Preparedness Assessment Visits (PAVs)
The NSFCC’s primary mechanism for assessing the environmental emergency response capabilities of a region is the Preparedness Assessment Visit (PAV Process). Each year, PAV’s are planned to correspond with the 6 scheduled national government-led PREP exercises. Even if a PREP exercise is cancelled due to a COTP receiving credit for response to an actual event, NSFCC will still conduct the PAV, unless directed otherwise by the COTP. Additional PAV’s may also be conducted at the written request of a COTP or other key federal decision-maker, schedule permitting.
A PAV typically includes an in-brief with the COTP or alternate COTP in order to ensure specific concerns are addressed during the conduct of the visit itself. The NSFCC visit team will also conduct an OSRO classification guidelines training session for all interested parties, to include industry and government entities. During the PAV site visits, the NSFCC identifies and characterizes the emergency response equipment holdings, personnel training records, and equipment maintenance records of classified OSROs. Other government agencies and other emergency response organizations (ex. Marine salvage, hazardous materials release response, non-classified oil spill response organizations) that may be able to provide key emergency response capabilities to the COTP will also be visited. At the conclusion of the PAV, NSFCC will provide an out-brief with the COTP or alternate COTP to discuss the PAV findings. These findings will also be submitted to the COTP in a formal written after-action report within 45 days of the conclusion of the PAV.
OSRO Classification Program
The OSRO classification program was created in response to new regulatory requirements established by OPA 90. The program is completely voluntary and its purpose is to assist oil-handling facilities and vessels in writing spill response plans. By listing a Coast Guard classified OSRO in a response plan, the plan holder is exempted from providing and updating extensive lists of response resources. This remains the only regulatory benefit that plan holders receive from using a classified OSRO. The program is simply a tool that helps plan holders meet statutory requirements set forth in 33 CFR 154 and 155. An OSRO that does not have a Coast Guard classification may still be employed by a plan holder and may be listed in the plan, but must be listed along with its entire emergency response resource inventory.
This voluntary program provides a measurement of the degree of capability of an OSRO using variables such as the amount and type of equipment, its geographic location, and the OSRO's degree of control over its response resources (whether the resources are owned or contracted). The classification part of the program is only a planning tool and DOES NOT GUARANTEE THE PERFORMANCE of an OSRO. This program does not relieve the plan holders (facility or vessel) of their responsibility to determine whether an OSRO will meet specific planned response needs as required by 33 CFR 154 and 155.
Plan holders are encouraged to contact their local Captain of The Port (COTP) via Sector or Marine Safety Unit (MSU) with any questions concerning the regulations as set forth in 33 CFR 154 and 155 and how they apply to a certain facility or vessel.
The RRI, an extensive OPA-90 mandated database maintained by the Coast Guard to provide a centralized listing of the national and international spill response capabilities, contains the OSRO classification information along with its other response resource data. All classified OSRO resources are automatically input into the database, but any emergency response company or local/state/federal entity may elect to have its resources listed. Various government agencies, scientific organizations, or civilians may request this information from the Coast Guard by submitting a Freedom of Information Act (FOIA) request.
Differences in OSRO Classifications
OSROs may receive classifications for four different spill sizes (Maximum Most Probable Discharge (MMPD), Worst Case Discharge (WCD) Tier 1, WCD Tier 2, and WCD Tier 3) in six different operating areas (Rivers /Canals, Inland, Great Lakes, Near Shore, Offshore and Open Ocean). Spill sizes and operating areas are defined in the Coast Guard OSRO Classification Guidelines (draft). OSROs are classified for operation in up to 42 COTP zones and 10 Alternative Classification Cities (ACC's) . Classifications are based upon minimum equipment amounts and response time standards outlined in the Coast Guard OSRO Classification Guidelines (draft). Response travel times are calculated by measuring the straight line (great circle) distance between the latitude and longitude of an OSRO's individual resource site and the latitude and longitude of the CG COTP office or ACC. The response travel time to cover the straight line distance is then calculated using a speed of 35 MPH over land, 5 KTS over water, or 100 KTS airspeed.
Response travel time in the Near Shore area is calculated to a reference point located 12 nautical miles seaward from the boundaries as specified in 46 CFR 7 and modified with the CG Sector structure reorganization. The response travel time in the Offshore area is calculated to a reference point located 38 nautical miles seaward of the outer boundary of the Near Shore area. The response travel time in the Open Ocean area is calculated to a reference point located 150 nautical miles seaward of the outer boundary of the Offshore area, to include the Exclusive Economic Zone.
The total response time needed for equipment and personnel to move from its staging site to a CG COTP city or ACC is the sum of the response travel time, notification time, and mobilization time.
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