The Coast Guard published Marine Environmental Response Marine Safety Information Bulletin 02-17, which clarifies three items pertaining to Remote Access and Consultation (RAC) drills:
1. Section 3.4 of the 2016 National PREP Guidelines (Guidelines) directs a vessel owner or operator, vessel master, or designee (as specified in the approved VRP) to: “Contact the SMFF remote assessor by telephone, radio, or other means of communications to discuss a shipboard response scenario as detailed in the VRP.” This will be revised to read “Contact the QI and/or the SMFF remote assessor as specified in the approved VRP.”
2. The frequency of RAC drills specified in section 3.4 of the Guidelines is annually (NOT quarterly). Specifically, Section 3.4 articulates that RAC frequency is “Annually while operating in U.S. waters, including the EEZ; otherwise, upon entry into U.S. waters, no less than one time per vessel per year.”
3. It is allowable to conduct RAC drills in conjunction with QI Notification Drills provided all of the objectives for both drills are met as detailed in the Guidelines.
Administrative revisions to the Guidelines will be done by the PREP Compliance, Coordination and Consistency Committee (PREP4C). The aforementioned items apply immediately and will be incorporated in the next revision to the Guidelines, expected this Spring.
The above represents the Coast Guard’s commitment to ensuring the preparedness-to-respond intent of OPA 90 is optimized. As RAC drills are new to PREP, it is imperative to closely monitor their execution and adjust the Guidelines accordingly. Such adjustments will formally be considered by PREP4C at future meetings.
Questions or comments with respect to VRP exercises should be e-mailed to vrp@uscg.mil.
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.