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QUARTERLY DRILLS

Learn more about the regulatory requirements for quarterly drills

In order to ensure plan-holders are prepared to respond to various emergencies, many regulatory agencies require that plans be drilled quarterly to test the personnel and processes identified in the plan. Read on to learn more about which regulations apply to your business.

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Response Plans

dRILLING rESPONSE pLANS

According to the 2016 National Preparedness for Response Exercise Program (NPREP) Guidelines, a drill is defined as "an operations-based exercise employed to validate a specific function or capability that is commonly used to provide training, validate procedures, or practice and maintain current skills."

RESPONSE PLANS (WA)

WA ECY

The following drills shall be conducted within each triennial cycle. (1) Tabletop drills: Tabletop drills are intended to demonstrate a plan holder's capability to manage a spill using the incident command system (ICS). Role playing shall be required in this drill. During all required tabletop drills plan holders must provide a master list of equipment and personnel identified to fill both command post and field operations roles. The master resources list must include: (a) Western regional response list identification numbers for all response resources; and (b) Personnel names, affiliation, home base and command post or field role. (2) Once during each three year cycle, the plan holder shall ensure that key members of the regional/national "away" team as identified in the plan shall be mobilized in state for a drill. However, at ecology's discretion, team members that are out-of-state may be evaluated in out-of-state tabletop drills if ecology has sufficient notice, an opportunity to participate in the drill planning process, and provided that the out-of-state drills are of similar scope and scale to what would have occurred in state. In this case, key away team members shall be mobilized in this state at least once every six years. (3) Plan holders covering multiple vessels and ecology shall together design a systematic approach to, over time, involve all spill management teams identified in WAC 173-182-230 (6)(a) in tabletop and deployment drills as a best practice to demonstrate the preparedness of enrolled vessel members. These drills will be scheduled by the plan holder or unannounced to be conducted by ecology, at the discretion of ecology. These drills may test any plan components but at a minimum will include notification to the enrolled vessel qualified individual, coordination of supplemental resources under WAC 173-182-232 and the transition from the plan holder spill management team to the enrolled vessel company spill management team. (4) Equipment deployment drills: Plan holders shall use deployment drills to demonstrate the actions they would take in a spill, including: Notifications, safety actions, environmental assessment, and response equipment deployment. (a) During the triennial cycle, deployment drills shall include a combination of plan holder owned assets, contracted PRC assets, nondedicated assets, and vessels of opportunity. (b) Plan holders should ensure that each type of dedicated equipment listed in the plan and personnel responsible for operating the equipment are tested during each triennial cycle. Plan holders must design drills that will demonstrate the ability to meet the planning standards, including recovery systems and system compatibility and the suitability of the system for the operating environment. Drills shall be conducted in all operating environments that the plan holder could impact from spills. (c) At least twice during a triennial cycle, plan holders shall deploy a geographic response plan (GRP) strategy identified within the plan. If no GRPs exist for the operating area, plan holders will consult with ecology to determine alternative sensitive areas to protect. (d) Plan holders may request credit for the prebooming of an oil transfer provided the transfer is scheduled as a deployment on the drill calendar. Such credit may only be requested once per triennial cycle. (5) Plan holders may receive credit for deployment drills conducted by PRCs if: (a) The PRC is listed in the plan; and (b) The plan holder operates in the area, schedules on the drill calendar, and participates in or observes the drill. (6) Additional large-scale multiple tank vessel plan holder equipment deployment drill requirement. Once every three years all tank vessel plan holders, including plan holders that enroll multiple tank vessels, must participate in a multiple plan holder deployment exercise. At least one plan holder shall be the drill planning lead, participate in all the planning meetings and observe the drill. This deployment may include the following objectives: (a) Demonstration of dedicated and nondedicated equipment and trained contracted personnel; (b) Demonstration of contracted vessel of opportunity response systems and crew performing operations appropriate to the vessel capabilities; (c) Demonstration of multiple simultaneous tactics including: (i) On-water recovery task forces made up of complete systems which demonstrate storage, recovery, and enhanced skimming; (ii) Protection task forces which deploy multiple GRPs; (iii) Vessel and personnel decontamination and disposal; (iv) Deployment of contracted aerial assessment assets and aerial observers to direct skimming operations; and (v) Personnel and equipment identified for night operations. (d) Verification of the operational readiness during both the first six hours of a spill and over multiple operational periods. (7) Additional deployment requirement for vessel plan holders with contracted access to the ERTV. Once every three years plan holders with contracted access to the ERTV must cosponsor a drill that includes deployment of the ERTV, unless ERTV drill credit has already been received under WAC 173-182-242 (1)(e). This drill must be scheduled on the area exercise calendar. The drill shall include at a minimum: (a) Notifications and tug call out; (b) Safety and environmental assessment; (c) Demonstration of making up to, stopping, holding, and towing a drifting or disabled vessel; (d) Demonstration of the capability to hold position within one hundred feet of another vessel; and (e) Communications. (8) Additional deployment requirement for all plan holders. Once every three years plan holders must deploy regional mobile wildlife rehabilitation equipment and personnel necessary to set up the wildlife rehabilitation system found in the plan. This is an additional deployment drill unless it is incorporated into a large multiobjective deployment drill. (9) For all plan holders, ecology may initiate scheduled inspections and unannounced deployment and tabletop drills. (a) In addition to the drills listed above, ecology will implement a systematic scheduled inspection and unannounced drill program to survey, assess, verify, inspect or deploy response equipment listed in the plan. This program will be conducted in a way so that no less than fifty percent of the resources will be confirmed during the first triennial cycle, and the remaining fifty percent during the subsequent triennial cycle. (b) Unannounced drills may be initiated by ecology when specific problems are noted with individual plan holders, or randomly, to strategically ensure that all operating environments, personnel and equipment readiness have been adequately tested. (c) Unannounced notification drills are designed to test the ability to follow the notification and call-out process in the plan. (d) Immediately prior to the start of an unannounced deployment or tabletop drill, plan holders will be notified in writing of the drill objectives, expectations and scenario. (e) Plan holders may request to be excused if conducting the drill poses an unreasonable safety or environmental risk, or significant economic hardship. If the plan holder is excused, ecology will conduct an unannounced drill at a future time.

PIPELINE RESPONSE PLANS

DOT PHMSA

Response plan: Section 7. Drill Procedures Section 7 would include a description of the drill procedures and programs the operator uses to assess whether its response plan will function as planned. It would include: (a) Announced and unannounced drills; (b) The types of drills and their frequencies. For example, drills could be described as follows: (1) Manned pipeline emergency procedures and qualified individual notification drills conducted quarterly. (2) Drills involving emergency actions by assigned operating or maintenance personnel and notification of the qualified individual on pipeline facilities which are normally unmanned, conducted quarterly. (3) Shore-based spill management team tabletop drills conducted yearly. (4) Oil spill removal organization field equipment deployment drills conducted yearly. (5) A drill that exercises the entire response plan for each response zone, would be conducted at least once every 3 years.

VESSEL RESPONSE PLANS

USCG

§ 155.1060 Exercises. (a) A vessel owner or operator required by § 155.1035, § 155.1040, or § 155.5035 to have a response plan shall conduct exercise as necessary to ensure that the plan will function in an emergency. Both announced and unannounced exercises must be included. The following are the minimum exercise requirements for vessels covered by this subpart: (1) Qualified individual notification exercises, which must be conducted quarterly; (2) Emergency procedures exercises, which must be conducted quarterly; (3) Shore-based spill management team tabletop exercises, which must be conducted annually. In a triennial period, at least one of these exercises must include a worst case discharge scenario; (4) Oil spill removal organization equipment deployment exercises, which must be conducted annually; and (5) An exercise of the entire response plan, which must be conducted every 3 years. The vessel owner or operator shall design the exercise program so that all components of the response plan are exercised at least once every 3 years. All of the components do not have to be exercised at one time; they may be exercised over the 3-year period through the required exercises or through an area exercise. (b) Annually, at least one of the exercises listed in § 155.1060(a) (2) and (4) must be unannounced. An unannounced exercise is one in which the personnel participating in the exercise have not been advised in advance of the exact date, time, and scenario of the exercise. (c) A vessel owner or operator shall participate in unannounced exercises, as directed by the Coast Guard COTP. The objectives of the unannounced exercises will be to evaluate notifications and equipment deployment for responses to average most probable discharge spill scenarios outlined in vessel response plans. The unannounced exercises will be limited to four per area per year, an area being that geographic area for which a separate and distinct Area Contingency Plan has been prepared, as described in the Oil Pollution Act of 1990. After participating in an unannounced exercise directed by a COTP, the owner or operator will not be required to participate in another unannounced exercise for at least 3 years from the date of the exercise. (d) A vessel owner or operator shall participate in area exercises as directed by the applicable on-scene coordinator. The area exercises will involve equipment deployment to respond to the spill scenario developed by the exercise design team, of which the vessel owner or operator will be a member. After participating in an area exercise, a vessel owner or operator will not be required to participate in another area exercise for at least 6 years. (e) The vessel owner or operator shall ensure that adequate exercise records are maintained. The following records are required: (1) On board the vessel, records of the qualified individual notification exercises and the emergency procedures exercises. These exercises may be documented in the ship's log or may be kept in a separate exercise log. (2) At the United States' location of either the qualified individual, spill management team, the vessel owner or operator, or the oil spill removal organization, records of exercises conducted off the vessel. Response plans must indicate the location of these records. (f) Records described in paragraph (e) of this section must be maintained and available to the Coast Guard for 3 years following completion of the exercises. (g) The response plan submitted to meet the requirements of this subpart must specify the planned exercise program. The plan shall detail the exercise program, including the types of exercises, frequencies, scopes, objectives, and the scheme for exercising the entire response plan every 3 years. (h) Compliance with the National Preparedness for Response Exercise Program (PREP) Guidelines will satisfy the vessel response plan exercise requirements. These guidelines are available from the TASC DEPT Warehouse, 33141Q 75th Avenue, Landover, MD 20875 (fax: 301-386-5394, stock number USCG-X0241). Compliance with an alternative program that meets the requirements of paragraph (a) of this section and has been approved under § 155.1065 will also satisfy the vessel response plan exercise requirements.

RESPONSE PLANS (CA)

CA OSPR

(A) Facility Notifications. For all facility and mobile transfer unit oil spill contingency plans, actual telephonic notifications must be conducted by the plan holder each quarter to test and achieve the objective described in subsection (g)(1). For oil spill contingency plans with assets in or operating in more than one region, facility notifications must occur in each region each quarter so that staff in each region will be proficient in making the required notifications. When a drill or exercise is held and the Notifications objective is successfully achieved, this will fulfill the facility notification requirement for the applicable region and quarter. (B) Vessel Notifications. For all vessel oil spill contingency plans, an actual telephonic notification must be made by the plan holder each quarter, or at least 72 hours prior to entering waters of the state if that is less often, to test and achieve the objective described in subsection (g)(2).

FACILITY RESPONSE PLANS (INLAND)

EPA

§ 112.21 Facility response training and drills/exercises. (a) The owner or operator of any facility required to prepare a facility response plan under § 112.20 shall develop and implement a facility response training program and a drill/exercise program that satisfy the requirements of this section. The owner or operator shall describe the programs in the response plan as provided in § 112.20(h)(8). (b) The facility owner or operator shall develop a facility response training program to train those personnel involved in oil spill response activities. It is recommended that the training program be based on the USCG's Training Elements for Oil Spill Response, as applicable to facility operations. An alternative program can also be acceptable subject to approval by the Regional Administrator. (1) The owner or operator shall be responsible for the proper instruction of facility personnel in the procedures to respond to discharges of oil and in applicable oil spill response laws, rules, and regulations. (2) Training shall be functional in nature according to job tasks for both supervisory and non-supervisory operational personnel. (3) Trainers shall develop specific lesson plans on subject areas relevant to facility personnel involved in oil spill response and cleanup. (c) The facility owner or operator shall develop a program of facility response drills/exercises, including evaluation procedures. A program that follows the National Preparedness for Response Exercise Program (PREP) (see appendix E to this part, section 13, for availability) will be deemed satisfactory for purposes of this section. An alternative program can also be acceptable subject to approval by the Regional Administrator.

FACILITY RESPONSE PLANS (MARINE)

USCG

§ 154.1055 Exercises. (a) A response plan submitted by an owner or operator of an MTR facility must include an exercise program containing both announced and unannounced exercises. The following are the minimum exercise requirements for facilities covered by this subpart: (1) Qualified individual notification exercises (quarterly). (2) Spill management team tabletop exercises (annually). In a 3-year period, at least one of these exercises must include a worst case discharge scenario. (3) Equipment deployment exercises: (i) Semiannually for facility owned and operated equipment. (ii) Annually for oil spill removal organization equipment. (4) Emergency procedures exercises (optional). (5) Annually, at least one of the exercises listed in § 154.1055(a)(2) through (4) must be unannounced. Unannounced means the personnel participating in the exercise must not be advised in advance, of the exact date, time and scenario of the exercise. (6) The facility owner or operator shall design the exercise program so that all components of the response plan are exercised at least once every 3 years. All of the components do not have to be exercised at one time; they may be exercised over the 3-year period through the required exercises or through an Area exercise. (b) A facility owner or operator shall participate in unannounced exercises, as directed by the COTP. The objectives of the unannounced exercises will be to test notifications and equipment deployment for response to the average most probable discharge. After participating in an unannounced exercise directed by a COTP, the owner or operator will not be required to participate in another COTP initiated unannounced exercise for at least 3 years from the date of the exercise. (c) A facility owner or operator shall participate in Area exercises as directed by the applicable On-Scene Coordinator. The Area exercises will involve equipment deployment to respond to the spill scenario developed by the Exercise Design Team, of which the facility owner or operator will be a member. After participating in an Area exercise, a facility owner or operator will not be required to participate in another Area exercise for at least 6 years. (d) The facility owner or operator shall ensure that adequate records of all required exercises are maintained at the facility for 3 years. Records shall be made available to the Coast Guard upon request. (e) The response plan submitted to meet the requirements of this subpart must specify the planned exercise program. The plan must detail the exercise program, including the types of exercises, frequency, scope, objectives and the scheme for exercising the entire response plan every 3 years. (f) Compliance with the National Preparedness for Response Exercise Program (PREP) Guidelines will satisfy the facility response plan exercise requirements. These guidelines are available from the TASC DEPT Warehouse, 33141Q 75th Avenue, Landover, MD 20875 (fax: 301-386-5394, stock number USCG-X0241). Compliance with an alternative program that meets the requirements of paragraph (a) of this section and has been approved under § 154.1060 will also satisfy the facility response plan exercise requirements.

Drilling Security Plans

A security drill is defined in 33 CFR 101.105 as "a training event that tests at least one component of the [Area Maritime Security], vessel, or facility security plan and is used to maintain a high level of security readiness.

FACILITY SECURITY PLANS

USCG

§ 105.220 Drill and exercise requirements. (a) General. (1) Drills and exercises must test the proficiency of facility personnel in assigned security duties at all MARSEC Levels and the effective implementation of the Facility Security Plan (FSP). They must enable the Facility Security Officer (FSO) to identify any related security deficiencies that need to be addressed. (2) A drill or exercise required by this section may be satisfied with the implementation of security measures required by the FSP as the result of an increase in the MARSEC Level, provided the facility reports attainment to the cognizant COTP. (b) Drills. (1) The FSO must ensure that at least one security drill is conducted every 3 months. Security drills may be held in conjunction with non-security drills, where appropriate. (2) Drills must test individual elements of the FSP, including response to security threats and incidents. Drills should take into account the types of operations of the facility, facility personnel changes, the type of vessel the facility is serving, and other relevant circumstances. Examples of drills include unauthorized entry to a restricted area, response to alarms, and notification of law enforcement authorities. (3) If a vessel is moored at the facility on the date the facility has planned to conduct any drills, the facility cannot require the vessel or vessel personnel to be a part of or participate in the facility's scheduled drill.

VESSEL SECURITY PLANS

USCG

§ 104.230 Drill and exercise requirements. (a) General. (1) Drills and exercises must test the proficiency of vessel personnel in assigned security duties at all Maritime Security (MARSEC) Levels and the effective implementation of the Vessel Security Plan (VSP). They must enable the Vessel Security Officer (VSO) to identify any related security deficiencies that need to be addressed. (2) A drill or exercise required by this section may be satisfied with the implementation of security measures required by the Vessel Security Plan as the result of an increase in the MARSEC Level, provided the vessel reports attainment to the cognizant COTP. (b) Drills. (1) The VSO must ensure that at least one security drill is conducted at least every 3 months, except when a vessel is out of service due to repairs or seasonal suspension of operation provided that in such cases a drill must be conducted within one week of the vessel's reactivation. Security drills may be held in conjunction with non-security drills where appropriate. (2) Drills must test individual elements of the VSP, including response to security threats and incidents. Drills should take into account the types of operations of the vessel, vessel personnel changes, and other relevant circumstances. Examples of drills include unauthorized entry to a restricted area, response to alarms, and notification of law enforcement authorities. (3) If the vessel is moored at a facility on the date the facility has planned to conduct any drills, the vessel may, but is not required to, participate in the facility's scheduled drill. (4) Drills must be conducted within one week from whenever the percentage of vessel personnel with no prior participation in a vessel security drill on that vessel exceeds 25 percent. (5) Not withstanding paragraph (b)(4) of this section, vessels not subject to SOLAS may conduct drills within 1 week from whenever the percentage of vessel personnel with no prior participation in a vessel security drill on a vessel of similar design and owned or operated by the same company exceeds 25 percent.
Security Plans
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