Environmental Response Policy

9/25/2017: FY18 requirements for Gov’t Initiated Unannounced Exercises

Editor’s Note: In May 2017, Lt. Cmdr. Johna Rossetti and Petty Officer 2nd Class Chris Klarmann gave a presentation, “Using GIUEs to Improve Marine Environmental Response Preparedness,” at the International Oil Spill Conference in Long Beach, California. That presentation is summarized below, as it relates to a recent announcement regarding the FY18 GIUE requirements for each captain of the port.

The Coast Guard published Sept. 12, 2017 the FY18 Government Initiated Unannounced Exercise (GIUE) requirements for each captain of the port, to include sectors and marine safety units. In 2015, the Office of Marine Environmental Response Policy (CG-MER) reinvigorated the Coast Guard GIUE program by releasing new GIUE policy which has since been incorporated into the Marine Environmental Response and Preparedness Manual. This policy established consistent exercise design, execution and documentation across the Coast Guard. It also defined the number of GIUEs required at each unit.

Chart showing FY18 GIUE targets for each captain of the port zone.

FY18 GIUE targets for each captain of the port zone.

“GIUEs are one of the cornerstones of an area’s exercise cycle and a tool for Coast Guard captains of the port to evaluate industry’s preparedness for oil spill response,” said Lt. Cmdr. Johna Rossetti during a joint presentation with Petty Officer 2nd Class Chris Klarmann at the International Oil Spill Conference in May.

GIUEs are no-notice exercises required by the National Contingency Plan. They are conducted to measure a facility or vessel response plan holder’s initial response actions to a most probable discharge scenario at the type of facility or vessel the plan covers.

The NCP’s National Preparedness for Response Exercise Program (PREP) provides guidelines for conducting all preparedness and response exercises. PREP is co-owned by Coast Guard, Environmental Protection Agency, Bureau of Safety and Environmental Enforcement, and Pipeline and Hazardous Materials Safety Administration, and any one of the four agencies may require a separate GIUE.

GIUEs provide many benefits for plan holders. First, GIUEs allow plan holders to verify and validate response plans and identify areas for improvement. Second, GIUEs provide training and experience for employees, responders, and oil spill response organization (OSROs) contractors who may not have the opportunity to work together regularly. Additionally, GIUEs provide OSROs the chance to become more familiar with regulatory requirements. Last, GIUEs improve communication among regulators, contractors, and facility or vessel employees during a lower-stress situation than what would be found in an actual response.

Rossetti’s co-presenter at IOSC, Petty Officer 2nd Class Klarmann, provided an overview of the process the Coast Guard uses to initiate and conduct an unannounced GIUE (Steps 1-5 do not involve any contact with the plan holder, other than the initial letter described in Step 1):

1. COTP sends a letter to every facility in the COTP zone reminding them of their regulatory requirement to conduct a GIUE, if selected.

2. Selects a facility or vessel, based on past performance during real responses or exercises. (A history of poor performance increases the chances of being selected for a GIUE.)

3. Conducts a full plan review to ensure the plan is up to date and to get familiar with the contents of the plan in advance, such as contracts and response timetables.

4. Develops a plan-specific scenario that is as realistic as possible. The product chosen will be one normally used or found at the facility or on the vessel and the point of the entry into the water is one that actually exists.

5. Identifies objectives the plan holder must meet. Typically, these are to conduct notifications per the plan, deploy equipment in accordance with the plan, and conduct the exercise in a safe manner.

6. The Coast Guard arrives unannounced at the facility and provides the plan holder with the scenario and talks through any questions they may have in advance.

7. Executes the exercise. If at any point the plan holder fails to meet an objective, the exercise is immediately halted.

8. Documents the exercise results and provides it to Coast Guard marine environmental response offices at all levels.

If a Coast Guard GIUE is determined to be successful, the plan holder is exempt from another Coast Guard-led GIUE for 36 months. Plus, they receive three exercise credits in accordance with PREP guidelines. Rossetti said joint-agency GIUEs, though perhaps more complicated and involved, reduce the overall impact to industry since multiple agency requirements may be satisfied through one exercise.

Klarmann said the most common reason for unsuccessful GIUEs is equipment deployment deficiencies.

“This is a real exercise and we want to see them deploy boom and skimmers in a manner that will really work, and we want to see anchors deployed properly,” Klarmann said. “Basically, we want to see that they’re following their plan.”

Other issues include missing equipment that was listed in the response plan, failure to actually follow the response plan, inadequately prepared qualified individuals, and unsafe response operations.

Rossetti said as more GIUEs are conducted under the new policy, lessons learned from the field will be used to improve guidance. She also added that CG-MER is encouraging Coast Guard units to partner with EPA, BSEE, and PHMSA to do joint GIUEs to allow for different perspectives and to reduce redundancies and duplication of effort.

Last, Rossetti said CG-MER is encouraging COTPs improve their outreach programs.

“We need to better communicate with vessel agencies and OSROs and engage them at venues such as Area Committee Meetings and Regional Response Team meetings,” she said. “We’re hoping with stronger outreach programs implemented at the sector level, and more discussion at the area and regional meetings, port partners such as plan holders and OSROs will become better informed of the requirements, leading to better preparedness.”

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.

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