Meeting the compliance deadline - 30th January 2014

Although the US Coast Guard's deadline for submitting Vessel Response Plans (VRPs) is rapidly approaching, the time available to comply is even more compressed by the need to pre-contract with Qualified Individuals (QIs), Oil Spill Response Companies (OSROs), Dispersant service providers and salvors. Some local consultants have already advised that they require owners to secure their services within early December if they are to provide all the necessary arrangements in time for the 30th January 2014.

Essential guidance of Club circulars

Our recent circulars 19/13, 18/13, 17/13, 14/13 and 12/13 have advised Members on the requirements both country-wide and of individual states in respect of the Coast Guard Final Rule on VRPs and the 30th January 2014 deadline.  Members are reminded that such circulars include guidance on remaining within Club cover when complying with such requirements. 

For example Annex I of Circular 14/13 contains the Group guidelines on vessel response plans & use of salvors contracts for compliance.

Scroll down this page to view a collation of the relevant Club Circulars.

Club contact & support

Although the main contact at the Club is Dr Chao Wu (chao.wu@thomasmiller.com) in view of the short timescale for compliance and the intervening Chrismas and New Year holiday season Jacqueline Tan (jacqueline.tan@thomasmiller.com ) of London Syndicate 1 is also available to support Members' queries and need for assistance.

SMFF / VRP support Contracts

The Funding agreements of five salvors have been reviewed and found to conform with the International Group (IG) Salvage Guidelines on Vessel Response Plans. These five salvors agreements are listed below. Click on any record to download specimen copies of the relevant salvor's contract or other relevant documents.

Additional information

Other miscellaneous news and advisory information is posted in the right hand column of this page.

11/02/2014
Members are advised to take care to sign the updated WSMC enrolment agreement which is compliant with International Group guidelines ( Circular 22/13 ) and not earlier unapproved versions as described in Circular 17/13.

10/12/2013
These twenty or more 'frequently asked questions' include guidance on the Final Rule and its application, the contractual arrangements that need to be in place as part of VRP compliance and various points on remaining within cover. Updated 10th December 2013.

20/12/2013
Vessel operators issued monetary fines for non-compliance with tank vessel response plan regulations in Western Alaska

Salvor contracts & documentation

26/02/2014
An updated version of the Donjon-Smit Funding Agreement which has the following new footer: Donjon-Smit (Tanker and Non-Tank) Version B February 11, 2014 together with Annexes 1-5 has been uploaded to the Club website.

04/10/2013
Donjon Smit documents for use in Vessel Response Plan arrangements.  These documents should be read in conjunction with the earlier Club Circular 14/13  US Vessel Response Plans - Salvage & Marine Firefighting (SMFF) Requirements Final Rule - 30 September 2013. Deadline for implementation - 30 January 2014

16/10/2013
Marine Response Alliance documents for use in Vessel Response Plan arrangements.  These documents should be read in conjunction with the earlier Club Circular 14/13  US Vessel Response Plans - Salvage & Marine Firefighting (SMFF) Requirements Final Rule - 30 September 2013. Deadline for implementation - 30 January 2014

05/12/2013
The attached contract is conforming with International Group Vessel Response Guidelines and is referred to in Circular 19/13: "United States Vessel Response Plans - OSRO Contracts".

05/12/2013
The attached contract is conforming with International Group Vessel Response Guidelines and is referred to in Circular 19/13: "United States Vessel Response Plans - OSRO Contracts". 

05/12/2013
Members are recommended to strike out a requirement within this Addendum which is outside the International Group approval guidelines.  Circular 19/13 refers.

01/10/2013
Resolve Salvage & Fire documents for use in Vessel Response Plan arrangements.  These documents should be read in conjunction with the earlier Club Circular 14/13  US Vessel Response Plans - Salvage & Marine Firefighting (SMFF) Requirements Final Rule - 30 September 2013. Deadline for implementation - 30 January 2014

04/10/2013
T&T Salvage documents for use in Vessel Response Plan arrangements.  These documents should be read in conjunction with the earlier Club Circular 14/13  US Vessel Response Plans - Salvage & Marine Firefighting (SMFF) Requirements Final Rule - 30 September 2013. Deadline for implementation - 30 January 2014  

21/10/2013
Svitzer documents for use in Vessel Response Plan arrangements.  These documents should be read in conjunction with the earlier Club Circular 14/13  US Vessel Response Plans - Salvage & Marine Firefighting (SMFF) Requirements Final Rule - 30 September 2013. Deadline for implementation - 30 January 2014

UK Club Circulars

13/06/2014
The “Nontank Vessel Response Plans and Other Response Plan Requirements” (NTVRP) final rule  required owners or operators of nontank vessels 400 gt and above to submit oil spill response plans for vessels operating on the navigable waters of the United States by 30th January 2014. The Coast Guard used an Interim Operating Authorization (IOA) process to assist vessel owners and operators to meet thedeadline and continue to operate.

09/12/2013
Second issuance of Vessel General Permit (VGP) is effective from 19th December 2013 and will supersede the first iteration of VGP.  Vessels must file an Notice of Intent (NOI), by the 12th December 2013 or 7 days prior to discharge to continue uninterrupted coverage.  Notice of Intent must be submitted using EPA’s Electronic NOI system.  NOI submission deadlines and discharge authorization can be found in Annex II of this circular.  Club advice on VGP requirements was posted on our website on 19th November

05/12/2013
OUTLINE:  This circular refers to Circular 18/13 United States Vessel Response Plans. Copies of the appropriate MSRC and NRC contracts are attached as PDFs to the website version of this circular. US Coast Guard has issued a set of FAQs on Non Tank Vessel Response Plans (NTVRP).

29/11/2013
The Group clubs have terminated their retainer agreements with MSRC and NRC. Non-tank vessel operators should contract directly with MSRC or NRC in future. Both MSRC and NRC provide spill response contracts that conform with Group guidelines. MSRC have withdrawn their dispersant addendum to spill response contracts making purchase of extended cover unnecessary. NRC offer a fee-paying option to opt out of their addendum and avoid exposure to additional liabilities.

12/11/2013
OUTLINE: This circular concerns ships trading to Washington State waters.  All ships over 300 gross tons, and all tank ships, are required to file a Washington State oil spill contingency plan before entering Washington State waters. Washington State Maritime Co-operative’s (WSMC) ‘umbrella’ contingency plan still does not comply with International Group guidelines. National Response Corporation’s (NRC) ‘umbrella’ plan has now been approved by Washington State with effect from 1st November 2013. The NRC contingency plan is compliant with the International Group guidelines. The further Washington State requirement for enrolment for Emergency Response Towing Vessel (ERTV) services is still in place. All clubs in the International Group have issued similar circulars

16/10/2013
Owners of non-tank vessels with oil-carrying capacity of 2,500 barrels or greater must enter into funding agreements with marine salvors and fire-fighting resource providers.Owners of non-tank vessels with...

01/10/2013
Owners of non-tank vessels calling at US ports will be required to submit their Vessel Response Plan (VRP) by 30th January 2014.  This new requirement is being reviewed by the International Group and a more detailed circular will be issued in due course.

05/10/2012
US oil spill response organisations’ (OSROs) standard service agreements often include an addendum that does not comply with Group guidelines.  Members agreeing to such an addendum may incur liabilities that are outside Club cover.  National Response Corporation (NRC) is the latest OSRO to adopt such a non-compliant addendum to its service agreements.  Group guidelines on VRP service agreements and the addendum are published in Club Circular 6/09

26/08/2011
Under new US Coast Guard requirements, tank vessel response plans must cite an oil spill response organisation (OSRO) with capability for applying dispersants by air. MSRC has amended its service agreement for tank vessels by addition of a 'dispersant addendum' which contains indemnities that do not conform to the International Group's US VRP guidelines. Details of additional market cover are available from the Managers. No such addendum has been introduced by NRC at this time. There is no similar requirement for non tank vessels and most VRPs for non tank vessels are therefore unlikely to refer to dispersant capability in their citation of MSRC, in which case no action is required. Members should, however, confirm this by directly checking their VRPs or consulting their plan writers. 

22/02/2011
Dear Sirs, US Vessel Response Plans - Salvage and Marine Firefighting Requirements - Final Rule - 31 December 2008 - Deadline for implementation - 22 February 2011 - further...

US Coast Guard Authorization Act of 2010

The Coast Guard Authorization Act of 2010 has been enacted and took effect from the 15th October 2010. 
 
Generally, provisions are effective on the day of enactment unless legislation specifies otherwise. The following provisions are noted, as they may concern the Members:

  • Section 702 calls for the Coast Guard to enact new safeguards for, among other things, the transfer of oil, "within 1 year after the date of enactment."
  • Section 708, which provides added funds for NOAA and calls for various audits and reports is effective immediately, with deadlines for the audits and reports tied to the date of enactment.
  • Section 711 extends the dual tug escort requirements for single hull vessels to double hulled tankers in Prince William Sound effective 90 days after enactment. 
  • Section 712 specifies no effective date for its provisions broadening the applicability of OPA '90 financial responsibility requirements to any tank vessel over 100 gross tons. It should be assumed, therefore, that it became effective upon enactment.
  • Section 713, which makes the cargo owner a "responsible party" under OPA '90 in the event of an oil spill from a single hull tank vessel, is effective "after December 31, 2010."
  • Section 912, which limits the liability of vessel owner/operators and other people who use or authorize force to defend a US vessel against pirates is effective upon enactment.  Coast Guard regulations for the use of self-defense are due 180 days after enactment.

 

 

 

 

VRP news & advisories

26/11/2013
In a public statement of 8th November, the US Coast Guard Sector Anchorage announced increased enforcement of tank vessel response plan (VRP) requirements including monetary penalties for operators in violation of those federal regulations.

30/09/2013
New round of Vessel General Permit (VGP) to be enacted on the 19th December 2013.

30/09/2013
Advisory on Final Rule relating to Nontank Vessel  Response Plan requirements confirms 30 January 2014 VRP submission date.

Emergency Contacts


If you need to call our offices out of hours and at weekends, click After Office hours for a up to date list of the names of the Duty Executives and their mobile phone numbers. 

Ship Finder


This Ship Finder is updated on a daily basis. Members who need to advise the Club of updates to their recorded ships' details should advise their usual underwriting contact.