There has been increasing discussion in recent months re-garding the possibility of using floating Production, Storage, and Offloading (FPSO) systems as an oil and gas development option on the United States (U.S.) Gulf of Mexico outer continental shelf (OCS). Operators interested in using FPSOs in the U.S. sector of the Gulf of Mexico will have to obtain regulatory approval from the U.S.Department of Interior, Minerals Management Service (MMS). In addition, FPSOs proposed for use on the U.S. OCS will be required to meet specific vessel design and operational regulations administered by the U.S. Coast Guard. The U.S.Coast Guard recently stated that the Oil Pollution Act of 1990 (OPA90) requirements for tank vessels apply to U.S. and foreign flag FPSOs proposed for use on the U.S. OCS. Consequently, operators considering use of an FPSO will need to work closel with the U.S.Coast Guard to determine whether OPA-op double hull construction requirements apply to their vesslels. The use of single hull FPSOs on the U.S.OCS may not be possible in cretain cases.
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