Encl (1) TO COMDTINST 16450.32A
Enclosure (1):
AREAS FOR FRP REVISION
16471
REQUIRED REVISIONS
The revisions listed below need to be incorporated into your plan
before your plan is approved.
1. Your plan must specify training regimens for the Qualified
Individual, Alternate Qualified Individual, members of the spill
management team, and facility personnel who are assigned
responsibilities under the plan. Your plan's training section
fails to convey how the elements contained in enclosure ## are
effectively addressed in a training program. Although your plan's
training section describes that the Qualified Individual and
Alternate Qualified Individual will attend OSHA training, this
course in itself does not prepare an individual to effectively
execute your plan. Please amend your plan to include an outline
of specific training courses, company developed programs, or
lesson or video tape series that describe how personnel will
acquire the knowledge and familiarity to carry out their
responsibilities under your response plan.
(33 CFR 155.1035(e); NVIC 7-92 Section 12)
2. Your plan must discuss the organizational structure of the
spill management team including the responsibilities and duties of
personnel that will be responsible for managing response actions.
The source of personnel, in-house or contracted, to fill the
functions should be identified. Your plan should also identify
the various organizational layers that exist below key team
positions. Enclosure ## discusses recommended spill management
team organization and functions.
[33 CFR 154.1035(b)(3); NVIC 7-92 Section 8(b)(3)]
RECOMMENDED REVISIONS
The Coast Guard suggests the following changes to improve your
plan.
a. The notification checklist to be made by facility or shore-
based personnel does not include telephone numbers. For ease of
use, we recommend telephone numbers be added to the checklist.
b. Your plan includes the toll-free number to the U.S. Coast
Guard National Response Center. We recommend that you amend your
plan to add the direct number, which is (202)267-2675.
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