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U.S. Coast Guard – Vessel Response Plans for Non-Tank Vessels
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Published on March 23, 2005
On August 9, 2004, the President signed the Coast Guard and Marine Transportation
Act of 2004 which requires preparation and submission of oil response plans for nontank
vessels. All self-propelled U.S. or foreign vessels of 400 gross tons or greater,
other than tank vessels, that carry oil of any kind as fuel for main propulsion will be
required to have USCG approved Vessel Response Plans (VRPs) to operate on U.S.
navigable waters. Vessel operators will be required to have sufficient response
equipment to respond to fuel spills in addition to lightering and salvage equipment.
These response plans must be submitted to the US Coast Guard by August 8, 2005.
The Act requires the Coast Guard to promulgate regulations, which are not anticipated
to be published in the near future. However, recognizing the amount of time that it will
take to prepare these plans, the Coast Guard has released a Navigation and Vessel
Inspection Circular (NVIC) in advance of regulations to provide guidance on the
preparation of these plans and assist plan preparers in meeting the August 8, 2005
deadline.
We are sending this regulatory alert to offshore operators because it is anticipated that
much of the offshore vessel fleet (supply, work, and crew boats) will be required to
submit these plans. There is also confusion regarding the applicability of these
requirements based on tonnage measurements. The Coast Guard has noted that
operators of vessels currently measured only under U.S. regulatory tonnage should
bear in mind that a vessel typically has a higher tonnage when measured under
International Tonnage Conventions (ITC)
If you or your vessel contractor(s) have questions regarding these requirements, or
need assistance in preparing vessel response plans, please contact
Bea Stong or
David Lewis at (281) 578-3388.
Please feel free to forward this Regulatory Alert to your
vessel suppliers.
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