We refer to our Circulars of 21 July and 10 August 1999. The California Office of Oil Spill Prevention and Response (OSPR) has advised that the final Non-Tank Vessel Contingency Plan Regulations have been approved and filed with the California Secretary of State. Non-Tank Vessel Contingency Plans must accordingly be submitted to the OSPR on or before 3 February 2000.
The final regulations contain few substantive differences from the previously amended draft version; however, members who wish to review the text of the final regulations may access them on the California Department of Fish & Game home page.
Members who do not have access to the Internet may obtain copies by writing the California Department of Fish & Game, 1416 Ninth Street, P.O. Box 944209, Sacramento, CA 94244-2090 (telephone 916-445-9338; fax 916-324-5662).
Non-tank vessel owners who have enrolled their vessels with O'Brien's Oil Pollution Services under Skuld's member contract will have their contingency plans submitted in the approved format directly to the California OSPR by O'Briens prior to the 3 February deadline. Members who have not enrolled in this program should be aware that the current Pacific Merchant Shipping Association (PMSA) vessel enrolment agreement does not conform with International Group guidelines. For this reason the Association cannot at the present time accept enrolment by non-tank vessel members in the PMSA plan. Skuld has been advised that the PMSA agreement and its subcontracts have been revised and re-submitted to the International Group Pollution Sub-Committee and that approval may be forthcoming shortly. As soon as approval is granted, Skuld will issue details on its website. To avoid any possible disruption in their operations, however, non-tank vessel members whose vessels are scheduled to call at California ports during the month of February may wish to consider utilising the services of O'Brien's Oil Pollution Services and the Marine Spill Response Corporation (MSRC) described in Skuld's Circular of 21 July 1999.
Members are also reminded that the contingency plan must reference the California Certificate of Financial Responsibility (COFR) number for the non-tank vessel(s) covered by the plan. Documentation that a California COFR application has been submitted and is being processed by OSPR will fulfill this requirement. Members requiring further information or guidance should feel free to contact the Association or its United States general correspondents, Anchor Marine Claims Services, at any time.