As explained, the implications of VRP activation are significant, as failure to activate a plan quickly or failure to use pre-contracted resources can result in delayed response and exacerbate potential environmental damages.
Which situations require VRP activation?
- The master is required to activate the VRP when he or she determines that the resources and personnel available onboard cannot meet the needs of an actual discharge or the substantial threat of discharge. Although hazardous conditions, such as an engine casualty, grounding, fire, or flooding, may not directly result in a discharge, plan activation is still required because, if left unresolved, they could result in a discharge.
- The master’s accurate situation assessment is critical to initiating an effective response. Despite often reluctance from vessel masters, quick and proper activation of a VRP will eventually cost less.
- Delayed activation of a VRP can mean the resources identified in a plan won’t reach the scene in time to mitigate a worst case discharge. Plan holders invest significant time in identifying the appropriate resources for a vessel’s VRP, and proper activation ensures the correct resources are engaged to manage the situation.
- If USCG sees any hesitation in the master’s decision to activate a VRP, the captain of the port may issue an order to activate the plan. The decision comes down to resource availability and waiting might hinder the ability to get on scene soon enough.
When does VRP activation occur?
- VRP activation occurs when the master contacts the Qualified Individual (QI) identified in the VRP. This is required when resources and personnel available onboard the vessel cannot meet the needs of an actual discharge or the substantial threat of discharge; or when unresolved hazardous conditions are present.
- Contacting the QI does not always result in resource mobilization; instead, it begins a discussion between the master and the QI to determine if resource mobilization and/or consultation services are necessary. However, VRP activation obligates the QI to employ the resources identified in the VRP for the services being considered, unless given prior approval by the federal on scene coordinator.
- The QI is defined in regulation as having the authority to mobilize resources and consultative services identified in the VRP and to act as the liaison with the federal on scene coordinator. Coast Guard notifications are required for spills and hazardous conditions onboard. When USCG is notified of a spill or hazardous condition, the federal on scene coordinator will ask if the VRP has been activated and assumes that certain resources identified in the plan are being employed or consulted.
- Under exceptional circumstances, the federal on scene coordinator will consider requests to deviate from the VRP during a response where it would lead to a more expeditious or effective response to the spill or mitigation of its environmental effects. In this situation, the QI must identify the resources and obtain approval for a deviation from the FOSC.
The successful handling of commercial vessel casualties can often be particularly challenging, as they require coordinated, simultaneous efforts from both Coast Guard prevention and response personnel and industry. Marine salvage companies and/or OSROs mitigate the casualty and prevent or minimize the threat of pollution. VRPs provide clear guidance to vessel operators, qualified individuals, and the federal on scene coordinator regarding a vessel’s pre-designated marine salvage companies and OSROs, and how these entities are to be activated during a response.