Release of 2016 National Preparedness for Response Exercise Program (PREP) Guidelines
As we have previously advised our clients, the implementation of the Salvage and Marine Firefighting (SMFF) Regulations (33 CFR 155 Subpart I) and the Nontank Vessel Response Plan Final Rule (33 CFR 155 Subpart J) added drill and exercise requirements for vessel response plan holders and covered vessels. The USCG provides industry guidance for drills and exercises through the National Preparedness for Response Exercise Program (PREP) Guidelines, which were last updated in 2002.
After an extensive review of the new drill and exercise requirements, which included comments and feedback from ECM and other industry sources, the USCG released the 2016 PREP Guidelines.
ECM utilizes the PREP Guidelines when constructing our annual exercise program. Doing so ensures that all of our clients (plan holders) are in full compliance with the drill and exercise requirements under the Oil Pollution Act of 1990 (OPA 90) and the California regulations.
Impacts to your Vessel Response Plans
The vessel response plans (VRPs) will be revised to update changes in terminology as amended in the 2016 PREP Guidelines, and to include information regarding the new required exercises. The term “spill management team” or “SMT” has been replaced by the term “incident management team” or “IMT”. The term “tabletop exercise” or “TTX” has also been replaced with the term “exercise”, (although the term “TTX” continues to be used in the 2016 PREP Guidelines). These and other changes regarding the new exercise requirements will impact the “Exercises” chapter of the VRPs, which ECM will amend in due course. These changes to the VRP do not impact the approval status of the plan.
The new guidelines also include the addition of the following three (3) new significant exercise requirements involving owners/operators (plan holders), vessels and contracted SMFF resource providers:
- The vessel owner/operator, vessel master, or designee will now be required to conduct an annual “remote assessment and consultation exercise” with the contracted SMFF resource provider.
The objectives of this exercise include:
- The review of a general scenario type from the VRP’s shipboard emergency procedures (i.e., collision, excessive list, fire, grounding, etc.);
- A discussion with the contracted SMFF provider to facilitate a preliminary assessment of the vessel’s status; and
- Given the scenario, the completion of the vessel’s stability and structural integrity assessment through the use of a salvage software program.
2. The plan holders must conduct an annual “shore-based salvage exercise” with their contracted SMFF provider.
3. The plan holders must conduct an annual shore-based “marine firefighting exercise” with a focus on the decision-making management in a marine firefighting response.
The purpose of this article is to provide you with a basic overview of these new requirements. ECM will contact each of the SMFF providers to review their individual approaches to providing compliance for our mutual clients and to offer our recommendations for an effective, streamlined and coordinated solution to the maximum extent possible. You may also receive guidance directly from your contracted SMFF provider.
Rest assured that additional information will be forthcoming. We also intend to address these new requirements during our upcoming annual 2016 SMT TTX – now known as the 2016 IMT Exercise Program.
PREP Guidelines (select the “Port Level Exercises” link)
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