/ The Offshore Petroleum Activities (Oil Pollution Prevention and 2005/2055
Control) Regulation with amendments 2011/983
/69/ The Pipeline Safety Regulations (PSR) with amendments 1996/825
2003/2563
/70/ The Provisions and Use of Work Equipment Regulations 1998/2306
(PUWER)
/71/ The Supply of Machinery (Safety) Regulations with amendments 2008/1597
2011/2157
/72/ Offshore Helicopter Landing Areas – Guidance Standards, Civil 2012/CAP 437
Aviation Authority, incorporating Amendment 01/2013
Table 8-1: UKCS Offshore Legislations
In addition to the above, some Merchant Shipping Regulations relevant for non-UK registered
Ships/FPSOs operating in UK jurisdictional waters will apply.
EU Directives
Installation of the FPSO in the UK sector implies that the FPSO must be in accordance with the
EU directives enforced by UK regulations. This will mean that CE-marking applies, and that
relevant systems and equipment (of non-marine nature) must comply with i.e. PED, EMC, MD,
LVD, R&TTE and ATEX directives as defined in the EU Directives Applicable to FPSO’s on
UKCS document /51/ .
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The FPSO shall be designed in accordance with all applicable national laws, regulations,
resolutions and guidance and international maritime Conventions, Regulations, Codes and Acts
but not limited to, i.e. SOLAS, MARPOL, ILLC and MODU Code as found applicable.
A list of relevant Flag State Rules and Regulations relevant to the design of the FPSO can be
found in Appendix A.
8.3.1 International Conventions and Statutory Certificates
The international maritime conventions made at the International Maritime Organization and at
the International Labour Organization (ILO) are formally extended to Panama Maritime Authority’s
Merchant Marine Circulars and PMA Resolutions once they have been ratified by the Republic of
Panama.
It is BWO’s understanding that Panama want the MODU Code to be applied (as applicable) also
for non-drilling offshore units, including FPSOs, hence from BWO’s understanding MODU stated
in PMA Circulars will also apply to FPSOs (as applicable) [HOLD 1].
Conventions ratified by the Republic of Panama, and the associated statutory certificates the
FPSO shall carry, are found in the below table:
Engine International Air Pollution MARPOL Protocol 1997 Annex VI, MARPOL 73/78,
Prevention Certificate (EIAPP) Reg. 13 Consolidated
(This Annex is yet to be formally extended to
Edition 2011/2012
Bermuda by the UK but is given full effect on
Bermuda ships)
Load Line Certificate (ILLC) Load Line 1966 / protocol of 1988 as 66/88,
amended Consolidated
Edition 2008
Tonnage Certificate (1969) Tonnage 1969 1969
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The FPSO will be designed to Hydrocarbon Production Plant (PROD) notation, and the notation
is used for certification of the topside only. The notation will be removed upon renewal of Class.
1
User defined project-specific Design Fatigue Factors (DFFs) to be used
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DNV Offshore Service Specification for Classification of Floating Production, Storage and
Loading Units (DNV-OSS-102) refer to a number of various normative DNV GL standards,
whereof the following are of main importance for the safe design and operation of the vessel:
Classification shall comply with the latest issue of the rules and amendments published by the
Classification Society as of the EFFECTIVE DATE.
8.5 Interface between Class and Various Sites
The DNV GL acts as an independent 3rd party throughout the design, engineering and building of
the FPSO, fabrication of the Topsides and Mooring Systems, offshore installation and
commissioning phases. DNV GL will set up its organisation accordingly, headed by a dedicated
Project Manager (PM).
During the design and engineering phase, DNV GL will be involved with a Plan Approval team,
headed by a Project Manager Approval (PMA), who will be responsible for the review a set of pre-
defined drawings, calculations etc. as required by DNV GL. BWO will by this obtain required
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design approval, in order to fulfil Class and Statutory requirements. Class comments will be
reviewed and acted upon as applicable.
During the building of the FPSO at the selected yard, DNV GL will be represented by a site team,
headed by a Project Manager Field (PMF), responsible for site surveys, mechanical completion
and commissioning activities. DNV GL representatives will participate in the amount deemed
necessary by Class. Site punch list items will be reviewed and acted upon as applicable.
BWO shall engage a Certification of Materials and Components (CMC) coordinator from the
selected Classification Society, who will act as a Single Point of Contact towards all BWO sub-
contractors delivering materials and components to the Catcher project. The CMC-coordinator will
have the overview of Class and Statutory requirements relevant for the project.
As part of BWO sub-contractors deliverable, materials and components are to be delivered with
accompanying relevant certification as required. It is the responsibility of each sub-contractor to
contact the selected Classification Societies local office in order to obtain such certificates. DNV
GL will review documents, witness FAT’s etc. as deemed necessary.
8.6 International Standards
In addition to Coastal State, Flag State and Classification Requirements, international standards
apply as referenced in the Premier Oil project specific Basis of Design /1/ and Functional
Specification /2/, and BWO Philosophies and Specifications. International Standards referenced
in the Premier Oil documents are enclosed in Appendix A.
Where government legislation, Flag State requirements, Classification Society Rules, the Premier
Oil documents, and the BWO’s Philosophies, Specifications, Procedures and Working Standards
do not explicitly prescribe codes and standards, recognized industry codes and standards shall
be utilized.
Unless specifically noted otherwise, codes and standards referenced in the Premier Oil Technical
Documents shall be the latest edition at the time of the EFFECTIVE DATE.
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11 Communication
The communication process between BWO, Premier Oil, the Classification Society, including Flag
State, and other Regulatory Agencies to facilitate the management of regulatory compliance,
certification and classification deliverables, shall follow the communication procedures set valid
for the project.
Reference is made to correspondence procedures.
The communication procedure shall indicate how notification protocol will be established and how
documentation will be forwarded to/from Classification / Certification and Regulatory Agencies
to/from BWO or Sub-Contractor for approval, review etc. and procedures for timely flow of
information to Premier Oil.
11.1 Communication with Regulatory Agencies/Bodies
The Field Licence Holder (Premier Oil) is responsible for appointing the Duty Holder and will
appoint the FPSO vessel owner (BWO) as Duty Holder for the installation, and as such BWO
would have to interact with the UK Health and Safety Executive.
For areas of communication with Regulatory Agencies for which BWO has direct responsibility,
formal lines of communication shall be arranged. This includes communication with the Health
and Safety Executive as Duty Holder, with regard to Design Notification and Safety Case.
Attendance of Premier Oil representatives at any related meetings will be at the discretion of
Premier Oil. BWO’s representative shall attend meetings with Regulatory Agencies as required by
Premier Oil.
11.2 Communication with Flag State Authorities
Where the chosen Classification Society is delegated authority to act on behalf of chosen Flag
State, all communication with Flag State Authorities shall be routed through the Classification
Society’s Flag State Liaison Office.
All formal communication shall be signed by BWO, as the Owner of the FPSO, prior to submitting
it to the Classification Society for their review and support.
11.3 Communication with Classification Society
BWO shall permit, support and authorize free and open communication between the appointed
FPSO Classification and Certification Societies and all parties as needed.
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Title Year/SI
Convention) Regulations, as amended by SI 2001/1639 2001/1639
The Merchant Shipping (Prevention of Pollution by Garbage) Regulation 1998/1377
The Offshore Chemicals Regulations, as amended by SI 2011/982 2002/1355
2011/982
The Offshore Combustion Installations (Prevention and Control of Pollution) 2001/1091
Regulations with amendments 2007/938
The Offshore Installations (Emergency Pollution Control) Regulations 2002/1861
The Offshore Installations (Inspectors and Casualties) Regulations 1973/1842
The Offshore Installations (Logbooks and Registration of Death) Regulations 1972/1542
The Offshore Installations (Operational Safety, Health and Welfare) Regulations, as 1976/1019
amended
The Offshore Installations (Prevention of Fire and Explosion, and Emergency 1995/743
Response) Regulations (PFEER)
The Offshore Installations (Safety Case) Regulations (SCR) 2005/3117
The Offshore Installations (Safety Representatives and Safety Committees) 1989/971
Regulations
The Offshore Installations and Pipeline Works (First-Aid) Regulations 1989/1671
The Offshore Installations and Pipeline Works (Management and Administration) 1995/378
Regulations (MAR)
The Offshore Installations and Wells (Design and Construction, etc.) Regulations 1996/913
(DCR)
The Offshore Petroleum Activities (Oil Pollution Prevention and Control) Regulation 2005/2055
with amendments 2011/983
The Offshore Petroleum Production and Pipelines (Assessments of Environmental 1999/360
Effects) Regulations as amended by SI 2007/933 2007/933
The Personal Protective Equipment Regulations 2002/1144
Petroleum Licensing (Exploration and Production) (Seaward and Landward Areas) 2004/352
Regulations, as amended by SI 2006/784 2006/784
Petroleum Licensing (Production) (Seaward Areas) Regulations 2008/225
The Pipeline Safety Regulations (PSR) with amendments 1996/825
2003/2563
The Pollution Prevention and Control (Scotland) Regulations 2012/360
The Pressure Equipment Regulations, as amended by SI 2002/1267 1999/2001
2002/1267
The Provisions and Use of Work Equipment Regulations 1998/2306
The REACH Enforcement Regulation 2008/2852
The Special Waste Regulations, as amended by SI 2001/3148 1996/972
2001/3148
The Supply of Machinery (Safety) Regulations with amendments 2008/1597
2011/2157
The Work at Height Regulations, as amended by SI 2007/114 2005/735
2007/114
Offshore Helicopter Landing Areas – Guidance Standards, Civil Aviation Authority, 2012/CAP 437
as amended by 01/2013
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Title Year/SI
UK Air Quality Standards Regulations 2010/1001
Electronic versions of the above Acts and Regulations are available on the web, free of charge at
the following address:
http://www.legislation.gov.uk/
EU Directives
Electronic versions are available on the web, free of charge at the following address:
http://eur-lex.europa.eu/en/index.htm
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SOLAS 74/88 as amended Safety of Life at Sea Convention 1974 Consolidated 2012
and the 1988 Protocol as amended Edition
COLREG 1972 International Regulations for Preventing 1972
Collisions at Sea
MARPOL 73/78 Annex I International Convention for the Consolidated 2011/2012
Prevention of Pollution from Ships Edition
MARPOL 73/78 Annex IV International Convention for the Consolidated 2011/2012
Prevention of Pollution from Ships Edition
MODU Code Code for the Construction and Equipment 2010 Edition 2009
of Mobile Offshore Drilling Units
Load Line 1966 / protocol of International Convention of Load Lines Consolidated 2008
1988 as amended Edition
Tonnage 1969 International Convention of Tonnage 1969
Measurements
STCW 1978 as amended Standard of Training, Certification and 1978 as
2010 Watchkeeping amended
2010
AFS Convention Anti-fouling System Convention 2001
MLC 2006 Maritime Labour Convention 2006
Electronic versions of the Codes and Conventions are made available to the BWO PTM through
our Techstreet subscription, at the following address:
http://subscriptions.techstreet.com/
At the moment Panama has limited rules applicable to FPSOs other than the requirements of
IMO, ILO and Class.
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Some Panama Maritime Authority’s Merchant Marine Circulars and PMA Resolutions may be
applicable to FPSOs, the once relevant to the design are however listed in the table below for
information:
Title Year / No.
MODU Code 1978 & 1989 MMC No. 87
The official text of Panama Maritime Authority’s Merchant Marine Circulars and PMA Resolutions
covering Panamanian ships are published on the web, available free of charge, at the following
web-site:
http://www.segumar.com/circulars/ and http://www.segumar.com/chronogram-of-issued-
resolutions/
In addition, Panama issue relevant Marine Notices, these can be found on the following web-site:
http://www.segumar.com/marine-notices/
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Electronic versions of the above DNV Rules and Standards are available on the web, free of
charge, at the following address:
https://exchange.dnv.com/Publishing/Servicedocs.asp
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Technical Safety
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Naval Architecture
Moorings
Topside Structure
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Hull Structures
Marine Operations
Quality Management
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Electronic versions of the above Standards (majority) are made available to the BWO PTM
through BWO’s Techstreet subscription, at the following address:
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http://subscriptions.techstreet.com/
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For a complete list of Offshore Information Sheets, please see the below web-page:
http://www.hse.gov.uk/offshore/infosheets/is_index.htm
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Statutory Authorization
DNV GL holds all relevant authorizations for issuance of statutory certificates on behalf of the
Flag State, Bermuda. Approval on behalf of other Local Governmental Authorities is in general
not delegated to the Classification Societies.
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approval comments prior to formal issue will reduce the overall project risk and contribute to a
successful project.
It is proposed that project documentation in the detailed design phase will be handled by the use
of digital drawings and DNV GL e-approval application, or as required by selected Classification
Society.
The Scope of Work consists of approval of all required class and statutory documents as defined
by DNV GL document requirements (Doc.Req).
The work will be documented by approved drawings and approval letters with appropriate
statuses.
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