Alaska – Tank vessel response plan compliance to be more strictly enforced

Alaska – Tank vessel response plan compliance to be more strictly enforced

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.

Tank vessels bound to or from a United States port and transiting through the Western Alaska Captain of the Port (COTP) Zone* must have an approved Geographic Specific Appendix in their VRP for Western Alaska prior to transiting or operating within that zone if carrying oil in bulk as cargo or oil cargo residue.

Owners failing to comply with “Title 33 Code of Federal Regulations Part 155 Subpart D” face a monetary penalty of up to $11,000 per violation, per day.

Compliance with Alternative Planning Criteria

In 2012 no organisation in the Western Alaska zone was capable of supplying the oil spill response equipment required for VRPs by the US Coast Guard. An Alternate Planning Criteria (APC) was established by the Alaska Maritime Prevention & Response Network to enable tank vessels operating in Western Alaska to comply with an appropriate alternative to the criteria established under Title 33 Code of Federal Regulations Part 155.

This APC provided a series of risk reduction measures that all tankers transiting these waters en route to or from a US port must comply with effect from 31st March 2012. These alternative criteria have been reviewed and revised since 2012.  The latest edition ( April 2013) are attached in PDF form at the head of this web page.

In addition to APC compliance those tankers transiting en route to or from US ports must submit

a) proof of contract – usually a “Certificate of Participation” with the Alaska Maritime Prevention and Response Network

b) proof of contract with Alaska Chadux

Tankers transiting these waters without a US port call are considered to be on innocent passage and are not required to comply.

The Club’s previous Circular 7/12: New Vessel Response Plan requirement in Alaska - Alternative Planning Criteria (APC) gave a briefing on this development when it first arose.


Alaska Maritime Prevention and Response Network is a non-profit organization established to provide the capabilities required to implement the WA-APC’s prevention and response measures to protect Alaska waters from environmental harm.

Alaska Chadux Corporation (Chadux) is a member-funded, 501(c)(4) not-for-profit oil spill response organization headquartered in Anchorage, Alaska. Chadux is classified as an Oil Spill Removal Organization (OSRO) by the US Coast Guard and registered as Primary Response Action Contractor (PRAC), and a Non-tank Vessel Cleanup Contractor (NTVCC) with the State of Alaska.

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