Slaying the Paper Tiger

Abstract

ABSTRACT California's Oil Spill Response Organization (OSRO) and Plan-Holder Unannounced Drill Programs have provided an opportunity for state, Federal, and industry representatives to work together to ensure that the best achievable response for the State of California is attained. As a result of the success of these two initial programs, the Office of Spill Prevention and Response (OSPR) considers unannounced drills to be the cornerstone of response resource assessment. Unannounced drills present an opportunity to practice and improve how the OSROs and plan-holders (tank vessels, non-tank vessels, and facilities) respond to oil spills by testing contingency plans, reviewing the systems approach, and revealing issues that may hamper an oil spill response. The OSRO unannounced drills test the OSRO's response capabilities for the first six hours of a response, while the plan-holder drills test the owner/operator's ability to initiate a response to a spill incident, based on the owner/operator's contingency plan, for the first three hours of a response. Unannounced OSRO and plan-holder drills both require government agency notification, equipment activation and deployment, and response resources to be operated. Since the only way to evaluate how a plan-holder's team will respond in an emergency is to evaluate them in a non-emergency, adding the element of surprise allows the state to better make the determination as to the adequacy of their preparedness. Non-tank vessel, tank vessel, and facility operators are also required to conduct to plan-holder initiated drills, and these have also been highly successful. Part of the success of these drills is that they have revealed potential problems, for which plan-holder-initiated solutions or OSPR regulatory fixes have been identified and proposed. Through this process, the California Unannounced Drill Program has evolved from being planning standard-based to performance standard-based for OSROs. Under new legislation that reflects the OSRO performance requirements (Government Code 8670.29), plan-holders must now contract with one or more state-rated OSROs to meet contingency plan requirements and an OSRO will only be granted a state rating by participating in unannounced drills.