Can oil spill response plans (OSRPs) be functional and regulatory compliant?

That’s a burning question addressed at this year’s International Oil Spill Conference (IOSC) in Savannah, Georgia.  Martin Cramer, of ConocoPhillips, posed the query to a packed room. Cramer, on behalf of the American Petroleum Institute’s (API) Joint Industry Task Force (JITF), asserted that plans can meet both of these objectives.
The JITF was tasked with developing guidance for preparing OSRPs that are highly functional and regulatory compliant, and the group has developed a new approach to the plan preparation process.

Cramer explained that most existing OSRPs are adequate,  are in compliance with the regulations, but lack usefulness. For many plan holders, the primary objective is just that: to meet regulatory obligations and receive regulatory approval.

Many plan holders also believe that there is “little latitude in deviating from the format or content of previously approved plans to make them more functional” because many regulations suggest a format for OSRPs to follow and plan holders are resistant to not follow the suggested regulatory format exactly. The result is that plans often include a significant amount of general information rather than expansive and detailed information, response guidance, and specific cleanup strategies.

 Cramer explained, though, that just because the regulations offer a suggested format, does not mean that such a format will result in the highest functioning and regulatory compliant plan.

According to the JITF, logical organization should be the intent when preparing an OSRP to be both functional and compliant. Important information should be in a graphical or tabular format, and the focus of the plan should be on the initial response actions required, which is when guidance is needed the most during a response effort. The team’s recommendations also include that plans focus on actionable and useful information rather than on background information.
The JITF guidance suggests the following format:

• Quick guide to the plan up front, with key response information that is needed during the first few hours of a response effort
• Ten plan sections, including introduction, initial spill response action, notification and contact information, response resources, response organization, on-water response, shoreline response, wildlife protection and rehabilitation, decontamination and waste management, and demobilization
• Appendices with introductory paragraphs explaining the objective of each appendix, including health and safety protocols, facility description, communication systems, risk assessment and spill scenarios, training and drill exercises, definitions, and acronyms

Although Cramer’s presentation focused on the preparation of OSRPs, he explained that the premise behind changing perspective in order to make plans more user-friendly can apply to any type of response plan. The key is to organize a plan logically so that when needed, it can be of the greatest use during a rapid and effective response action.