Encl (1) TO COMDTINST 16450.32A
DRILL REQUIREMENTS FOR RESPONSE PLANS
That portion of the plan dealing with drills 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,
included drills as one of the sections required in a vessel or
facility response plan. In reviewing submitted response plans, it
has been noted that the drill section of response plans have
generally been complete, but they have been so only in the fact
that they have identified the drill requirements as contained in
the interim final rules for vessel and facility response plans.
Unfortunately, the drill section of the response plan is often
well covered in a mechanical sense. By this it is meant that the
plan identifies all of the key drills set forth in the
regulations, but it does not really identify that the intent is to
enhance the preparedness of the vessel's crew or others identified
in the plan. This section of the plan needs to not only give the
drills to be conducted and their scheduled frequency, but it must
also give the sense that this is an integral part of the response
preparedness program for that vessel. There should be a logical
tie-in between this section of the response plan and the section
dealing with training. The plan is more than just the paper it is
written on, and this section of the plan helps to define the
commitment of the owner and/or operator to the viability of the
plan. A well written drill section will include a discussion of
the various drill objectives and expectations of a
satisfactory/realistic drill.
(NOTE: With the advent of the National Preparedness for Response
Exercise Program (PREP), and industry's wide acceptance of it, we
expected that a number of plans would be changed to incorporate
the PREP guidelines. Incorporating the concepts of PREP in your
response plan would satisfy all of the above issues.
It is hoped that the information provided above will assist plan
preparers in reviewing their process in developing the section of
their response plan dealing with drills. It is expected that each
plan preparer has determined the needs of their organization as
created by the development of the response plan and the actions
identified as necessary to increase the company's and its
personnel's preparedness for responding to discharges or
substantial threats of a discharge of oil.
Copies of the PREP document are available to anyone wishing a
copy. If you do not have a copy, but wish one, please contact YN1
Daniel Caras at (202) 267-6570.
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