Legislation and Guidance
Certificate of Fitness
The Atlantic Accord Implementation and Offshore Renewable Energy Management Acts and the associated regulations require that each prescribed offshore installation (production, drilling, diving and accommodation) have a valid Certificate of Fitness (COF) issued by a recognized Certifying Authority (CA) before that installation is used to conduct any petroleum related activity in the offshore area.
The Government of Canada, Government of Newfoundland and Labrador and the Government of Nova Scotia through the regulations have recognized four organizations to act as certifying authorities. The four organizations are:
The purpose of this additional certification, issued by the CA, is to provide an independent third party verification that the installation and associated systems and equipment, during the term of the certificate, is fit for purpose and is being maintained in compliance with the regulations without compromising safety and/or polluting the environment.
Prior to the issuance of the COF, the CA is required to submit a Scope of Work (SOW) to the CSO for approval. This is an agreement between the CA, COF applicant and CSO and it describes how the CA will assess the installation, its equipment and systems to determine its fit for purpose and that it meets the required regulations.
Following the issuance of the COF, the CA conducts verification activities including surveys of the installation periodically to verify the continued integrity of the installation, associated systems and equipment. In addition, any modifications/repairs to the installation, that fall within the CA’s responsibility, that may affect its strength, stability, integrity, operability, safety or regulatory compliance would need to be reviewed and accepted by the CA to ensure the continued validity of the certificate.
Certification staff within the Safety department receives periodic reports and meets regularly with the CAs for installations operating in our jurisdiction. Staff also monitor and conduct compliance verification activities of the CA as per their approved SOW document.
In addition, floating installations such as mobile offshore drilling units (MODUs), floating production storage and offloading (FPSO’s) and vessels, etc., also comply with the requirements of their associated flag state and carry the applicable convention certificates. The permanent floating installations in the offshore area (e.g. FPSO’s) are Canadian flagged and are therefore reviewed by Transport Canada Marine Safety as the Flag State. The C-NLOER and Transport Canada Marine Safety have an MOU that includes technical advice and support to each.
It is the ultimate responsibility of the Operator to ensure the activity, including the installation and associated systems and equipment, comply with the regulations and to ensure the activity can be conducted safely without polluting the environment.