Port Notes: Meeting Regulatory Requirements for Response - Part 1

From the Desk of Captain Jeffrey Monroe, MM, AMPE

Most ports and terminals depend on local firefighting personnel or their own firefighters to meet the requirements of 33 CFR Part 155: the section of the US Code of Federal Regulations which covers oil or hazardous materials pollution prevention and response. It may surprise some folks that this section of the CFR can extend beyond tankers to the other types of vessels that most ports handle: container ships, cruise ships, and bulk vessels can face emergency situations that require response by other than port or terminal personnel. Recognizing the impacts of the regulations, as well as the Oil Pollution Act of 1990, several ports organized cooperative teams to address incidents within the collective port area. In the 1990’s, for example, the Commonwealth of Massachusetts, the Massachusetts Port Authority, the US Coast Guard, and the communities around Boston formed the Marine Incident Response Team (MIRT). The MIRT mission was designed to provide intelligence, reconnaissance, and mitigation capabilities for incidents occurring in the maritime environment. Since MIRT’s inception, its coverage area has expanded to include the entire Massachusetts Coastline and respective ports.

In the case of 33 CFR Part 155, what is the impact for ports? Overall, public agencies are in the best position to bring together key personnel from various state agencies as well as the US Coast Guard. Cooperation and practices are best established before an incident, and such preparation must include outlining jurisdictions and the means of addressing an incident. Training is the key: what was discovered in the 1990’s was that while firefighters are highly skilled, some were unfamiliar with the port or terminal’s environment and vessels. While specific training objectives are not outlined in the CFR, it is imperative that any port that handles vessels should develop a program that involves all first responders and agencies to see that an incident is addressed effectively and safely. In order to be effective, training should be specific and address the potential emergencies relative to the vessels being handled in a port or at a terminal, big or small. While our big coastal ports in the US and Canada have good systems in place, many smaller ports depend on local fire departments, some volunteer, to address emergencies in the port area. To that end, each port agency, terminal operator, and carrier should reach out to the US Coast Guard and their local communities to develop a program of training and drills to insure that in case of an emergency, response is effective and the lives of responders are protected.