Tom Millet

Meeting response plan timeframes

Advancing plan writing methods with the aid of technology / By Tom Millet

Meeting regulatory compliance timeframes for vessels calling at ports in the United States has been an ongoing challenge for vessel owner/operators in recent years. The United States Coast Guard (USCG) requires up to 60 days to review and approve new Vessel Response Plans (VRPs) and up to 30 days to approve updates to existing plans. In practice, average approval timeframes are often between two to four weeks. However, largely due to fluid voyage schedules and tight budgets, many VRP holders continue to struggle with the timeframe requirements to receive full VRP approvals prior to their vessels’ arrivals in the US. To combat these challenges, the use of technology in the plan writing process and the issuance of one-time waivers by local USCG Sectors have been crucial.

Advancing plan writing methods with the aid of technology are helping plan holders better meet USCG timeframes. For example, Witt O’Brien’s VesselPro™ Service Request Tracking feature allows plan holders to enter vessel information and plan update requests from anywhere around the world at any time. This ability to help plan holders in any time zone walk through the compliance process aids quicker plan submissions, and in return, quicker regulatory approvals.

When planning timeframes cannot be met, one-time VRP waivers can often be used to allow vessels to maintain their voyage schedules and call US waters while their VRP is still being reviewed. A one-time waiver is a regulatory option that allows the local USCG Captain of the Port (COTP) to authorize a vessel’s entry into their zone while the vessel is awaiting VRP authorization from USCG headquarters. There are risks involved with this option, and it is certainly not a guaranteed solution. The decision to grant a waiver or not is at the discretion of the local COTP, and each zone handles these requests differently.

Even if granted, the interpretation of what operations are allowed under a one-time waiver can vary in some COTP Zones based on geographical specific risks and impacts taken into consideration by local USCG leadership.

Additionally, as the name suggests, a one-time waiver may only be granted to a vessel once from each COTP Zone. Once the vessel departs from that zone, they may not re-enter until the full VRP approval has been issued.

It is important for plan holders to know that some areas, like Guam, American Samoa, and Alaska, require additional local coverages that can also be time sensitive. So even if a vessel does have an approved VRP, additional updates and approvals may be required, and the regulatory timeframes again come into play. Knowing the regulatory requirements in advance for areas vessels will be calling can often be half the battle.

Despite these risks involved, overall, the USCG has been incredibly helpful and understanding with the issuances of one-time waivers, and we have seen much positive cooperation to allow commerce to continue when planning timeframe requirements cannot be met.

Communication between industry and local regulatory authorities as an answer to regulatory timeline challenges is of increasing importance for oil spill response planning and preparedness.

We continue to stress the need for vessel owner/operators to remain aware of the latest coverage requirements for areas their vessels will be calling and take approval timeframes into account when planning their vessels’ voyages. Witt O’Brien’s is always here to help if you have any questions or need assistance getting your vessels into compliance for US operations.

Email: TMillet@wittobriens.com

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