Non-tank Vessel Response Plans in accordance with NVIC 01-05
are now offered in our suite of services. Learn more about this
new regulation and let Hudson be your guide.
This new NVIC No. 01-05 circular is meant to provide guidance to owners and operators of non-tank vessels for preparing and submitting plans for responding to a discharge, or threat of a discharge, of oil from their vessels.
Until Non-Tanker regulations are in effect, the Coast Guard may authorize a Non-Tank Vessel to operate without an approved vessel response plan until two years after the date of submission to the Coast Guard of a plan if the owner or operator certifies that he has ensured by contract or other means approved by the Coast Guard the availability of private personnel and equipment necessary to respond to a worst case discharge (WCD) or substantial threat of such a discharge.
The Vessel Response Plans must:
Be consistent with the requirements of the National Contingency Plan and Area Contingency Plan.
Identify the Qualified Individual (QI) having full authority to implement removal actions, and require immediate communications between that individual and the appropriate federal official and the persons providing personnel and equipment pursuant to Item No. 3 below.
Identify and ensure by contract or other means approved by the Coast Guard the availability of private personnel and equipment necessary to remove to the maximum extent practicable to a WCD (including a discharge resulting from fire or explosion) and to mitigate or prevent a substantial threat of such a discharge.
Describe the training, equipment testing, periodic unannounced drills and response actions of persons on the vessel, to be carried out under the plan to ensure the safety of the vessel and to mitigate or prevent the discharge or the substantial threat of a discharge.
Be updated periodically.
Be resubmitted for approval of each significant change.
In the event regulations are not in effect on August 8, 2005, the Coast Guard may issue a two-year authorization letter authorizing a non-tank vessel to operate without an approved response plan if the plan submitted meets the requirements of Item No. 3 above. If the Coast Guard cannot review all the plans by August 8, 2005, in sufficient detail for a two-year authorization letter, it may issue an interim authorization letter. The Coast Guard encourages vessel owners and operators to submit response plans as soon as possible to avoid a disruption of operations.
Until superseded by regulations, non-tank vessels must have a valid authorization or interim authorization letter in order to operate on or after August 8, 2005. We have recently been informed that the review and approval period for the OPA 90 Non-Tank Vessel Response Plan will be 60 days, due to the large number of plans expected to be submitted. We therefore strongly urge all owners/operators of Non-Tank Vessels operating or expected to operate in US waters on or after August 8, 2005 to immediately commence planning to develop OPA 90 Non-Tank Vessel Response Plans. If a non-tank vessel is not in compliance by August 8, 2005 it may be severely delayed or in the worst case denied entry into US waters.
For additional information about the new NVIC No. 01-05 circular, please contact Hudson Marine.
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