Role of Third-Party Oversight and Certified Verification Agents - Structural Integrity of Offshore Wind Turbines - page 96

institute's requirements of open development procedures, including
public participation in the development, review, and approval stages. All
comments to proposed standards must be addressed and resolution of
comments documented. While the standards are shepherded by an indus-
try organization, they are delivered as U.S. national standards.
Early Years of the CVA Program
In the early 1980s the Minerals Management Service (MMS) maintained
a list of preapproved CVAs. An organization could petition MMS to
approve it as a CVA for design, fabrication, or installation on the basis
of the organization's capabilities. Approval was granted for a period of
3 years. An operator could choose from the list of preapproved CVAs or
propose another organization for approval to function as a CVA on a given
project. After several years, MMS discontinued the practice of preapprov-
ing CVAs because of difficulties in maintaining the list and the relatively
few facilities requiring use of a CVA. Only a small subset of the approved
CVAs were actually selected and used.
Initial CFR and Notices to Lessees
USGS implemented a CVA program through provisions in OCS Order 8
(later incorporated into 30 CFR 250 Subpart I) and various notices to
lessees. The program initially covered structural aspects of fixed platforms
and has been expanded to cover structural and station-keeping aspects of
permanent floating production facilities and production risers for the float-
ing facilities. The drilling and process systems of the offshore facilities have
not been covered under the CVA program.
The CVA program can be summarized as follows:
1. Design, fabrication, and installation have been designated as distinct
phases of a project, and each phase must be verified.
2. A single CVA can be approved for all three phases, or individual CVAs
can be approved for each of the three phases.
3. Initially, individuals or companies could petition USGS to be approved
as a CVA for a given phase or for multiple phases on the basis of com-
petency. On acceptance by USGS, approval was granted for 3 years.
USGS maintained the list of preapproved CVAs by phase.