The OSRO Classification Program: Implementation of New Guidelines and its Impact on Industry Planholders and the US Coast Guard after September 11, 20011

Abstract

ABSTRACT The Coast Guard's Oil Spill Removal Organization (OSRO) classification underwent a significant revision in April 2001 and its implementation demanded a genuine combined effort by all stakeholders after September 11, 2001. The 2001 revision eliminated the Average Most Probable Discharge (AMPD) classification from the National Strike Force Coordination Center (NSFCC) planning criteria and placed this responsibility on the plan holders and their OSROs. This revision also introduced the concept of Notification and Mobilization Times in an effort to align the new guidelines with the 33 Code of Federal Regulations (CFRs) 154 and 155. These two factors, combined with a shift on mission priorities after the national incidents of September 11, created a major challenge in the OSRO guidelines implementation and training process. These new guidelines increased some of the minimum Boom, Effective Daily Recovery Capacities (EDRC) and Temporary Storage Capacity (TSC) requirements for two higher-level classifications Maximum Most Probable Discharge (MMPD) and Worst Case Discharge (WCD) at Tiers 1, 2, and 3. Consequently, the new guidelines had the potential to de-classify some existing OSROs and cause loss of classifications across operating areas: 41% for River/Canal, 38% for Inland, 60% for Great Lakes and 30% for Nearshore, Offshore and Open Ocean. The main cause for loss of classification was the regulatory mobilization time requirements for MMPD and WCD at Tier 1. This paper describes the process the NSFCC applied in order to accomplish the re-classification of 140 OSROs and the major issues that impacted all stakeholders: facility and vessel plan holders, Captains of the Ports (COTPs), OSROs and the NSFCC. Despite a twelve-month delay in the implementation timeline, the new guidelines were adjusted to reflect OSRO national response capability, allowing vessel and facility operators to fulfill the mandatory response planning criteria under the Oil Pollution Act of 1990 (OPA 90).