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.
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
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).
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 MSRC have withdrawn their dispersant addendum to spill response contracts making purchase of extended cover unnecessary.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.
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
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 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.
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
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.
Dear Sirs, US Vessel Response Plans - Salvage and Marine Firefighting Requirements - Final Rule - 31 December 2008 - Deadline for implementation - 22 February 2011 - further...