When a SOPEP has satisfactorily completed a comprehensive review, the plan is stamped
approved and returned to the owner or operator submitting the plan along with a plan
approval letter. The approved plan and the approval letter are required to be retained
aboard the vessel.
There is no entry made into MSIS regarding the status of a SOPEP. For vessels that have
an International Oil Pollution Prevention (IOPP) Certificate, this plan is onlyh a part of the
information requried for the issuance of that certificate. For other vessels, this plan is
viewed in much the same manner as are the vessels oil transfer procedures or oil record
book. No separate MSIS entry is made regarding this plan's review and approval.
WAIVERS AND ALTERNATIVE MEANS OF COMPLIANCE.
The planning standards contained in vessel and facility response plan regulations are
national standards. In developing these standards, it was recognized that they may not be
appropriate for all areas in which a vessel may operate, nor for all facilities. For this
reason provisions exist for on owner or operator to request the acceptance of an alternate
planning criteria. This action must be initiated by the owner or operator of the facility or
(1) Waiver and alternative compliance requests should set forth details of the alternative
being proposed, including: (1) alternative response methodologies (i,e,. chemical
countermeasures), (2) alternative rsponse equipment including type and quantity, (3)
an assessment of the increased or decreased risk posed by the facility or vessel if the
waiver/alternative is granted, (4) an assessment of the efficiency of the proposed
alternative/waiver and (5) any operational restrictions proposed to limit the risk.
(2) A facility owner or operator should submit requests for consideration of a waiver or
alternative planning standard directly to the COTP for the zone in which the facility is
(3) A vessel owner or operator should submit a request for acceptance of a waiver or
alternative planning standard 90 days before the vessel intends to operate under the
proposed waiver or alternative. These requests must be submitted to Commandant (G-
MEP-6) via the COTP for the geographic area(s) affected. The COTP should advise