Appendix C to Part 155 - Training Elements for Oil Spill Response Plans
33:2.0.1.5.24.12.179.1.7 : Appendix C
Appendix C to Part 155 - 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 the Oil Pollution Act of
1990, 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 training
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 C 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
vessel 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 -
2.2.3.1 Operational activities associated with internal or
external fuel and cargo transfers;
2.2.3.2 Grounding or stranding;
2.2.3.3 Collision;
2.2.3.4 Explosion or fire;
2.2.3.5 Hull failure;
2.2.3.6 Excessive list; or
2.2.3.7 Equipment failure.
2.2.4 Procedures and arrangements for emergency towing.
2.2.5 When performing shipboard mitigation measures -
2.2.5.1 Ship salvage procedures;
2.2.5.2 Damage stability; and
2.2.5.3 Hull stress considerations.
2.2.6 Procedures for transferring responsibility for direction
of response activities from vessel and facility personnel to the
spill management team.
2.2.7 Familiarity with the operational capabilities of the
contracted oil spill removal organizations and the procedures to
notify and activate such organizations.
2.2.8 Familiarity with the contracting and ordering procedures
to acquire oil spill removal organization resources.
2.2.9 Familiarity with the Area Contingency Plans.
2.2.10 Familiarity with the organizational structures that will
be used to manage the response actions.
2.2.11 Responsibilities and duties of the spill management team
members in accordance with designated job responsibilities.
2.2.12 Responsibilities and authority of the qualified
individual as described in the vessel response plan and company
response organization.
2.2.13 Responsibilities of designated individuals to initiate a
response and supervise shore-based response resources.
2.2.14 Actions to take, in accordance with designated job
responsibilities, in the event of a transfer system leak, tank
overflow, or suspected fuel or cargo tank or hull leak.
2.2.15 Information on the oil handled by the vessel or facility,
including familiarity with -
2.2.15.1 Cargo material safety data sheets (including oil
carried as fuel);
2.2.15.2 Chemical characteristics of all oils carried as fuel or
cargo;
2.2.15.3 Special handling procedures for all oils carried as
fuel or cargo;
2.2.15.4 Health and safety hazards associated with all oils
carried as fuel or cargo; and
2.2.15.5 Spill and firefighting procedures for all oils carried
as fuel or cargo.
2.2.16 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 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
vessel 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
individuals as specified in the response 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 vessel 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 vessels 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 vessels.
[CGD 91-034, 61 FR 1107, Jan. 12, 1996, as amended by
USCG-2008-1070, 78 FR 60135, Sept. 30, 2013]