CAN OIL SPILL RESPONSE PLANS BE FUNCTIONAL AND REGULATORY COMPLIANT?

Abstract

ABSTRACT In the event of an oil spill, rapid and effective response actions are the key to minimizing impacts to the environment and local communities. Consequently, oil spill response plans (OSRPs) should be prepared in a user friendly format that maximizes access to crucial information and focuses on the critical first few hours or days of a response. While existing OSRPs are generally adequate, they typically are not organized logically and contain fairly general information that focuses on the overall response rather than the initial stages. For many plan holders the primary, or in some cases the only, objective when preparing OSRPs is obtaining regulatory approval and believe there is little latitude in deviating from the format or content of previously approved plans to make them more functional. Following the 2010 Macondo incident in the Gulf of Mexico, the American Petroleum Institute (API) sponsored Joint Industry Task Force (JITF) identified the need to enhance the usefulness of OSRPs. A workgroup was convened consisting of representatives from integrated and independent oil companies and spill response planning consultants to develop a guidance document for preparing OSRPs that are highly functional and regulatory compliant. The JITF guidance document includes a detailed OSRP outline that provides the intended purpose and recommended content and format for each section. The primary features include:Information presented in the general order required when responding to an oil spillFocus is on the first 24 hours when guidance is needed the mostKey information is provided in tabular or graphical formats at the front of each sectionInitial responder health and safety issues are addressed that are often missing in OSRPsSimilar information is located in the same section to avoid searching multiple sectionsMore expansive and detailed information, response guidance and specific cleanup strategies are referenced, as appropriate, in other documents The guidelines were designed to be Gulf of Mexico centric with the concepts being applicable to all industry sectors and regions of the world. Similar to the Integrated Contingency Plan concept developed in 1996, they can be adapted to comply with multiple oil spill planning regulations. They were, however, designed specifically to comply with the Bureau of Safety and Environmental Enforcement (BSEE) 30 Code of Federal Regulations (CFR) Part 254 and Notice to Lessees NTL 2012-N06. The draft guidelines were reviewed and well received by BSEE and the few regulatory compliance issues they identified were addressed in the final document. Therefore, it is possible to prepare OSRPs that are both functional and regulatory compliant.