Hopefully you made the Jan. 30 deadline to submit your Nontank Vessel Response Plan (NTVRP) to the Coast Guard.

On Jan. 31, all old nontank vessel response plans were to be deactivated, the Coast Guard said. That’s because the long awaited final rule for the nontank vessel response plan regulations were finally published Sept. 30, 2013. The old nontank vessel response plans were drafted based upon Coast Guard guidance, which is now superseded by the regulation.

The regulation applies to any vessel operating in U.S. water that is 400 GT or more, regulatory or ITC. From there, the regulations get a little complicated based upon capacities. Some of the additional service requirements include firefighting and salvage, dispersants, aerial surveillance, shoreline protection and shoreline cleanup. If applicable, evidence of signed contracts for these services must be submitted with the NTVRP.

In conducting a gap analysis on one of our own plans, there didn’t appear to be much difference between the old guidance and the new regulation with regards to the actual content of the plan. However there were some additional requirements to be added to the NTVRP. If you have an existing plan that was fully compliant there shouldn’t be too much work involved. Some companies may not have conducted a thorough gap analysis between their existing NTVRP and the new regulations in time to meet the deadline. If so, the Coast Guard will notify those companies that their current NTVRP are inadequate.

The Coast Guard has many NTVRPs to review. It will take some time for all the interim operating letters to go out, and even longer for approval letters to be issued.

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