Encl (1) TO COMDTINST 16450.32A
Commandant
2100 Second Street, S.W.
United States Coast Guard
Washington, DC 20593-0001
Staff Symbol: G-MEP
(202) 267-0518
16471
APR 11 1994
From: Commandant
To:
Distribution
Subj: RECOMMENDED PROCEDURES FOR CONDUCTING COMPREHENSIVE REVIEWS
OF FACILITY RESPONSE PLANS
1. One of the objectives of facility response plans (FRP) regulations is that sufficient flexibility be
permitted for the plan to reflect an owner's or operator's corporate structure and existing operating
procedures. We have also stressed the point that these are "their" plans. Evaluation of FRP using a
structured line item check list may not be the best approach for plans which were not prepared in a
specified boilerplate fashion.
2. This letter provides information of an alternative method of plan review and is consistent with
how vessel response plans (VRP) comprehensive reviews are currently being conducted. It
proposes a list of critical areas to be thoroughly examined during the comprehensive review
process. We recognize that some plans will be better or more comprehensive than others, yet we
propose that plans be approved or rejected based on this critical area review which focuses on items
that are essential for the plan to meet the intent of the response plan regulations. (Process, Risk,
Preparedness, Responsibility)
3. Rather than applying a lengthy detailed checklist and hunting throughout a plan for language to
fulfill each requirement, it is recommended that reviewers read the entire plan to get a feel for the
workability of the document. (This action will also allow for the greatest flexibility in the structure
of the plan.) After reading through the plan, the reviewer should critically evaluate each item listed
in paragraph (4) below. Enclosure (1) is a sample checklist of the criteria that should be checked
thoroughly, and includes:
a. Those items which are key to the stated pupose and facility regulations, namely enhancing
the owner's and/or operator's preparedness to respond and mitigate.
b. Information upon which the owner/operator and facility personnel would rely in the event
of a spill.
c. Those plan details which we routinely scrutinize when informed of an incident involving a
facility.
4. Using the above approach, the following items would be comprehensively evaluated, using a
review sheet and a planning volume calculation spreadsheet.