To achieve confidence in continuous 20+ year FPSO service without fatigue cracks leading to costly repair offshore or in dry-dock, ExxonMobil has developed a prescriptive Fatigue Methodology Specification (FMS, ref. 5) for new-build FPSOs. An important FMS requirement for turret-moored FPSOs is to determine relative wave headings in non-collinear wind, current and wave environments using a first-principles approach. Based on initial review with FPSO designers, this FMS requirement may pose a significant challenge because appropriately defined met-ocean criteria and efficient analytical design tools are not readily available. To date, FPSO designers typically account for weather-vaning in non-collinear environments by assuming a distribution of relative wave headings based on experience. For example, one assumption is to use 0 degrees (head seas) for 70% of the time and within ±30 degrees off the bow for the remaining 30%. In certain environments, this assumption can lead to a non-conservative fatigue design for hull structural details that are sensitive to beam seas, and an overly conservative fatigue design for details sensitive to head seas. ExxonMobil contracted Moffat & Nichol to develop a time-domain procedure to predict mean FPSO headings by considering wave, wind and current induced loads on the FPSO hull and topsides throughout the FPSO’s 20+ year operational life. A key element of this methodology is a directional representation of met-ocean data, including waves, winds and currents for every 3- or 6-hour sea-state. We have implemented our heading analysis procedure in robust software, which includes processing of the 20+ year met-ocean data in the time domain. Once the FPSO heading time history is known, fatigue lives at critical structural connections are predicted using the spectral fatigue method prescribed in the FMS. To demonstrate the heading methodology and assess its efficiency for project use, an example analysis was performed for an FPSO at a specific geographic location, where relatively strong currents exist. Comparison of predicted FPSO headings and fatigue lives with those using the existing industry practices confirmed the need for a first principles based heading methodology for FPSO fatigue design. The heading and fatigue analysis procedure described here can lead to more accurate, robust fatigue designs for FPSOs in non-collinear environments.