John Allen, SCAA Outreach Director, reached out to several of our members in late June requesting comments on the status of their spill response preparedness and involvement in 2020 PREP exercises since the beginning of the calendar year. The Pipeline and Hazardous Material Safety Administration (PHMSA) had asked SCAA if and how the coronavirus is affecting our members’ response preparedness. Several members responded below, the last of which is very comprehensive. We hope this is helpful information:
One member company just finished up a table top for one of their clients who provides mobile service for fueling barges/tugs providing over-the-water fuel transfers. It was the first one since early March. This member is getting back into the swing of things and is adhering to modified means and methods - face coverings, social distances, remote meetings, etc.
Another member company is continuing to support all regulatory and customer activity related to OSRO classification. Many drills and exercises are supported virtually, but equipment deployments and training exercises are still being carried out.
Another member company continues to respond to casualty events on a daily basis and remain vigilant to respond as needed for live events, tabletop exercises, full deployment exercises and GIUE’s as may be required. This company’s president feels confident that you will find the same to me true with our SCAA response community.
Another member company has no issues meeting the regulatory requirements. Since the COVID onset, they have effectively responded to actual spill incidents and have participated in virtual PREP exercises, maintaining a consistent response preparedness throughout.
Really good topic and I can provide some recommendations or at least my perspective. Our company uses PREP as its OSRO programs foundation. COVID-19 has provided some unique challenges for sure but emergencies are still going to happen and the good OSRO’s and Plan Holders will want to make sure the policies and procedures they have to deal with the pandemic can adapt to a true emergency response. It’s our business. April 23 of this year, we had scheduled a TTX in Jacksonville. It was a WCD and the objective was to manage through the initial response phase of an event and to prepare a ICS 201 that we could use for a company-wide TTX. Due to social distancing, we did the majority of the planning and coordinating using Goto Meeting and essentially set up a virtual ICP. Our company, at the beginning of the pandemic had set up a COVID-19 task force that developed policies and procedures that were consistent with CDC guidelines and were put in place to protect our employees and ensure we could continue to service our clients. For the initial response, we used those guidelines to help support the logistics portion of our response as well.
If you really think about it, it is or could be treated like a inject during a TTX. For example, you have a response going and you just found out that a responder has symptoms and then goes to the doctors and tests positive for COVID. Oh, by the way, he was in close contact during a shoreline clean-up operation and was working with 25 other beach cleaners for 12 hours for the past 4 day. Now what? In today’s world, that is an absolute possibility which could bring a response to a grinding halt and potentially have a negative impact on the environment pending the overall event. Understanding how to deal with that while keeping the remaining responders healthy and continuing to meet the overall response objectives should be a good lessons learned and discussion. More importantly, what have we learned to this point about how the virus spreads? Can the basic fundamentals of face coverings and distancing but be effective during an emergency response. I think that is a really good question. During some responses, you may say yes. During others, it may be a little harder to say yes and it may be a hard NO. If that is the case, then what? Should plan holders have a plan to test responders? Or should OSRO’s have that as part of their response? Look at what the NBA is doing to get the remainder of their season in. Should every response create a “bubble” around the response organization and manage all 24 hrs of the day so potential impacts are reduced? With something like COVID, learning to adapt policies and procedures in a controlled environment would be ideal and provide much more of a learning opportunity to address what needs to be improved to keep responders healthy and safe. Obviously this could be costly but in today’s world, that may be the price of doing business in order to protect employees and meet response objectives. Having those conversations now with a plan holder and figuring out the logistics and financial impact will be an easier conversation during an exercise.
We have been engaged in several events over the last couple months and have been able to adapt our “new normal” to our ability to manage and respond to larger events. We have seen limited GIUE from the USCG but anticipate those ramping up. For the most part our requirements for equipment deployment under PREP are met annually from actual responses. We do have some training and deployments scheduled in the later part of July and August for a couple of our Co-op’s. That will be a good time to continue to maintain a disciplined approach and refine our procedures for dealing with COVID. We, as many companies probably are, are preparing for a potential increase in cases in the fall or even sooner. Our ability to maintain our workforce while staying at the ready for our clients is one of our top objectives for the remainder of 2020. Oh, I forgot about Hurricane Season. Could be an active one...
Lastly, to address the credit a Plan Holder or Holders get for an OSRO’s equipment deployment, it depends what is important. Is it important just to check a box or is it important to have an understanding of the overall capabilities of the OSRO and what the expectations are on both sides. I have always said that the best responses are a result of practice and established expectations. The more familiar a Plan Holder is with an OSRO and an OSRO is with a Plan Holder, the better a response will go. That also goes for GIUE. If a Plan Holder has confidence in their OSRO or the plan the OSRO developed to help them meet response time requirements, the better communication would go with the USCG onsite. It sounds simple but more times than not, it is a financial decision to not exercise the OSRO and the first time they are working together tends to be on an actual event. No matter how good and OSRO is, if there has not been familiarity with a Plan Holders facility or operation, a response will not go as good as it could have.
As far as COVID, this is a really good topic and I think challenging in the fact that our work and how we do it effectively doesn’t necessarily sync with CDC recommendations on how to stop the spread. We are a labor intensive business that provides hands on expertise that we cannot perform if sheltered in place.
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