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Maritime Compliance Report

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Nontank Vessel Response Plans

 Hopefully you made the deadline of January 30th to submit your Nontank Vessel Response Plan (NTVRP) to the Coast Guard. According to Coast Guard Headquarters, on January 31, 2014, all old nontank vessel response plans were to be deactivated. That's because the long awaited final rule for the nontank vessel response plan regulations was published a few months ago. The old nontank vessel response plans were drafted based upon Coast Guard guidance, which is now superseded by the regulation.

The regulation applies to any vessel operating in U.S. water that is measured 400 gross tons or more, regulatory or ITC. From there, the sub-applicabilities get a little complicated based upon capacities. Some of the additional service requirements include fire-fighting and salvage, dispersants, aerial surveillance, shoreline protection and shoreline clean-up. If applicable, evidence of signed contracts for these services must be submitted with the NTVRP.

In conducting a gap analysis on one of our own plans, there didn't appear to be much difference between the old guidance and the new regulation with regards to the actual content of the plan. However there were some additional requirements to be added to the NTVRP.  If you have an existing plan that was fully compliant there shouldn't be too much work involved. Some companies may have not have conducted a thorough gap analysis between their existing NTVRP and the new regulations in trying to meet the deadline. If so, the Coast Guard will notify those companies that their current NTVRP are inadequate.

The Coast Guard has many NTVRPs to review. It will take some time for all the interim operating letters to go out, and even longer for approval letters to be issued.
Towing Safety Management System - Contents
EPA Vessel General Permit 2013
 

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Saturday, 19 April 2025

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