Panama MMC-87 – Policy on MODU Code and Offshore Drilling Units
Panama Maritime Authority – Merchant Marine Circular MMC-87
Publication date: November 2026
Subject: Panama Policy on MODU Code and Offshore Drilling Units.
MMC-87 establishes the Panama Maritime Authority's policy for the application of the IMO Mobile Offshore Drilling Unit (MODU) Codes to Panamanian-flagged offshore drilling units. It sets out the applicable Code editions according to the unit's construction date, certification requirements, relevant international convention provisions, and instructions for Recognized Organizations (ROs).
This circular replaces MMC-48, MMC-70, MMC-81 and MMC-82.
Purpose and Scope of MMC-87
The circular provides guidance on the application of the 1979 IMO MODU Code to existing Mobile Offshore Drilling Units and establishes the applicability of the 1979, 1989 and 2009 MODU Codes to MODUs registered under the Panamanian flag.
It also clarifies the certification requirements and the dates on which the respective MODU Code editions were adopted by Panama.
Units covered
The requirements apply to self-propelled and non-self-propelled Mobile Offshore Drilling Units, irrespective of their keel-laying, construction or delivery date, subject to the applicable provisions of the circular.
International operations
International operations include drilling operations during international voyages or outside Panama's jurisdictional waters.
MODU definition
A MODU is a vessel capable of engaging in drilling operations for the exploration or exploitation of resources beneath the seabed, such as liquid or gaseous hydrocarbons, sulphur or salt. The circular refers to the 2009 MODU Code definitions in sections 1.3.11, 1.3.48 and 1.3.55 for Column-Stabilized Units, Self-Elevating Units and Surface Units.
Non-self-propelled units
This category includes units without mechanical propulsion, or units fitted with thrusters used only for short movements within a field, manoeuvring or propulsion while being towed, or maintaining position and heading without external assistance.
Applicable MODU Code According to Construction Date
The applicable MODU Code edition is determined by the date on which construction commenced, using the keel-laying date or a similar stage of construction as the reference point.
Existing MODUs – Before 13 December 1983
Units whose construction commenced before Panama adopted the 1979 MODU Code are treated as existing units.
Part B of Technical Note MODU 1/83 provides the applicable guidelines for existing units.
Technical Note MODU 1/831979 MODU Code
Applicable to units whose construction commenced on or after 13 December 1983 and before 12 August 1992.
The Code was adopted by Panama through Resolution 614-438-ALCN.
Resolution 614-438-ALCN1989 MODU Code
Applicable to units whose construction commenced on or after 12 August 1992 and before 27 June 2012.
The Code was adopted by Panama through Resolution 603-04-223-ALCN.
Resolution 603-04-223-ALCN2009 MODU Code
Applicable to units whose construction commenced on or after 27 June 2012.
The Code was adopted by Panama through Resolution 106-OMI-102-DGMM.
Resolution 106-OMI-102-DGMMMODU Code Amendments Adopted by Panama
MMC-87 identifies the following amendments and their respective implementation dates under Panama's resolutions.
2013 Amendments – Enclosed-Space Entry and Rescue Drills
Amendments MSC.357(92), MSC.358(92) and MSC.359(92) address enclosed-space entry and rescue drills. They were implemented through Resolutions 106-OMI-144-DGMM and 106-OMI-145-DGMM, effective from 21 January 2015, and Resolution 106-OMI-146-DGMM, effective from 1 January 2015.
2014 Amendments – Special Measures to Enhance Safety
Amendments MSC.382(94), MSC.383(94) and MSC.384(94) introduce special measures to enhance safety. They were implemented through Resolutions 106-OMI-172-DGMM, 106-OMI-173-DGMM and 106-OMI-174-DGMM, effective from 20 May 2016.
2009 MODU Code Amendment MSC.387(94)
This amendment concerns alternative guidelines implemented through MSC.1/Circ.1486. Panama gave effect to it through Resolution 106-OMI-174-DGMM, effective from 20 May 2016.
2016 and 2017 Amendments
Amendments MSC.407(96) and MSC.435(98) address fire safety and amendments to Chapters 1, 6, 8, 9, 10, 13 and 14. They were implemented through Resolution 107-OMI-220-DGMM, effective from 11 December 2019.
Note: MMC-87 also lists MSC.506(105), MSC.505(105) and MSC.504(105), all dated 28 April 2022, as recommendations only.
Surveys and MODU Safety Certification
Each MODU is subject to the surveys specified in section 1.6.1 of the applicable MODU Code edition.
Upon satisfactory completion of the required surveys, the unit is issued a Mobile Offshore Drilling Unit Safety Certificate in accordance with the applicable Code and Panama's requirements.
Application of SOLAS Requirements to MODUs
SOLAS Chapter IV – Radiocommunications
All MODUs, while stationary on location and including during drilling operations, are required to comply with the applicable Chapter IV requirements that would apply to a ship sailing through the same area.
All units must carry an updated Radio Station Licence issued by the flag State.
SOLAS Chapter V – Safety of Navigation
All units must carry a Minimum Safe Manning Certificate in accordance with Resolution 106-176-DGMM dated 15 December 2021. Nautical charts, publications and associated records are to be maintained in accordance with MMC-108.
The circular specifies that units whose keel was laid, or which were at a similar stage of construction, on or after 27 June 2012 and which are certified under the 2009 MODU Code must comply with all SOLAS Chapter V regulations on all voyages, subject to the distinctions below.
Requirements addressed to “ALL SHIPS”
These provisions apply while the MODU is on location and during transit for self-propelled units, or while escorted or towed for non-self-propelled units.
Requirements addressed to “MOBILE OFFSHORE DRILLING UNITS”
Where a SOLAS regulation specifically refers to Mobile Offshore Drilling Units, the circular treats this reference as applying to self-propelled MODUs. The relevant requirements apply to such units while on location or in transit.
Non-self-propelled MODUs
The circular recognizes that non-self-propelled units may be unable to comply with certain SOLAS Chapter V regulations. Panama may grant exemptions or accept equivalent arrangements under SOLAS Regulation 3.
SOLAS Chapter IX – Management for the Safe Operation of Ships
Chapter IX applies only to self-propelled MODUs. These units must carry updated Declarations of Company and Declarations of the Designated Person Ashore (DPA), issued by the flag State.
SOLAS Chapter XI-1 – Special Measures to Enhance Maritime Safety
All self-propelled MODUs must comply with the applicable Chapter XI-1 requirements and carry a Continuous Synopsis Record (CSR).
SOLAS Chapter XI-2 – Special Measures to Enhance Maritime Security
The circular states that this chapter applies only to self-propelled MODUs, which must carry a Declaration of Company Security Officer (CSO) and an International Ship Security Certificate (ISSC).
Editorial clarification: In paragraph 6.5.1, under the Chapter XI-2 heading, the circular's text refers to “Chapter IX”. This appears as a textual inconsistency in the source circular. The above section identifies the requirement under the Chapter XI-2 heading while making the source wording discrepancy explicit.
MODU Code Chapter 14 – Operations
Coastal States may require a higher safety standard for MODUs when they are stationary and engaged in drilling operations within their jurisdiction.
MODUs operating within the jurisdictional waters of a coastal State must comply with the safety requirements that the coastal State considers adequate for the unit and its operations.
Flag State Inspection Requirements
All MODUs registered under the Panamanian flag are subject to assessment for eligibility for Flag State Inspection (FSI), in accordance with MMC-171 and Article 117 of Law 57 of 2008.
FSI eligibility and authorization
Owners and operators should contact the FSI Section to verify the unit's current status and the authorization process for inspection.
Deficiencies identified during inspection
Deficiencies identified during FSI must be rectified. The corrective actions must be reported to the FSI Section within 30 days, in accordance with MMC-201.
Remote and inaccessible units
Exceptions may be granted for units operating in remote or difficult-to-access locations where an authorized FSI inspector is not readily available, unless the Directorate General of Merchant Marine (DGMM) authorizes otherwise.
Other International Convention Requirements
MARPOL – Prevention of Pollution
Drilling MODUs may be unable to comply with certain requirements concerning oily-water separators (OWS). Panama may grant an exemption or accept equivalent arrangements under MARPOL Regulation 3, provided the conditions stated in the circular are satisfied.
An adequate holding tank must be provided, to the satisfaction of the Recognized Organization, for the retention of all oily bilge water.
All oily bilge water must be retained on board for delivery to suitable shore reception facilities in accordance with MARPOL requirements.
Appropriate records of the retained and discharged material must be maintained.
Maritime Labour Convention, 2006 (MLC 2006)
A Maritime Labour Certificate and Declaration of Maritime Labour Compliance (DMLC) Parts I and II are not mandatory for MODUs under Regulation 5.1.3 and Standard A5.1.3. Voluntary certification is available in accordance with MMC-251 and MMC-269.
All units should have the financial security arrangements specified in MMC-336 covering:
- Repatriation under MLC Regulation 2.5.
- Shipowner liability under MLC Regulation 4.2.
ILO Convention No. 92 – Crew Accommodation
A Certificate of Inspection of Crew Accommodation (CICA) is not mandatory. Voluntary certification is available where the unit complies with ILO Convention No. 92 and MLC Regulation 3.2, in accordance with Article 5 of Resolution J.D. 045-2021. The circular also refers to MMC-279 and MMC-396.
Anti-Fouling Systems (AFS)
An Anti-Fouling Systems Certificate issued by an approved Recognized Organization is required for all self-propelled MODUs, in accordance with MMC-157.
For non-self-propelled MODUs, the owner or authorized agent must provide a declaration supported by appropriate documentation, such as paint receipts or a contractor's invoice, or an endorsement confirming that the paint does not contain substances controlled under the AFS Convention.
Casualty Reporting and Investigation
The Recognized Organization responsible for issuing the MODU Safety Certificate must receive reports of casualties or defects that may affect the safety of the unit, its life-saving appliances or its equipment.
The RO must initiate an investigation to determine whether a survey is necessary.
A Flag State Inspector or an authorized RO surveyor involved in a casualty may be required to submit relevant records and documentation in accordance with Resolution 106-135-DGMM dated 9 September 2013.
Instructions and Responsibilities for Recognized Organizations
MMC-87 sets out specific responsibilities for Recognized Organizations in relation to the design, construction, classification, maintenance and certification of Panamanian-flagged MODUs.
Design, construction and maintenance
ROs must maintain appropriate requirements in accordance with section 2.2 of the RO Code. These include class rules and procedures addressing materials, stability, hull structure, machinery, electrical systems, automation, lifting appliances and operational matters.
Structural evaluation
Special attention must be given to structural evaluation according to the hull configuration of Surface Units, Self-Elevating Units and Column-Stabilized Units. The assessment should take account of drilling-related stresses and the required structural strength.
Interpretation of Code provisions
Class rules must also address provisions containing expressions such as “consideration”, “special consideration”, “should give special consideration” and “to the satisfaction of the Administration”.
Class notation
The Certificate of Class should include the applicable class notations according to the MODU type and the relevant technical requirements.
Communication with the Administration
ROs must communicate with the Administration regarding class assignments, changes and withdrawals in accordance with section 3.9.2.1.2 of the RO Code.
MODU Safety Certificate – Required Wording and Certification
For existing units that do not fully comply with the MODU Code but are considered suitable for international operations under Part B of Technical Note MODU 1/83, the MODU Safety Certificate must include the wording specified by the Administration.
Required wording for applicable existing units:
“as modified by the guidelines of the Administration for its application to existing units”
The circular distinguishes the certificate headlines applicable to units certified under the 1979, 1989 and 2009 MODU Codes. Recognized Organizations must use the appropriate certificate format and wording for the applicable Code edition.
2009 MODU Code – SOLAS Chapter V
All units certified under the 2009 MODU Code must comply with SOLAS Chapter V in accordance with paragraph 11.10.1 of that Code.
Paragraph 6 of the relevant certificate is to state that the survey has shown compliance with the applicable requirements for shipborne navigational equipment under SOLAS Chapter V.
Use of a later Code edition
A higher edition of the MODU Code may be applied where the construction contract specifies that the customer requested compliance with that later edition.
Additional SOLAS certificates
Where required by a coastal State, the Recognized Organization may issue conventional SOLAS Safety Construction, Safety Equipment and Safety Radio Certificates in addition to the MODU Safety Certificate.
Manning and Personnel Requirements
All MODUs must be appropriately manned. Recognized Organizations are instructed to verify the applicable manning documentation and personnel requirements during the Annual Survey.
The Minimum Safe Manning Certificate and Panama Seaman Books for offshore personnel are to be verified in accordance with Resolution J.D. 052-2021 dated 2 August 2021.
Exemption Certificate – Application and Issuance Procedure
The circular establishes a process for exemptions involving the operator, Resident Agent, Recognized Organization and SEGUMAR.
Application to SEGUMAR
The operator, Resident Agent or Recognized Organization submits the exemption request to SEGUMAR.
Authorization and concurrence
SEGUMAR issues the concurrence or authorization letter for the Recognized Organization to proceed with the interim exemption process.
Interim exemption
The Recognized Organization may issue an interim exemption certificate valid for five months.
Full exemption certificate
The full Exemption Certificate is issued by SEGUMAR.
MODU Safety Certificate endorsement
The Recognized Organization must issue or update the MODU Safety Certificate and list the applicable exemptions in paragraph 4.
ROs must also take into account the applicable fees under Resolution J.D.019-2009, as amended by Resolution J.D.002-2010.
Recommended MODU Class Notations
The circular identifies class notations that may be appropriate according to the unit's design, propulsion arrangement, operating mode and service limitations.
Unit Type
Column Stabilized Drilling Unit
Self-Elevating Drilling Unit
Drillship
Machinery and Propulsion
Unattended Machinery Spaces
Mechanically propelled units
Non-self-propelled units with short field moves
Positioning and Dynamic Positioning
Dynamic Positioning (DP) system, where fitted and applicable.
Service and Environmental Limitations
Service limitation, site or geographical location.
Restricted service for environmental considerations.
Terminology Used in the Certificate of Class
MMC-87 instructs Recognized Organizations to avoid using the terms “Platform”, “Facility”, “Installation” and “Rig” in the Certificate of Class. The circular explains the specific terminology used in the MODU Code.
Platform
In the context described by the circular, this term refers to areas such as the helideck, deck level, manoeuvring area or personnel transfer net.
Facility
The term is used in relation to areas or equipment such as the helicopter area, maintenance service station, helideck lights and output devices.
Installation
The circular uses this term in connection with the installation of electrical services, machinery and equipment.
Barge
The MODU Code uses the term “Barge” in defining a Surface Unit, referring to a ship- or barge-type displacement hull, which may be single-hull or multi-hull and floating.
Rig
The term “Rig” is not used in the MODU Code. It is a generic industry expression that may refer to different types of offshore units and is not a specific MODU Code unit classification.
Frequently Asked Questions – Panama MMC-87
The following questions summarize key points of MMC-87 for owners, operators and Recognized Organizations dealing with Panamanian-flagged Mobile Offshore Drilling Units.
Which MODU Code applies to a Panamanian-flagged offshore drilling unit?
The applicable edition depends on the date construction commenced, using the keel-laying date or a similar stage of construction. The circular distinguishes existing units before 13 December 1983, the 1979 Code, the 1989 Code and the 2009 Code, with the relevant dates and Panama adoption resolutions set out above.
Does MMC-87 apply to both self-propelled and non-self-propelled MODUs?
Yes. The circular addresses both self-propelled and non-self-propelled MODUs, irrespective of their construction or delivery date, while identifying certain convention requirements that apply only to self-propelled units.
Are all MODUs required to carry a MODU Safety Certificate?
MODUs are subject to the surveys specified in section 1.6.1 of the applicable MODU Code. Upon completion of the required surveys, the Mobile Offshore Drilling Unit Safety Certificate is issued in accordance with the applicable requirements.
Do non-self-propelled MODUs have to comply with all SOLAS Chapter V requirements?
The circular recognizes that non-self-propelled units may be unable to comply with certain SOLAS Chapter V regulations. Panama may grant exemptions or accept equivalent arrangements under SOLAS Regulation 3.
Are SOLAS Chapter IX and Chapter XI-2 requirements applicable to all MODUs?
MMC-87 identifies the relevant Chapter IX and Chapter XI-2 requirements as applying only to self-propelled MODUs. The circular specifies the applicable company, DPA and security documentation.
Is a Maritime Labour Certificate mandatory for a MODU?
According to MMC-87, a Maritime Labour Certificate and DMLC Parts I and II are not mandatory for MODUs under the cited MLC provisions. Voluntary certification is available under MMC-251 and MMC-269. The circular separately addresses financial security arrangements under MMC-336.
Are Flag State Inspections required for Panamanian-registered MODUs?
All registered MODUs are subject to assessment for FSI eligibility under MMC-171 and Article 117 of Law 57 of 2008. Owners and operators should contact the FSI Section to verify the unit's status and inspection authorization requirements.
What is the reporting period for deficiencies identified during FSI?
Deficiencies must be corrected and reported to the FSI Section within 30 days, in accordance with MMC-201.
Can a MODU receive an exemption from a specific requirement?
Panama may grant exemptions or accept equivalent arrangements where permitted by the relevant convention or circular. MMC-87 describes the application process through SEGUMAR, including the interim exemption issued by the RO and the full exemption certificate issued by SEGUMAR.
Can a Recognized Organization issue conventional SOLAS certificates in addition to the MODU Safety Certificate?
Yes. The circular states that conventional SOLAS Safety Construction, Safety Equipment and Safety Radio Certificates may be issued by the RO in addition to the MODU Safety Certificate when requested due to coastal State requirements.
Does MMC-87 require a particular class notation for every MODU?
The circular provides recommended class notations according to the unit type, machinery and propulsion arrangement, dynamic positioning system and service limitations. The applicable notation depends on the individual unit and its characteristics.
Which previous Panama circulars are replaced by MMC-87?
MMC-87 replaces MMC-48, MMC-70, MMC-81 and MMC-82.
Regulatory References and Official Contact
References cited in MMC-87
- Technical Note MODU 1/83 dated 1 January 1983.
- Resolution 614-438-ALCN dated 13 December 1983.
- Resolution 603-04-223-ALCN dated 12 August 1992.
- Resolution 106-OMI-102-DGMM dated 27 June 2012.
- IMO Resolution MSC.506(105), dated 28 April 2022 – recommendation only.
- IMO Resolution MSC.505(105), dated 28 April 2022 – recommendation only.
- IMO Resolution MSC.504(105), dated 28 April 2022 – recommendation only.
Panama Maritime Authority – SEGUMAR
General Directorate of Merchant Marine
Panama Maritime Authority – SEGUMAR Panama
Telephone: +507 501-5353 / 501-5350 / 501-5348
Email: [email protected]
Email: [email protected]
Official circulars: Panama Ship Registry – Circulars
Source: Panama Maritime Authority, General Directorate of Merchant Marine, Control and Compliance Department, Merchant Marine Circular MMC-87, November 2026.