The US Coast Guard uses many methods to evaluate a tank or non-tank vessel owner/operator’s compliance with vessel response plan (VRP) regulations. In April 2017, the US Coast Guard Office of Marine Environmental Response Policy began a new verification performed along with the review of a VRP for approval.
This verification is scenario-based and is also designed to evaluate compliance specific to applicable salvage and marine firefighting (SMFF) planning criteria.
The verification has accomplished the following:
- The Coast Guard has reviewed and determined satisfactory the results of 58 scenario-based SMFF verifications conducted in conjunction with respective VRP reviews.
- 16 vessel owners/operators satisfactorily completed at least one scenario-based SMFF verification.
- Locations of the completed scenario-based SMFF verifications include 16 different Captain of the Port zones, with a minimum of one or more of the 19 SMFF services verified in each zone.
In accordance with their VRP, operators and their SMFF resource providers can identify resources capable of providing the selected SMFF service within the regulatory planning timeframes.
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The majority of the US Coast Guard’s requests for follow-up information involved the identification or explanation of response personnel’s qualifications and training, as well as clarification on the use of subcontractors and resource deployment routes. Where there are differences between resources in a verification scenario and the VRP, operators in coordination with their respective SMFF provider, have to update their VRP, including correction of geographic specific appendices.
Process of the verification:
- SMFF verifications occur in conjunction with the regular review of VRPs submitted for initial approval or five-year renewal.
- Not every VRP will be selected for SMFF verification. Selection will be based on the Coast Guard’s goal of verifying SMFF capability in all 41 COTP zones. Participation in the scenario-based SMFF verification is mandatory for those vessel owners/operators selected.
- Following a vessel’s submission of a VRP for approval or renewal, vessel owners/operators, or the designated plan preparer on their behalf, are asked to answer verification questions specific to a scenario involving one of their vessels, tank or non-tank, requiring certain SMFF services in one Captain of the Port zone listed in their VRP.
- Operators answer the verification questions following the information provided in their VRP. The verification questions are specific to SMFF planning criteria applicable to the scenario, including planned timeframes and endpoints to provide services in response to an incident.
- The verification scenario is based on a specific date and time, typically within hours upon notification of the verification, to allow for an accurate snapshot of response resource information.
- Operators have up to ten days to complete the verification questions and respond to the US Coast Guard.
- If the Coast Guard determines the answers provided in response to the scenario-based SMFF verification demonstrate compliance, then no further action is required.