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 (firstname.lastname@example.org) in view of the short timescale for compliance and the intervening Chrismas and New Year holiday season Jacqueline Tan (email@example.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.
Other miscellaneous news and advisory information is posted in the right hand column of this page.
Salvor contracts & documentation
UK Club Circulars
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.