Revisions to the OSRO and Prep Guidelines: What's that about?1

Abstract

ABSTRACT The Coast Guard's Oil Spill Removal Organization (OSRO) Classification Program Guidelines and National Preparedness for Response Exercise Program (PREP) Guidelines are periodically reviewed and revalidated. The OSRO program, managed by the National Strike Force Coordination Center (NSFCC), affords plan holders relief from having to include extensive equipment lists within already lengthy plans. It also gives government plan reviewers a national standard against which to evaluate response contractors listed in plans. The PREP Guidelines offer a cycle of internal and external exercises to be followed in the preparedness cycle of plonning and assessment by government and industry members of the response community. For years, these programs enjoyed support from both government and industry. Recently, however, response community rumblings revealed growing doubt about the usefulness of these standards in assuring response readiness. This skepticism threatened to undermine both programs. The government responded by engaging industry through a series of meetings and public workshops to examine concerns and identify solutions. In the process, two critical findings revealed what had changed: 1) While initial regulatory momentum was high following enactment of the Oil Pollution Act of 1990, industry and government plan holder focus had been slowly diverted to competing priorities; 2) The OSRO and PREP Guidelines, originally envisioned as tools to guide plan holders, had become a vehicles for plan holder acceptance of NSFCC evaluations of OSRO adequacy without local user analysis, and of OSRO exercises as sufficient without plan holder participation or oversight. The Coast Guard's response has been to overhaul each program's policy guideline to clarify the original intent of the response plan regulations. The success of these efforts hinges on their effectiveness to reemphasize that ultimate accountability falls on the shoulders of plan holders at the local level under active government oversight.