In fact, the above mentioned MSIB serves as a reminder that vessel and facility owners or operators must ensure the availability of response resources remain within stipulated response times in accordance with 33 CFR § 154 and 33 CFR § 155.
Vessel and Facility owners or operators should continually communicate with their oil spill response and salvage and marine firefighting (SMFF) providers to assess changes or degradation of resource availability and capability.
The uninterrupted flow of commerce on our Marine Transportation System (MTS) is critical to both National Security and economic vitality.
During the ongoing national emergency, it is paramount that we safeguard the continued operation of the MTS in the face of the acute and evolving threats posed by the novel coronavirus (COVID-19) pandemic. The MTS, which provides more than 90 percent of the domestic supply chain, is dependent on an extensive support network, to include the response community.
For the records, the 2019 USCG guidelines for the Oil Spill Removal Organization (OSRO) Classification Programrequires classified OSROs to notify the applicable Captain of the Port (COTP) and the National Strike Force Coordination Center of any significant changes made to its response resources within 72 hours. A significant change is defined as a reduction in the OSRO’s capacity by a factor of 10% or greater, for a period of 48 hours or longer.
All OSROs, classified or not, and SMFF providers must notify their clients if they are unable to meet their contractual agreements. Vessel and facility owners or operators remain responsible to ensure the availability of response resources, and shall immediately contact the COTP of any response resource impacts.