Submitted by Christopher Friese, Commercial Vessel Safety Specialist
Office of Marine Environmental Response (CG-MER)
Vessel Response Plan activation is one area where Coast Guard personnel often encounter confusion from vessel masters and response plan holders over the threshold for activating a response plan and which of their actions actually constitute plan activation. The implications of VRP activation are significant and a clear understanding is essential. Failure to activate a plan quickly or failure to use pre-contracted resources can result in delayed response and exacerbate potential environmental damages.
In this post, we will attempt to clarify when plan activation occurs and which situations require plan activation.
Which situations require VRP activation?
The master or person in charge of the vessel is required to activate the VRP when he or she determines that the resources and personnel available on board the vessel cannot meet the needs of an actual discharge or the substantial threat of discharge. It is important to understand that 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. On occasion, we see reluctance from vessel masters to make the sometimes-difficult decision to activate a VRP because they want more time to troubleshoot the problem. However, quick and proper activation of a VRP will cost less in the end. Delayed activation of a VRP can also mean the resources identified in a plan won’t reach the scene in time to mitigate a worst case discharge. Plan preparers/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 the Coast Guard 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 or person in charge of the vessel contacts the Qualified Individual (QI) identified in the VRP. As stated above, this is required when resources and personnel available on board 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 vessel 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 on board. When the Coast Guard 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.
Find more information and answers to Frequently Asked Questions by visiting Homeport and selecting “Environmental” from the Missions tab, and then the “Vessel Response Plan Program” tab. Alternatively, questions may be sent to the VRP program manager at firstname.lastname@example.org.
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.