Encl (1) TO COMDTINST 16450.32A
TRAINING REQUIREMENTS FOR RESPONSE PLANS
The portion of the plan dealing with training is one of the key elements
of a response plan. This concept is clearly expressed by the fact that
Congress, in writing the Oil Pollution Act of 1990, specifically
included training as one of the sections required in a vessel or
facility response plan. In reviewing submitted response plans, it has
been noted that the plans often do not provide sufficient information in
the Training Section of the plan for either the user or the reviewer of
the plan. In some cases, plans simply state that the crew and others
will be trained in their duties and responsibilities, with no other
information being provided. In other plans, information is simply given
that required parties will receive the necessary worker safety training
(HAZWOPER).
The training section of the plan need not be a detailed course syllabus,
but it must contain sufficient information to allow the user and
reviewer or evaluator to have an understanding of those areas that are
believed to be critical. Plans should identify key skill areas and the
training that is required to ensure that the individual identified witll
be capable of performing the duties prescribed to them. It should also
describe how the training will be delivered to the various personnel.
Further this section of the plan must work in harmony with those
sections of the plan dealing with drills, the spill management team, and
the qualified individual.
To assist in the preparation of the training section of a facility
response plan, some of the key elements that should be addressed are
indicated below. Again, while it is not necessary that the
comprehensive training program for the company be included in the
response plan, it is necessary for the plan to convey the elements that
define the program as appropriate. An effective spill response training
program should consider and address:
*
Notification requirements and procedures.
*
Communication system(s) used for the notifications.
*
Procedures to mitigate or prevent any discharge or a
substantial threat of a discharge of oil resulting from:
Operational activities associated with oil transfers.
Failure of manifold
Transfer system leak
Explosion or fire
Tank failure
Tank overflow
Equipment failure
*
Procedures for use of equipment which may be used to mitigate
an oil discharge.
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