August 23, 2019 Vessel Specific NTVRPs are Required to Enter U.S. Waters
There are unique requirements for vessels coming into the United States and its territories, and not adhering to them may mean a denial of entry and/or a substantial fine. One item in particular that often slips through the cracks is the Non-Tank Vessel Response Plan (NTVRP).
The NTVRP requirement went into effect on 31 January 2014, and the USCG has since taken a zero-tolerance stance whereby all foreign flagged vessels (private and commercial) of 400 GT and above must have an NTVRP prior to coming into U.S. territorial waters. This includes the US Virgin Islands, American Somoa, Guam, Northern Mariana Islands, and Puerto Rico.
In order to obtain an NTVRP, a vessel is required to contract with a U.S. Based company that holds an Authorization Number and that has an approved Qualified Individual (QI) assigned to the vessel. Dayboard’s QI works with the vessel throughout the year to ensure it meets the requirements for the quarterly drills and annual exercises, which is something the USCG checks up on during a Port State Control inspection.
The QI is akin to a DPA and is the vessel’s primary point of contact should a spill occur and will assist the vessel in coordinating with the Oil Spill Response Organization (OSRO) and Salvage and Marine Fire Fighting (SMFF) providers.
Captains and Management Companies shouldn’t underestimate the
amount of time it takes to have an NTVRP created and approved. At the time of writing, the USCG is currently quoting 4-6 weeks from the receipt of the plan to approval. It is very important to note that entry is not allowed until the USCG issues the Approval Letter for the NTVRP.
Prior to submitting the plan to the USCG, however, there are a number of documents and other pieces of information we must receive from the vessel. For example, Tank Details, General Arrangement, Fire Plan, and insurance details, to name a few.
Many in the industry are not aware that an NTVRP is still a requirement if you are being transported via a ship, such as Dockwise or Sevenstar. Prior to disembarking, you will be required to show proof of having your NTVRP in place.
To further complicate matters, California, Hawaii, and Alaska each have their own unique requirements prior to entering into those States.
If you’re traveling to a US jurisdiction, we recommend getting your information and documents to us sooner rather than later. While we are often times able to have the NTVRP approved by the USCG sooner than the quoted 4 – 6 weeks, it is always best to be well prepared.
If you’re interested in a full breakdown of the NTVRP requirements, click here to see the U.S. CFRs.
Don’t get caught with your anchors down!
John W. Smith is a former USCG Boarding Officer and the Qualified Individual for Dayboard as recognized by the USCG, SMFF, and OSRO. He has successfully submitted NTVRPs for hundreds of vessels since its inception.