The United States Coast Guard has issued notice that it intends to conduct unannounced oil spill drills on vessels in the Port of New Orleans Zone, which includes Baton Rouge, New Orleans, and Plaquemines. The drills are designed to meet the Oil Pollution Act of 1990 (OPA-90)’s requirement for exercises to ensure the quality of oil spill vessel response plans (VRP) and crew execution of those plans.
The most important aspect of this new program is the fact that the crew will not get prior notice of the drill. Instead, a Coast Guard representative will arrive onboard and present a scenario to the crew, and then evaluate the crew’s response on a pass/fail basis, similar to a fire drill during a routine inspection.
As part of the drill, the crew will be expected to immediately locate the vessel response plan and carry out its instructions. This will include actually notifying the vessel’s qualified individual (QI) and designated person ashore (DPA). The QI and DPA will be responsible for contacting a local oil spill removal organization to attend the vessel and actually deploy spill containment equipment such as booms.
The cost of the drill response, including the deployment of equipment, will be on the vessel owner. Additionally, if the Coast Guard conducts an oil spill drill, the vessel must maintain the drill records on the vessel for three years.
A link to a copy of the Coast Guard’s announcement is attached below.
If you have any question regarding the Coast Guard’s oil spill drills or any other regulatory requirements of the Oil Pollution Act of 1990, please contact any member of the Phelps Dunbar Marine and Energy Practice Group.