Salvage and marine firefighting requirements for oil spill prevention |...

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Salvage and marine

firefighting requirements
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Marine environmental protection is one of the Coast Guards core missions,

and the Coast Guard remains committed to ensuring that U.S. waters are
protected by a robust oil spill response network. While traditional oil spill
response assets are critical to this network, salvage and marine firefighting
services are also important in mitigating the risk of oil spills.

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The Oil Pollution Act of 1990 requires certain ships to have vessel response plans (VRPs). Vessel owners
and operators are charged with identifying spill response resources by contract or other approved means,
capable of being on-scene within established timeframes. Because ships move from port to port, owners
identify response resources in each captain of the port zone for their area of operations. The number of
spills and volume of oil spilled in U.S. waters has substantially decreased with the development of response
capability and processes that were implemented for tank vessels by industry and the Coast Guard together.

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SMFF services.
Originally applicable to tank vessels, it became apparent that oil spill risks from non-tank vessels increased
as the vessels grew in size. In 2013, SMFF services became a required component for non-tank VRPs as

3 March 2015

The documentation process required to capture information for 19 distinct SMFF services in up to 41
captain of the port zones places an administrative burden on the VRP community. The Coast Guard worked
to resolve this burden through the establishment of Coast Guard protocol for incorporating repetitive
Geographic-Specific Appendix (GSA) information into VRPs by reference. The core GSA approach resulted
in a significant savings in time for both the development and review of VRPs. Those VRPs not incorporating
core GSAs by reference are required to include complete SMFF listings.
To ensure SMFF providers submitted complete and accurate SMFF resource capabilities, as required by
VRPs, the Coast Guard instituted a verification program to review each core GSA from 2011 through 2013.
Quarterly reviews focused on a subset of related resource services (e.g. firefighting services or emergency
towing services) and led to the discovery, and correction, of shortfalls in emergency towing vessel and
firefighting resources coverage among other services. The review and subsequent corrective actions
improved the overall quality of submitted information.
In order to follow up on the Coast Guards initial round of engagement, a full verification of the SMFF core
GSA service providers for all 19 SMFF services will be initiated in 2016. The objectives of the 2016
verification are to ensure that resource providers (1) meet SMFF planning and service/capability standards
identified in regulation; and (2) can deliver resources/services within regulatory time windows. Unlike the
2011 verification, Coast Guard Headquarters will engage directly with the four core GSA providers rather
than using Coast Guard districts and sectors to verify the planning considerations for services/capabilities in
each captain of the port zone.
Verifying the four core SMFF providers addresses SMFF planning for almost all VRP-required vessels
calling in U.S. ports. Verification of the remaining SMFF providers will follow. If a service provider is found,

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well. Today, all vessels which must have a VRP are required to plan for SMFF response services as part of
their VRP.
The vessel owner / operator is responsible for determining the adequacy of the resource providers included
in their response plan, and must certify in the VRP that the identified SMFF provider meets regulatory
criteria. The Coast Guard is responsible for review of the VRPs and notifies the vessel owner / operator of
VRP approval, or that the VRP does not meet all the requirements. The applicable regulations for plan
approval, review, amendment and appeal are found in 33 CFR 155.1065 and 155.1070 (tank vessels)
and 33 CFR 155.5065 and 155.5070 (non-tank vessels).

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The following article provides a brief background of the Coast Guards role in vessel planning for salvage
and marine firefighting response and current activity related to implementation of recent salvage and
marine firefighting regulations:

Timely response activities are key to preventing the escalation of incidents. Because salvage and marine
firefighting expertise can both prevent oil spills and minimize threats of spills from escalating, the same VRP
resource planning principles were put into place for salvage and marine firefighting services. A long and
collaborative development process led to the identification of various distinct salvage and marine
firefighting (SMFF) services for assessment, stabilization and special operations. This consultative process
resulted in the promulgation of regulations that went into effect in 2009, requiring tank vessels to plan for

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through the course of the 2016 verification, unable to meet the planning standards in a particular COTP
zone, they will have a reasonable opportunity, as determined by the Coast Guard, to correct shortfalls or
remove a service. The Coast Guard will no longer issue conditional acceptances of core GSAs.

progress has been made throughout the United States to address vulnerabilities. The progress that has
been realized is a direct function of a steady and proactive partnership between the Coast Guard and the
salvage industry, which has remained intent on growing capacity and ensuring compliance across U.S.
ports. Going forward, this partnership, coupled with the 2016 verification effort, will serve to continue that
progress, grow SMFF response capability, increase preparedness and reduce risk in the marine
environment.

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While the full scope of the SMFF regulatory regime remains relatively new, it is clear that significant

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