Appendix D to Part 154 - Training Elements for Oil Spill Response Plans
33:2.0.1.5.23.13.179.1.4 : Appendix D
Appendix D to Part 154 - Training Elements for Oil Spill Response
Plans 1. General
1.1 The portion of the plan dealing with training is one of the
key elements of a response plan. This concept is clearly expressed
by the fact that Congress, in writing OPA 90, specifically included
training as one of the sections required in a vessel or facility
response plan. In reviewing submitted response plans, it has been
noted that the plans often do not provide sufficient information in
the training section of the plan for either the user or the
reviewer of the plan. In some cases, plans simply state that the
crew and others will be trained in their duties and
responsibilities, with no other information being provided. In
other plans, information is simply given that required parties will
receive the necessary worker safety training (HAZWOPER).
1.2 The training section of the plan need not be a detailed
course syllabus, but it must contain sufficient information to
allow the user and reviewer (or evaluator) to have an understanding
of those areas that are believed to be critical. Plans should
identify key skill areas and the training that is required to
ensure that the individual identified will be capable of performing
the duties prescribed to them. It should also describe how the
training will be delivered to the various personnel. Further, this
section of the plan must work in harmony with those sections of the
plan dealing with exercises, the spill management team, and the
qualified individual.
1.3 The material in this appendix D is not all-inclusive and is
provided for guidance only.
2. Elements To Be Addressed
2.1 To assist in the preparation of the training section of a
facility response plan, some of the key elements that should be
addressed are indicated in the following sections. Again, while it
is not necessary that the comprehensive training program for the
company be included in the response plan, it is necessary for the
plan to convey the elements that define the program as
appropriate.
2.2 An effective spill response training program should consider
and address the following:
2.2.1 Notification requirements and procedures.
2.2.2 Communication system(s) used for the notifications.
2.2.3 Procedures to mitigate or prevent any discharge or a
substantial threat of a discharge of oil resulting from failure of
manifold, mechanical loading arm, or other transfer equipment or
hoses, as appropriate;
2.2.3.1 Tank overfill;
2.2.3.2 Tank rupture;
2.2.3.3 Piping rupture;
2.2.3.4 Piping leak, both under pressure and not under pressure,
if applicable;
2.2.3.5 Explosion or fire;
2.2.3.6 Equipment failure (e.g., pumping system failure, relief
valve failure, or other general equipment relevant to operational
activities associated with internal or external facility
transfers).
2.2.4 Procedures for transferring responsibility for direction
of response activities from facility personnel to the spill
management team.
2.2.5 Familiarity with the operational capabilities of the
contracted oil spill removal organizations and the procedures to
notify the activate such organizations.
2.2.6 Familiarity with the contracting and ordering procedures
to acquire oil spill removal organization resources.
2.2.7 Familiarity with the ACP(s).
2.2.8 Familiarity with the organizational structures that will
be used to manage the response actions.
2.2.9 Responsibilities and duties of the spill management team
members in accordance with designated job responsibilities.
2.2.10 Responsibilities and authority of the qualified
individual as described in the facility response plan and company
response organization.
2.2.11 Responsibilities of designated individuals to initiate a
response and supervise response resources.
2.2.12 Actions to take, in accordance with designated job
responsibilities, in the event of a transfer system leak, tank
overflow, or suspected cargo tank or hull leak.
2.2.13 Information on the cargoes handled by the vessel or
facility, including familiarity with -
2.2.13.1 Cargo material safety data sheets;
2.2.13.2 Chemical characteristic of the cargo;
2.2.13.3 Special handling procedures for the cargo;
2.2.13.4 Health and safety hazards associated with the cargo;
and
2.2.13.5 Spill and firefighting procedures for cargo.
2.2.14 Occupational Safety and Health Administration
requirements for worker health and safety (29 CFR 1910.120).
3. Further Considerations
In drafting the training section of the facility response plan,
some further considerations are noted below (these points are
raised simply as a reminder):
3.1 The training program should focus on training provided to
facility personnel.
3.2 An organization is comprised of individuals, and a training
program should be structured to recognize this fact by ensuring
that training is tailored to the needs of the individuals involved
in the program.
3.3 An owner or operator may identify equivalent work experience
which fulfills specific training requirements.
3.4 The training program should include participation in
periodic announced and unannounced exercises. This participation
should approximate the actual roles and responsibilities of
individual specified in the plan.
3.5 Training should be conducted periodically to reinforce the
required knowledge and to ensure an adequate degree of preparedness
by individuals with responsibilities under the facility response
plan.
3.6 Training may be delivered via a number of different means;
including classroom sessions, group discussions, video tapes,
self-study workbooks, resident training courses, on-the-job
training, or other means as deemed appropriate to ensure proper
instruction.
3.7 New employees should complete the training program prior to
being assigned job responsibilities which require participation in
emergency response situations.
4. Conclusion
The information in this appendix is only intended to assist
response plan preparers in reviewing the content of and in
modifying the training section of their response plans. It may be
more comprehensive than is needed for some facilities and not
comprehensive enough for others. The Coast Guard expects that plan
preparers have determined the training needs of their organizations
created by the development of the response plans and the actions
identified as necessary to increase the preparedness of the company
and its personnel to respond to actual or threatened discharges of
oil from their facilities.
[CGD 91-036, 61 FR 7938, Feb. 29, 1996]