COMDTINST 16450.32A
c.
There is a need for consistency in the review and approval of a plan; however, this effort
will be tempered by the fact that a facility response plan is intended for the use of the
facility's personnel and its owner or operator to increase their level of preparedness. The
plans may be presented in a manner consistent with other guidance and plans used by the
the facility. The information contained in these plans in based upon national planning
standards and the response scenarios are intended to be used to develop a planning
document and not establish a performance document or standard.
d.
COTPs shall ensure the continuous tracking of all response plans received, and maintain a
response plan log that allows for the unique identification of submitted plans. This plan
number can be the same as the facility's Marine Safety Information System (MSIS) facility
identification number, or some other number uniquely generated by that COTP. This log
should contain key information such as (1) facility name, (2) date received, (3) review
status (preliminary sat/unsat and comprehensive pends/sat/unsat), (4) date authorized by
COTP to operate under submitted plan, (5) date authorization letter expires, (6) date plan
was approved, and (7) plan approval expiration date. When a field unit receives a
response plan for a facility under its jurisdiction, it should log in the plan, conduct a
preliminary review of the plan for legal sufficiency, provide confirmation of receipt of the
plan to its submitter, conduct a comprehensive review and upon satisfactory completion of
that review issue an approval letter.
e.
The emphasis in reviewing response plans should be on ensuring that the owner or
operator has gone through the planning process to prepare facility personnel to respond, to
the maximum extent practicable, to an actual or threatened discharge of oil. OPA 90
identifies a number of elements considered key to effective preparedness. These include:
identifying properly trained personnel, prearranged private response resources, and a
system to allow the timely and efficient activation and employment of equipment and
personnel. A reviewer should look at the plan's overall effectiveness, workability, and
organiztion for ease of use toward the goal of preparedness. Keep in mind that a plan
preparer may employ approaches that would vary from the Coast Guard's. A number of
formats may be employed in plan preparation. One format may use bullets to outline the
information and remind the users of their responsibilities while another uses detailed
information to lay out planned actions. The Coast Guard's objective
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