823 - 05/12 - Non-tank Vessel Response Plan (NTVRP) UPDATE - USA
GMS recently contacted the Vessel Response Plan - Program office at USCG Headquarters to inquire about the status of the NT VRP rule. The VRP program office confirmed that they had finished the regulations and sent them to the Secretary of Homeland Security for their review/comment and final authorization to be published. Presently, there is no indication if the review has started or when it will be finished. Further, there is no timeline indicating when the regulations will be published. We will continue to communicate with USCG Headquarters and will keep you advised accordingly.
A non-tank vessel is described as a self-propelled vessel of 400 gross tons or greater that operates on the navigable waters of the U.S. carries oil of any kind as fuel for main propulsion and is not a tank vessel.
COMPLIANCE RECOMMENDATION:Although the NTVRP rule is not yet final, non-tank vessels are required to hold current NT VRPs which are required to be followed while in U.S. waters. This includes, among other things,
- Completing qualified individual (QI) notification
- Perform and document Shipboard Emergency Procedures Exercises
- Perform and document an annual Table Top Exercise
NTVRP Regulatory Timeline: www.reginfo.gov/public/do/eAgendaViewRule?pubId=201110&RIN=1625-AB27Interim Guidance for Development of the NTVRP:
www.uscg.mil/hq/cg5/nvic/pdf/2005/NVIC
%2001-05,%20CH-1.pdf
Federal Register Vol 73, No. 121 - June 23, 2008 (USCG Enforcement of 2004 Act)www.gpo.gov/fdsys/pkg/FR-2008-06-23/pdf/E8-14115.pdfUnquote
The Club would advise Members with American interests to make themselves familiar with the interim guidance given in the links above so to soften the impact of the final ruling when it is published.
Source of Information:Gallagher Marine Systems LLC
New Jersey, USA
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