Developing a regulatory framework for certifying spill management teams in California: a balancing act

Abstract

ABSTRACT 1141476 Major oil spills in California have historically instigated legislation aimed at improving preparedness and response. Most recently, public concern over management of high-profile pipeline spills precipitated the 2017 passage of Assembly Bill (AB) 1197, which mandated a certification program for spill management teams (SMTs). AB 1197 directs contingency plan holders to identify a certified SMT capable of managing their reasonable worst-case spill (RWCS) volumes, and tasks the Office of Spill Prevention and Response (OSPR) with adopting regulations establishing criteria for certification, including personnel on-scene times, training, and response objectives. We aimed to develop regulations detailing requirements that are achievable, but effectively advance preparedness, drawing upon accepted standards while incorporating mechanisms for flexibility. As we developed the regulations, we conducted informal scoping meetings with industry to fine-tune these mechanisms. We created three tiers for certification delineated by RWCS volume. To account for phased resource mobilization, we established separate requirements for initial response and cascading SMT personnel. We applied team-based training requirements to initial responders and used pared-down National Incident Management System qualifications for cascading personnel, allowing equivalent courses and/or experience to substitute for required training courses. We composed a short objectives checklist, aiming to capture essential tasks to be completed within the first 24 hours. The final regulatory package strikes balances between flexibility and prescription, and between achievability and advancing statewide preparedness.