Guidelines for Classifying Oil Spill Removal Organizations

Attached are the revised guidelines for conducting the Coast Guard's Oil Spill Removal Organization (OSRO) program. Navigation and Vessel Inspection Circular (NVIC) No. 12-92 is no longer in effect.

The Coast Guard created the voluntary OSRO classification program so that facility and vessel response plan holders could list Coast Guard "evaluated" OSROs in response plans in lieu of providing voluminous detailed lists of response resources. This was, and still is, the only regulatory benefit plan holders receive from utilizing Coast Guard classified OSROs. OSROs and plan holders participate and use the classification program on a strictly voluntary basis.

After the implementation of NVIC 12-92, weaknesses were identified in the classification process that prevented the program from realistically representing the geographic response capabilities of an OSRO. The Coast Guard held public workshops in January 1994 and June 1995 to solicit input for a revised program. Based on the input received from the workshops and from written and verbal comments, draft revised guidelines were developed and released for public review and comment in September 1995.

The Coast Guard received 70 comprehensive, well written and constructive comments on the draft OSRO guidelines. As a result of the comments received, and our own review, the draft has undergone many changes. Many of the public comments have been incorporated into the final guidelines. The cooperation of OSROs, plan holders, and state and federal agencies has been essential to the development of a program which will allow all of us to better meet the intent of the Oil Pollution Act of 1990 (OPA 90).

We continue to stress that using a Coast Guard classified OSRO does not in anyway relieve plan holders of the responsibility to ensure that their specific response needs are met. The revised classification guidelines provide a good indication of an OSRO's response capability by Captain of the Port zone. They do not, however, represent a "one size fits all" solution. Using the computer system, when it comes on line, will allow us to accurately and consistently calculate an OSRO's capability to respond to specific plan holder requirements.

One issue that deserves particular discussion is that of dedicated versus non-dedicated resources. Ideally, dedicated resources provide more of a timely response "guarantee" than non-dedicated resources but, historically, the response industry has depended to varying degrees on non-dedicated resources to meet some critical response functions. We recognize that non-dedicated resources are a valuable tool during response operations. To better ensure the availability of these resources, we have required a redundancy factor of 2:1 when using non-dedicated response resources. This means that an OSRO depending on non-dedicated resources must ensure the availability of non-dedicated response resources by contract or other approved means in quantities equal to twice what they actually require of the non-dedicated resources. We plan to use random spot checks to verify the "availability" of all response resources.

The thrust of OPA 90 is to develop private sector responsibility for all aspects of oil spill response planning. Realistic response capability is a crucial link in this process, so the emphasis on a comprehensive OSRO classification process is well placed. The revised guidelines will give planners a much better tool to use in gauging a classified OSRO's potential to meet specific planning requirements.

Any questions regarding the revised OSRO guidelines should be directed to Lieutenant Terry Hoover at (202)267-0448.

We in the Coast Guard appreciate the interest shown in this project by plan holders, OSROs, state and federal agencies, and many others. We believe the revised guidelines are significantly better than the previous ones. They represent a partnership among groups that will allow us to better preserve our environment for future generations.

Sincerely,

J. C. Card
Rear Admiral, U.S. Coast Guard
Chief, Office of Marine Safety,
Security, and Environmental Protection

GUIDELINES FOR CLASSIFYING
OIL SPILL REMOVAL ORGANIZATIONS (OSROS)

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SECTION 1: INTRODUCTION

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Purpose

The Oil Spill Removal Organization (OSRO) classification process was developed to facilitate the preparation and review of vessel and facility response plans. Section 4202 of the Oil Pollution Act of 1990 (OPA 90) amended section 311(j) of the Federal Water Pollution Control Act (FWPCA) to require the preparation and submission of response plans for all vessels defined as "tank vessels" under 46 U.S.C. 2101 and for certain oil-handling facilities. An owner or operator who is required to submit a response plan must, among other things, identify and ensure by contract, or other means approved by the President, the availability of private personnel and equipment necessary to remove, to the maximum extent practicable, a worst case discharge (including a discharge resulting from fire or explosion), and to mitigate or prevent a substantial threat of such a discharge.

The magnitude of the investment in specialized oil recovery equipment, temporary storage capacity, transporting oil for disposal, and in training sufficient numbers of personnel to remove such a discharge, in all foreseeable locations and operating environments, is unprecedented for marine environmental response preparation. The system for assembling, mobilizing, and controlling these resources is extremely complex. To meet the statutory requirements, each response plan must identify the means for accomplishing these tasks.

The OSRO classification process represents standard guidelines by which the Coast Guard and plan preparers can evaluate an Oil Spill Removal Organization's potential to respond to and recover oil spills of various sizes. Plan holders that arrange for the services of a Coast Guard classified OSRO do not have to list their response resources in their plans.

Applicability

The OSRO classification process is a strictly voluntary process in which OSROs can participate and plan holders can utilize for planning purposes. An OSRO does not have to be classified and owners or operators do not have to limit their response resources to Coast Guard classified OSROs.

As already indicated, however, plan holders that use Coast Guard classified OSROs are exempt from the requirement to list their response resources in their plans. Coast Guard classification of an OSRO does not relieve an owner or operator of their ultimate statutory responsibility to ensure the adequacy of the spill response resources identified in a response plan.

Definitions

a. Classification is a process for identifying oil spill removal organizations within specified geographic locations on the basis of their ownership or control of specialized equipment and trained personnel to remove oil from the environment.

b. Containment boom/Protective boom are descriptive terms describing the intended use of the boom. The Vessel Response Plan regulations require a plan holder to have available a specific amount of boom for shoreline protection purposes. The regulations require containment boom, used for recovery purposes, in addition to the specific protective boom requirements.

c. Effective Daily Recovery Capacity (EDRC) means a calculated oil recovery capacity of oil recovery devices determined by using a formula that takes into account limiting factors such as daylight, weather, sea state, and emulsified oil in the recovered material.

d. Exclusive economic zone (EEZ) means the zone contiguous to the territorial sea of the United States, extending to a distance up to 200 nautical miles from the baseline from which the breadth of the territorial sea is measured.

e. Great Lakes means Lakes Superior, Michigan, Huron, Erie, and Ontario; their connecting and tributary waters; the Saint Lawrence River as far as Saint Regis; and adjacent port areas.

f. Inland area means the area shoreward of the boundary lines defined in 46 CFR part 7, except that in the Gulf of Mexico, it means the area shoreward of the line of demarcation (COLREG lines) as defined in Sections 80.740 - 80.850 of 33 CFR Chapter I. The inland area does not include the Great Lakes or rivers and canals areas.

g. Nearshore area means the area extending seaward 12 miles from the boundary lines defined in 46 CFR part 7, except that in the Gulf of Mexico it means the area extending seaward 12 miles from the line of demarcation (COLREG lines) as defined in Sections 80.740 - 80-850 of 33 CFR Chapter I.

h. Non-persistent or Group I oil means a petroleum-based oil that, at the time of shipment, consists of hydrocarbon fractions--

(1) At least 50% of which by volume, distill at a temperature of 340 degrees C (645 degrees F); and

(2) At least 95% of which by volume, distill at a temperature of 370 degrees C (700 degrees F).

i. Ocean means the open ocean, offshore area, and nearshore area as defined in this document.

j. Offshore area means the area up to 38 nautical miles seaward of the outer boundary of the nearshore area.

k. Oil Spill Removal Organization (OSRO) means any person or persons who own or otherwise control oil spill removal resources that are designed for, or are capable of, removing oil from the water or shoreline. Control of such resources through means other than ownership includes leasing or subcontracting of equipment or, in the case of trained personnel, by having contracts, evidence of employment, or consulting agreements. OSROs provide response equipment and services, individually or in combination with subcontractors or associated contractors, under contract or other means approved by the President, directly to an owner or operator of a tank vessel or facility required to have a response plan under 33 U.S.C. 1321(j)(5). OSROs must be able to mobilize and deploy equipment or trained personnel and remove, store, and transfer recovered oil. Persons such as sales and marketing organizations (e.g., distributorships and manufacturer's representatives) that warehouse or store equipment for sale are not OSROs.

l. Open ocean means the area from 38 nautical miles seaward of the outer boundary of the nearshore area, to the seaward boundary of the EEZ.

m. Operating area means Rivers and Canals, Inland, Great Lakes, Nearshore, Offshore, or Open Ocean. These terms are used to define the geographic location(s) in which a vessel or facility is handling, storing, or transporting oil.

n. Operating environment means Rivers and Canals, Inland, Great Lakes, or Ocean. These terms are used to define the conditions in which response equipment is designed to function.

o. Persistent oil means a petroleum-based oil that does not meet the distillation criteria for a non-persistent oil. For the purposes of this document, persistent oils are further classified based on specific gravity as follows:

(1) Group II - specific gravity less than .85.

(2) Group III - specific gravity between .85 and less than .95.

(3) Group IV - specific gravity .95 to and including 1.0.

(4) Group V - specific gravity greater than 1.0.

p. Response Resource Inventory (RRI) is the database of oil spill response resources developed by the Coast Guard in response to the requirements of the Oil Pollution Act of 1990.

q. Rivers and canals means bodies of water, including the Intracoastal Waterways and other waterways artificially created for navigation, confined within the inland area that have a project depth of 12 feet or less.

r. Shallow draft capable means equipment is capable of operating in waters of 6 feet or less depth.

s. Temporary storage capacity means, for the purposes of classification, sufficient storage capacity equal to twice the EDRC of an OSRO. Temporary storage capacity may include inflatable bladders, rubber barges, certificated barge capacity, or other temporary storage that is capable of being utilized on scene at a spill response and which is designed and intended for storage of flammable or combustible liquids. It does not include vessels or barges of opportunity for which no prearrangements have been made. Fixed shore-based storage capacity, ensured available by contract or other approved means, will be acceptable.

SECTION 2: CLASSIFICATION DETAILS

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Geographic Specific Classification

The Coast Guard's National Strike Force Coordination Center (NSFCC) classifies OSROs by Captain of the Port (COTP) zones. Classification is assigned based on the information supplied by each OSRO for inclusion in the computer based Response Resource Inventory (RRI). Participation in the RRI is mandatory for an OSRO to receive classification. Using response times and discharge quantities specified in the facility and vessel response plan regulations (33 CFR 154/155), and using equipment requirements as specified in the regulations and this document, NSFCC determines the appropriate classification(s) for each OSRO in each COTP zone.

The RRI program automatically takes into account the response capability of an OSRO (using travel speeds specified in the regulations). The maximum response time specified in the regulations is 72 hours (vessel Tier 3 Worst Case Discharge), so the computer generated classification may indicate the capability (travel speed x response time + resources) to respond to a spill in a COTP zone distant from an OSRO's normal area of response operations. If an OSRO desires to limit its response capability to a selected COTP zone(s), it should indicate this desire in its application. The verification visits conducted by the Coast Guard will confirm the cascading capability of an OSRO that claims remote response capability.

OSRO classifications for each COTP zone are based on a specific geographic location. This location is either the latitude and longitude of the COTP city or the latitude and longitude of a city within the COTP zone that an OSRO specifies. For oceans classification, a position 50 nautical miles seaward of the entrance to the port (COTP city/specified city) is used for classification purposes.

Because of the necessity to issue a classification based upon a specific location, an OSRO's actual capability to respond within a COTP zone may vary in relation to its classification. For example, an OSRO may be classified as a "C" Inland for a COTP zone; it may, however, be able to meet the "A" Inland needs of a customer located between the OSRO and the city its classification is based on. The opposite is also true; the "C" Inland classified OSRO may not meet any needs at a location on the other side of the city the classification is based on. The Coast Guard issued classification is only an indication of an OSRO's capability to respond within a COTP zone. Planholders must utilize an OSRO(s) capable of meeting specific response needs.

If the COTP city/specified city is a high volume port, the stricter response times will be used for classification purposes. The designated higher volume port areas are another factor OSROs and planholders must take into account when determining individual plan specific response needs.

The vessel and facility response regulations require planholders to ensure the availability of response resources by contract or other approved means. OSROs must meet these same requirements for all resources (dedicated, non-dedicated, owned and non-owned equipment and personnel) that they claim for classification purposes, including temporary storage and vessels intended to deploy cascaded resources. At the minimum, this requires a written document, from the resource supplier to the OSRO, which identifies the equipment, personnel, and services intended to be provided in the event of a response. The identified resources must be capable of being provided within stipulated response times in specified geographic areas.

Even though dedicated response resources are ideal, OSROs may utilize non-dedicated resources. If an OSRO elects to use non-dedicated resources, there must be a redundancy factor of 2:1. This means the OSRO must ensure the availability of non-dedicated response resources by contract or other approved means in quantities equal to twice what the OSRO requires of the non-dedicated resources.

As mandated in the regulations, all response times are based on the time of discovery of a discharge. Response times, travel speeds, and the ability to provide recovery systems are all factors in the classification of OSROs. For classification purposes, travel speed for land transit calculations is 35 miles per hour; travel speed for water transit calculations is 5 knots. If OSROs adequately demonstrate that their response resources are capable of quicker transit speeds than those specified in the regulations, classification may be based on demonstrated transit speeds (including air transit if applicable).

Plan holders must evaluate OSROs based on distances stated in the regulations. For a facility, the distance from the storage location of the response resources must be used to determine response time. For a vessel, the farthest distance the vessel operates from the storage location of the response resources must be used to determine whether the resources are capable of arriving on scene within the time required.

OSROs that have designated equipment to meet state resident equipment requirements must indicate this on their OSRO application. For classification purposes, designated resident equipment is not cascadable outside of the area for which it is designated.

Systems Approach

During the Coast Guard's evaluation of an OSRO, the systems approach is used. The three components evaluated to classify an OSRO within specific classification levels are containment, recovery, and storage devices. These all have specific elements, such as connectors and anchors for booms and pumps and hoses for recovery devices. Skimmers without boom to contain the oil or without temporary storage to store the oil are essentially useless in a response. Classification will be issued based upon the response system capability documented by an OSRO and verified by the Coast Guard.

Fixed storage capacity may be located at or near the scene of a spill, so a combination of mobile temporary storage and fixed temporary storage may be adequate to allow an OSRO to conduct efficient response operations. An OSRO that operates in an area where fixed storage is a realistic asset may claim fixed storage as meeting part of an OSRO's temporary storage requirement. The key factor that the Coast Guard will evaluate is whether the temporary storage an OSRO has identified will allow the OSRO to sustain its classified EDRC throughout spill response operations.

In addition to the above requirements, an OSRO's classification within a COTP Zone is limited by the lowest rated component of the recovery system. For example, if an OSRO has a EDRC of 10,000 bbls/day, but only has an ensured available temporary storage capacity of 14,000 bbls/day, then its recovery capacity is limited to 7,000 bbls/day (by regulation, temporary storage capacity must be twice EDRC).

Even though containment, recovery, and storage devices are used for classification purposes, they alone do not constitute a response system. Other equally important components that are evaluated as part of the system include:

1. personnel with appropriate training

2. proper equipment for the operating environment

3. logistical/sustainability capability

alternate response techniques (only if an OSRO claims this capability in order to reduce a planholder's mechanical recovery requirements)

These other factors can vary greatly depending on operating environments, cascading capability, and equipment utilized in response operations, so numerical limits are impractical. The Review Process section of this guide contains a list of some of the items that Coast Guard personnel consider when verifying the capability of an OSRO. An OSRO must have the capability to effectively deploy and operate equipment and sustain response operations in order to receive Coast Guard classification. Classification by the Coast Guard does not guarantee or predict operational performance. Plan holders should consider the actual response history of an OSRO in conjunction with the classification process and the plan holder's evaluation of an OSRO to determine if an OSRO can meet the plan holder's needs.

Proper equipment for the operating environment must be stressed. For example, an ocean capable deck barge that could be used for oil storage equipment would have to consider Load Line, Certificate of Inspection, and Shipboard Oil Pollution Emergency Plan requirements. Vacuum trucks will be limited to shoreline response unless there is a documented capability to utilize them via proper marine transportation. All vessels used in recovery operations must be appropriate for the grade of oil recovered. Certificate of Inspection service, routes, and conditions of operation must be adhered to. Vessels that do not require certification must be registered in accordance with state or federal laws and regulations.

Coastal facilities may be located on or near the dividing line between the Inland and Oceans environments. For on-shore facilities that lie outside of the boundary line or the line of demarcation (see Inland definition), the COTP will determine if Inland or Oceans response capability is required.

Classifications

OSROs are classified geographically with letter designations, A through E, by removal capacity and response times.

OSROs are classified for four different operating environments: rivers and canals, inland, Great Lakes, and oceans. The oceans operating environment includes the nearshore, offshore, and open ocean operating areas as defined in the regulations. The equipment operating parameters for the three operating areas incorporated in oceans are the same, so it is a logical OSRO classification. For VRP/FRP planning purposes, however, the three operating areas incorporated in the oceans classification have different removal capacity and mobilization calculation factors. Plan holders must be aware of the distinction between operating environments and operating areas.

As noted earlier, OSROs are now classified by COTP zone for resource availability. A computer program uses the information submitted by OSROs in the RRI format to calculate classifications based on a specific geographic location(s) within each COTP zone. Classifications correspond to planning quantities and time requirements as outlined in Section 5: Classification Requirements.

Each classification stands on its own; an "E" classification indicates the capability to meet "E" classification requirements; the "E" does not automatically include the capability to meet the requirements for "A", "B", "C", or "D".

Classification does not predict operational performance or relieve an owner or operator from the requirement to consider response times and cargo volumes in the planning process. The use of a classified OSRO does not relieve an owner or operator of the statutory responsibility to effectively and promptly remove spilled oil from the environment.

SECTION 3: APPLICATION PROCESS

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Any OSRO may apply for classification. The Coast Guard classifies applicants on the basis of their estimated capacity to remove oil from the marine environment, as calculated from the information provided in the application. In order for an application to be accepted, all pertinent data fields must be completed in the RRI application package. If an OSRO wants to limit the COTP zones for which it will be evaluated, or if an OSRO wants to limit the operating environments for which it will be classified, it must note this in the application package. If an OSRO does not otherwise specify, the computer program will evaluate the OSRO using all classification parameters for all applicable COTP zones.

An OSRO seeking classification shall supply information about itsequipment and personnel inventory in the format specified in the RRI instructions. The information must be clear, concise, and complete. Incomplete applications will not be processed.

The applicant shall identify the latitude and longitude of the locations from which oil spill response resources will be mobilized. The applicant shall also identify the COTP zone(s) in which response resources are located.

OSROs that do not want public availability to the data they supply the Coast Guard should indicate this in their application. Even though the raw data used to calculate classifications may not be available to the public, the resulting classification(s) matrix with resource totals must be publicly available to ensure the viability of the classification process.

An applicant shall attest in writing that the factual information provided regarding the applicant's response equipment and personnel is correct to the best of the applicant's knowledge and belief. The applicant shall agree to be visited by Coast Guard personnel for the purpose of verifying the information contained in the application. All response resources identified for classification purposes are subject to verification visits.

An OSRO may request an application from or submit an application to the following address:

National Strike Force Coordination Center (NSFCC)
(Attn: OSRO CLASSIFICATION REVIEW)
1461 U.S. 17 North
Elizabeth City, NC 27909

The NSFCC can be reached by telephone at (919) 331-6000 or by facsimile at (919) 331-6012. A classified OSRO shall notify, within 24 hours, the NSFCC and the Captain of the Port (COTP) of the zone in which the OSRO's resources are located of significant changes in response capability that might effect the classification and the OSRO's ability to respond to a spill as planned. A "significant" change is a reduction in the OSRO's classified capacity by a factor of 10% for a period of 48 hours or longer.

SECTION 4: REVIEW PROCESS

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Resource Assessment

An applicant's resources will be evaluated on the basis of the information provided, the process described in this guidance, and the information provided in the facility and vessel response plan regulations. When assigning OSROs to one or more response classes, the quantity of equipment, its designed purpose, the planning capacity of the resources identified in the application, and the number of trained response personnel will be considered. Incomplete applications will be returned to the applicant immediately with an explanation of the deficiency.

After completing the review of the information provided by the applicant, the Coast Guard will issue an interim letter of classification identifying removal capacity, operating environment(s), and COTP zone(s). The interim classification letter will remain in effect until a verification visit is conducted by the Coast Guard. A final classification letter, valid for three years, will be issued upon completion of verification visits and final review of the findings of these visits.

Coast Guard verification visits, PREP drills, random resource availability spotchecks, actual responses, or information gathered during the course of normal business may, from time to time, give the Coast Guard reason to suspend or revoke an interim or final classification. In all circumstances, the Coast Guard will give the OSRO written notice of the OSRO's potential classification suspension or revocation. Upon receipt of the written suspension or revocation notice, an OSRO will have the opportunity to document that its capability still justifies its classification. If the OSRO cannot document its capability, its classification will be suspended or revoked, as applicable. Restoration of a revoked classification will require a new application and verification visit. Review for reclassification may be initiated by either the Coast Guard or the OSRO.

The NSFCC is responsible for implementing and conducting the OSRO classification program. There may be times when an OSRO does not agree with a determination by NSFCC personnel on, for example, the suitability of equipment to perform in a designated operating environment. An OSRO may appeal NSFCC decisions, via NSFCC, to:

Commandant (G-MRO-3)
U.S. Coast Guard
2100 Second Street, S.W.
Washington, DC 20593-0001
(202)267-2611

Inspection and Verification

After reviewing the application and issuing an interim classification, the Coast Guard will assign a team to visit the OSRO and inspect and validate the rsources identified in the application. The inspection team will normally include members from the National Strike Force and the local Marine Safety Office (MSO), and may include other state and federal agency representatives. OSROs will be contacted by the NSFCC to schedule all verification visits. A final classification will be issued upon completion of verification visits.

The primary purpose of verification visits is to audit the OSRO's equipment and personnel inventory, inspect the personnel training records, inspect equipment maintenance records, verify agreements for non-owned resources, verify equipment condition, and to conduct an overall assessment of the accuracy of the OSRO's representations. The audit is a quality assurance check of the equipment and trained personnel and not a guarantee of performance. If the OSRO's equipment and personnel status does not accurately reflect the information provided in the application, the Coast Guard will issue the final classification at a level which appropriately reflects its actual resources.

The OSRO should ensure that its equipment is in good operating condition, that preventive maintenance is performed as recommended by the manufacturer, that equipment is transportable, and that there is compatibility between system components. Equipment that is inoperable, not mobile or transportable, or that has incompatible system components may not be counted toward overall removal capacity for the purposes of classification. The verification team may consider, among other conditions, the following:

(1) Booms:

(a) Overall condition

(b) Evidence of ownership, lease, or subcontract

(c) Manufacturer, type and quantity

(d) Compatibility of connectors

(e) Number and adequacy of anchors

(f) Transportability

(g) Planned operating environment(s)

(2) Recovery Devices:

(a) Skimmers and vacuum trucks

(b) Evidence of ownership, lease, or subcontract

(c) Manufacturer, type, model and throughput capacity

(d) Compatibility of components (hoses, suction and kimmer head, couplings , connectors, etc.)

(e) Operability and maintenance

(f) Condition of the prime mover and other supporting equipment

(g) Holding capacity

(h) Planned operating environment(s)

Oil Spill Recovery Vessels

(a) Small skimming vessels, small recovery vessels, recovery vessels, tank vessels

(b) Evidence of ownership, lease, or subcontract

(c) Operability and maintenance

(d) Storage capacity

(e) Inspection/Certification

(f) Planned operating environments

(g) Grade of oil carried

(h) Off-load capability

(i) Length, beam, draft, range, transit speed, crew size

(4) Temporary Storage Devices:

(a) Evidence of ownership, lease, or subcontract

(b) Manufacturer, type, model (as applicable)

(c) Capacity (twice the daily capacity of recovery devices)

(d) Inspected and maintained in accordance with manufacturer's recommendations

(e) Contracted barges with current certificates

(f) Planned operating environments

(g) Grade of oil carried

(h) Location of fixed storage

(5) Boats:

(a) Sufficient numbers of trailers, outboard motors and USCG-required safety equipment (life jackets, lights, etc.)

(b) Types and number of boats appropriate to the environment of the classification

(c) Operability and maintenance

(d) Length, beam, draft, range, transit speed, crew size

(e) Adequate working platform for oil spill response

(f) Certification/registration

(6) Records :

(a) Equipment clearly marked for identification

(b) Records supporting claims of ownership, lease, or subcontract

(c) Complete maintenance records reflecting condition of the equipment

(d) personnel training records

Prior to the Coast Guard's visit, the OSRO should check personnel records and subcontracting or consulting agreements to verify the number and availability of trained personnel listed in the application. Minimum training should include HAZWOPER training (29 CFR 1910.120). The numbers of personnel may vary from one OSRO to another depending upon unique needs, classification, and the requirements of major equipment. However, the OSRO may use the following schedule to estimate the number of trained personnel needed to accomplish certain response tasks:

(1) Boats: 2 people per boat (or as per Certificate of Inspection)

(2) Boom deployment: 2-5 people per 1000' of boom*, depending upon overall height, weather, current, etc. (probably 2 in harbor environments and 5 in open ocean or high current)

(3) Skimmers: 1-3 people per skimmer, depending on configuration and operating requirements

(4) Storage devices: At least 1 person per storage device

* Numbers are not necessarily cumulative.

The OSRO should be prepared to demonstrate the readiness of its personnel resources, including the following:

(1) Records should verify that training for oil spill response is in accordance with the requirements of 29 CFR 1910.120 (HAZWOPER).

(2) The number of trained personnel employed, subcontracted, or gained through consulting agreements should equal the resources identified by the OSRO in the application.

(3) There should be a demonstrated capability to train sufficient numbers of "surge" personnel in the time allowed by the response classification for which the OSRO has applied.

Reinspection

At the end of the three year classification period, an OSRO will be revisited by a Coast Guard verification team in order to maintain its classification. In between verification visits, the Coast Guard will conduct random spot checks to confirm resource availability and equipment operability.

SECTION 5: CLASSIFICATION REQUIREMENTS

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RIVER AND CANALS ENVIRONMENT

The minimum equipment standards and the maximum response times for classifying OSROs for planned response to spills in a rivers and canals environment are listed below and summarized in Table 1. All equipment to be used in this environment must be capable of operating in 1 foot wave heights. Additional boom requirements are:

Boom height (inches, draft plus freeboard) - 6-18

Reserve Buoyancy to Weight Ratio - 2:1

Total Tensile Strength (lbs) - 4500

Skirt Fabric Tensile Strength (lbs) - 200

Skirt Fabric Tear Strength (lbs) - 100

a: Class A - 50 Bbls/day Recovery

(1) Containment boom: 2,000 feet.

(2) Protective boom: 2,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 50 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 100 Bbls of temporary storage capacity.

(5) Boom deployment response time: 1 hour.

(6) Oil recovery equipment and temporary storage response time: 2 hours.

b. Class B - 1,250 Bbl/day Recovery

(1) Containment boom: 4,000 feet.

(2) Protective boom: 4,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 1,250 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 2,500 Bbls of temporary storage capacity.

(5) Facility response times: 6 hours for high volume ports; all other locations 12 hours.

(6) Vessel response times: 12 hours for high volume ports; all other locations 24 hours.

c. Class C - 1,500 Bbl/day Recovery

(1) Containment boom: 4,000 feet.

(2) Protective boom: 10,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 1,500 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 3,000 Bbls of temporary storage capacity.

(5) Facility response times: 6 hours for high volume ports; all other locations 12 hours.

(6) Vessel response times: 12 hours for high volume ports; all other locations 24 hours

d. Class D - 3,000 Bbl/day Recovery

(1) Containment boom: 4,000 feet.

(2) Protective boom: 16,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 3,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 6,000 Bbls of temporary storage capacity.

(5) Facility response times: 30 hours for high volume ports; all other locations 36 hours.

(6) Vessel response times: 36 hours for high volume ports; all other locations 48 hours.

e. Class E - 6,000 Bbl/day Recovery

(1) Containment boom: 4,000 feet.

(2) Protective boom: 22,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 6,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 12,000 Bbls of temporary storage capacity.

(5) Facility response times: 54 hours for high volume ports; all other locaions 60 hours.

(6) Vessel response times: 60 hours for high volume ports; all other locations 72 hours.

GREAT LAKES ENVIRONMENT

The minimum equipment standards and the maximum response times for classifying an OSRO for planned response to spills in a Great Lakes environment are listed below and summarized in Table 2. All equipment to be used in this environment must be capable of operating in 4 foot wave heights. Additional boom requirements are:

Boom height (inches, draft plus freeboard) - 18-42

Reserve Buoyancy to Weight Ratio - 2:1

Total Tensile Strength (lbs) - 15-20,000

Skirt Fabric Tensile Strength (lbs) - 300

Skirt Fabric Tear Strength (lbs) - 100

a. Class A - 50 Bbls/day Recovery

(1) Containment boom: 2,000 feet.

(2) Protective boom: 6,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 50 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 100 Bbls of temporary storage capacity.

(5) Boom deployment response time: 1 hour.

(6) Oil recovery equipment and temporary storage response time: 2 hours.

b. Class B - 1,250 Bbls/day Recovery

(1) Containment boom: 6,000 feet.

(2) Protective boom: 6,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 1,250 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 2500 Bbls of temporary storage capacity.

(5) Facility response times: 6 hours.

(6) Vessel response times: 12 hours.

c. Class C - 5,000 Bbls/day Recovery

(1) Containment boom: 12,000 feet.

(2) Protective boom: 12,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 5,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 10,000 Bbls of temporary storage capacity.

(5) Facility response times: 12 hours.

(6) Vessel response times: 18 hours.

d. Class D - 10,000 Bbls/day Recovery

(1) Containment boom: 18,000 feet.

(2) Protective boom: 18,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 10,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 20,000 Bbls of temporary storage capacity.

(5) Facility response times: 36 hours.

Vessel response times: 42 hours.

e. Class E - 20,000 Bbls/day Recovery

(1) Containment boom: 24,000 feet.

(2) Protective boom: 24,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 20,000 Bbls/day of effective daily recovery capacity.

(4) Recovered oil storage: 40,000 Bbls of temporary storage capacity.

(5) Facility response times: 60 hours.

(6) Vessel response times: 66 hours.

INLAND ENVIRONMENT

The minimum equipment standards and the maximum response times for classifying an OSRO for planned response to spills in an inland environment are listed below and summarized in Table 3. All equipment to be used in this environment must be capable of operating in 3 foot wave heights. Additional boom requirements are:

Boom height (inches, draft plus freeboard) - 18-42

Reserve Buoyancy to Weight Ratio - 2:1

Total Tensile Strength (lbs) - 15-20,000

Skirt Fabric Tensile Strength (lbs) - 300

Skirt Fabric Tear Strength (lbs) - 100

a. Class A - 50 Bbl/day Recovery

(1) Containment boom: 2,000 feet.

(2) Protective boom: 6,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 50 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 100 Bbls of temporary storage capacity.

(5) Boom deployment response time: 1 hour.

(6) Oil recovery equipment and temporary storage response time: 2 hours.

b. Class B - 1,250 Bbls Recovery

(1) Containment boom: 6,000 feet.

(2) Protective boom: 6,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 1,250 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 2,500 Bbls of temporary storage capacity.

(5) Facility response times: 6 hours for high volume ports; all other locations 12 hours.

(6) Vessel response times: 12 hours for high volume ports; all other locations 24 hours.

c. Class C - 10,000 Bbl/day Recovery

(1) Containment boom: 12,000 feet.

(2) Protective boom: 12,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 10,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 20,000 Bbls/day of temporary storage capacity.

(5) Facility response times: 6 hours for high volume ports; all other locations 12 hours.

(6) Vessel response times: 12 hours for high volume ports; all other locations 24 hours.

d. Class D - 20,000 Bbls/day Recovery

(1) Containment boom: 18,000 feet.

(2) Protective boom: 18,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 20,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 40,000 Bbls of temporary storage capacity.

(5) Facility response times: 30 hours for high volume ports; all other locations 36 hours.

(6) Vessel response times: 36 hours for high volume ports; all other locations 48 hours.

e. Class E - 40,000 Bbl/day Recovery

(1) Containment boom: 24,000 feet.

(2) Protective boom: 24,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 40,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 80,000 Bbls of temporary storage capacity.

(5) Facility response times: 54 hours for high volume ports; all other locations 60 hours.

(6) Vessel response times: 60 hours for high volume ports; all other locations 72 hours.

OCEANS ENVIRONMENT

The minimum equipment standards and the maximum response times for classifying an OSRO for planned response to spills in an oceans environment (includes nearshore, offshore, and open ocean) are listed below and summarized in Table 4. With the exception of shoreline protection boom, all equipment to be used in this environment must be capable of operating in 6 foot wave heights. Additional containment boom requirements are:

Boom height (inches, draft plus freeboard) - > 42

Reserve Buoyancy to Weight Ratio - 3:1 to 4:1

Total Tensile Strength (lbs) - > 20,000

Skirt Fabric Tensile Strength (lbs) - 500

Skirt Fabric Tear Strength (lbs) - 125

Shoreline protection boom requirements are:

Boom height (inches, draft plus freeboard) - > 18

Reserve Buoyancy to Weight Ratio - > 2:1

Total Tensile Strength (lbs) - > 15,000

Skirt Fabric Tensile Strength (lbs) - > 300

Skirt Fabric Tear Strength (lbs) - > 100

a. Class A - 50 Bbl/day Recovery

(1) Containment boom: 4,000 feet.

(2) Protective boom: 6,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 50 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 100 Bbls of temporary storage capacity.

(5) Boom deployment response time: 1 hour.

(6) Oil recovery equipment and temporary storage response time: 2 hours.

b. Class B - 1,250 Bbls Recovery

(1) Containment boom: 8,000 feet.

(2) Protective boom: 8,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 1,250 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 2,500 Bbls of temporary storage capacity.

(5) Facility response times: 6 hours for high volume ports; all other locations 12 hours.

(6) Vessel response times: 12 hours for high volume ports; all other locations 24 hours (for open ocean, plus travel time from shore).

c. Class C - 10,000 Bbl/day Recovery

(1) Containment boom: 12,000 feet.

(2) Protective boom: 12,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 10,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 20,000 Bbls/day of temporary storage capacity.

(5) Facility response times: 6 hours for high volume ports; all other locations 12 hours.

(6) Vessel response times: 12 hours for high volume ports; all other locations 24 hours (for open ocean, plus travel time from shore).

d. Class D - 20,000 Bbls/day Recovery

(1) Containment boom: 18,000 feet.

(2) Protective boom: 18,000 feet.

(3) Oil recovery equipment (skimmers, vacuums, etc.): 20,000 Bbl/day of effective daily recovery capacity.

(4) Recovered oil storage: 40,000 Bbls of temporary storage capacity.

(5) Facility response times: 30 hours for high volume ports; all other locations 36 hours.

(6) Vessel response times: 36 hours for high volume ports; all other locations 48 hours (for open ocean, plus travel time from shore).

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Guidelines for Classifying Oil Spill Removal Organizations

Guidelines for Classifying

Oil Spill Removal Organizations

Table of Contents

Introductory Letter from RADM J. C. Card Chief, Office of Marine Safety, Security and Environmental Protection

GUIDELINES FOR CLASSIFYING OIL SPILL REMOVAL ORGANIZATIONS (OSROS)

a: Class A - 50 Bbls/day Recovery

b. Class B - 1,250 Bbl/day Recovery

c. Class C - 1,500 Bbl/day Recovery

d. Class D - 3,000 Bbl/day Recovery

e. Class E - 6,000 Bbl/day Recovery

a. Class A - 50 Bbls/day Recovery

b. Class B - 1,250 Bbls/day Recovery

c. Class C - 5,000 Bbls/day Recovery

d. Class D - 10,000 Bbls/day Recovery

e. Class E - 20,000 Bbls/day Recovery

a. Class A - 50 Bbl/day Recovery

b. Class B - 1,250 Bbls Recovery

c. Class C - 10,000 Bbl/day Recovery

d. Class D - 20,000 Bbls/day Recovery

e. Class E - 40,000 Bbl/day Recovery

a. Class A - 50 Bbl/day Recovery

b. Class B - 1,250 Bbls Recovery

c. Class C - 10,000 Bbl/day Recovery

d. Class D - 20,000 Bbls/day Recovery

Introductory Letter from RADM J. C. Card
Chief, Office of Marine Safety, Security and Environmental Protection

GUIDELINES FOR CLASSIFYING
OIL SPILL REMOVAL ORGANIZATIONS (OSROS)