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Salvage / Marine Firefighting

Salvage / Marine Firefighting. Tim Dickensheets T&T Bisso, LLC Presentation to Caribbean RRT 2 December 2009. SMFF cont. 33 CFR Part 155 Salvage and Marine firefighting (SMFF) Requirements; Vessel Response Plans for Oil; Final Rule dated December 31, 2008

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Salvage / Marine Firefighting

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  1. Salvage / Marine Firefighting Tim Dickensheets T&T Bisso, LLC Presentation to Caribbean RRT 2 December 2009

  2. SMFF cont. 33 CFR Part 155 Salvage and Marine firefighting (SMFF) Requirements; Vessel Response Plans for Oil; Final Rule dated December 31, 2008 Compliance Extended to 22 February 2011

  3. SMFF cont. • These regulations apply to tank vessels carrying oil as cargo only. • What do these regulations primarily require? • A list of fifteen criteria the Resource Provider (salvor & firefighter) must meet • Response times • A contract with funding agreements and written consent between the Plan Holder (vessel owner) and Resource Provider

  4. RESOURCE PROVIDER • CURRENTLY PROVIDINGTHE RESPONSE SERVICE • DOCUMENTED HISTORYIN THE BUSINESS • OWN RESPONSEEQUIPMENT • TRAINED EMPLOYEES • 24 HOUR AVAILABILITYAND HISTORY OFPROVEN RESPONSECAPABILITY • TRAINING PROGRAM • HISTORY OF DRILLS ANDEXERCISES • HISTORY OF APPROVEDSALVAGE PLANS • MEMBERSHIP INASSOCIATIONS • INSURANCE • WELL CAPITALIZED • LOCAL EXPERIENCE • PROVEN LOGISTICALCAPABILITY • SAFETY SYSTEM • FAMILIARITY WITH ACPs Ref CFR 155.4050 (b.1-15)

  5. OPA 90 TIMEFRAMES

  6. OPA 90 TIMEFRAMES Ref CFR 155.4030 (b) “Timeframe starts when anyone in response organization receives notification of a potential or actual incident” Ref CFR 155.4040 (b)

  7. Contracting • Contracting- Highly emphasized in the final regulations • To ensure that resource providers will respond immediately and there will be no delay due to contract or funding negotiations, the following is required: • “Contract or other approved means” • Written contract between the plan holder and the • resource provider

  8. Additional impacts • 18 months to comply (now 26 months) • Waiver provisions on compliance • A “primary resource provider” who will be the primary point of contact for the planholder, FOSC, and Unified Command • Drill and exercises • Pre-fire plans • Public sector firefighters as listed responders • Safety standards (OSHA) • VRP compatible with the ACP and NCP

  9. Rescue / Towing Vessels “Emergency towing, also referred to as rescue towing, means the use of towing vessels that can pull, push or make-up alongside a vessel. This is to ensure that a vessel can be stabilized, controlled or removed from a grounded position. Towing vessels must have the proper horsepower or bollard pull compatible with the size and tonnage of the vessel to be assisted. “ “Ensuring the proper emergency towing vessels are listed in your VRP. Your VRP must identify towing vessels with the proper characteristics, horsepower, and bollard pull to tow your vessel(s). These towing vessels must be capable of operating in environments where the winds are up to 40 knots.”

  10. Municipal Firefighters Advantages for a Public Service FF to Consent? • Formally make the FD a part of the major casualty response • Opportunity for the FD to regularly drill with vessel owners, CG, State officials, port authorities, salvors, etc. • Would eliminate a duplication of response services, confusion and conflict • If the FD bills the vessel, this would formalize the process and perhaps even guarantee payment • Would provide a more effective and coordinated overall response to a vessel fire However, it’s a challenge to get that consent!!

  11. Current Status Compliance date changed from June 2010 to February 2011 Proposed Navigation and Vessel Inspection Circular (NVIC) to be published After 30 days, public meeting Final NVIC published

  12. Current Status cont. ASA members are meeting with National Strike Force Coordination Center to develop a Response Resource Inventory (RRI)

  13. Partnerships How might the federal agencies, RRTs, Area Committees, Area Maritime Security Committees, etc. assist in improving the response structure?

  14. SALVAGE & FIFI ASSETS

  15. GLOBAL EMERGENCY RESPONSE Tim Dickensheets td@ttbisso.com 713-534-0700 www.ttbisso.com

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