From the desk of Rear Adm. Anthony “Jack” Vogt, assistant commandant for response policy
The Coast Guard uses several methods to evaluate a tank or non-tank vessel owner/operator’s compliance with vessel response plan (VRP) regulations. In April 2017, the Coast Guard Office of Marine Environmental Response Policy began a new, scenario-based verification performed in conjunction with the review of a VRP for approval. This scenario-based verification is designed to evaluate compliance specific to applicable salvage and marine firefighting (SMFF) planning criteria in Subpart I of Title 33, Code of Federal Regulations, Part 155.
• The Coast Guard has reviewed and determined satisfactory the results of 58 scenario-based SMFF verifications conducted in conjunction with respective VRP reviews.
• With the assistance of seven third party plan preparers, 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.
Record of completion of a scenario-based SMFF verification is documented on the respective VRP approval letter.
In accordance with their VRP, vessel owners/operators and their SMFF resource providers have been able to identify resources (i.e. qualified personnel, support vessels, and/or equipment) capable of providing the selected SMFF service within the regulatory planning timeframes. Furthermore, SMFF resource providers have provided job histories showing they have a successful record of accomplishment of SMFF services.
Vessel owners/operators promptly responded to the Coast Guard when asked for more detail required for the assigned verification. The majority of the Coast Guard’s requests for follow-up information involved the identification or explanation of response personnel’s qualifications and training (within limitations for privacy rights), as well as clarification on the use of subcontractors and resource deployment routes. Where there have been differences between resources used in a verification scenario and the VRP, vessel owners/operators, in coordination with their respective SMFF provider, have been required to update their VRP, including correction of geographic specific appendices (e.g. towing vessel(s) and/or subcontractor information added or removed from a VRP).
• 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.
• Vessel owners/operators answer the verification questions following the information provided in their VRP, which may include contacting the primary SMFF resource provider for the specific SMFF service identified in the scenario. 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 owners/operators’ verification results are then evaluated by the Coast Guard to ensure the response resources used in completing the verification are identified in the VRP, provide the services specified in the VRP, and can meet the regulatory planning requirements.
• 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. Using such resources as Automated Information System vessel tracking history and documentation available within the Coast Guard’s Marine Information for Safety and Law Enforcement system, the Coast Guard evaluates the response resources and information provided by the vessel owner/operator, including the ability to safely meet the planning timeframes and endpoints identified in the regulation. The scenario-based SMFF verification approach does not involve the actual deployment of resources to a particular scene.
• Vessel owners/operators are afforded up to ten days to complete the verification questions and respond to the Coast Guard. This 10-day timeframe to provide final answers in support of the verification is considerate of the dynamic operational and administrative schedules of vessel owners/operators, plan preparers, and resource providers.
• If the Coast Guard determines the answers provided in response to the scenario-based SMFF verification demonstrate compliance, then no further action is required. The Coast Guard will document the scenario-based SMFF verification as satisfactory. Areas of concern identified by the Coast Guard will be communicated to the vessel owner or operator prior to the VRP’s approval. No VRP will be approved unless the plan holder sufficiently demonstrates the resources listed in the plan meet the requirements.
The SMFF scenario-based verification offers a number of benefits and capabilities intended to complement VRP compliance efforts by vessel owners/operators. Notably, the Coast Guard is a part of the conversation with vessel owners/operators and their contracted SMFF resource provider(s) at the earliest stage in the VRP approval process. Through the awareness gained in completing the verifications, the Coast Guard is strengthened in its continued service to our Nation – not only in verifying industry’s preparedness and readiness to respond in the event a VRP is activated, but also in identifying impacts to VRPs resulting from changes in operational, environmental, and administrative factors faced by the maritime industry. Furthermore, the Coast Guard will continue to evaluate the SMFF verification procedure to account for changing conditions, as well as lessons learned through the verification effort.
A summary of SMFF verifications performed in conjunction with the review of VRPs for approval is posted to the Vessel Response Plan “What’s New?” Homeport page and will be updated on a quarterly basis.
If you have any questions or comments, please contact the VRP program staff 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.