Guidance

UK national standard for marine oil spill response organisations

Updated 20 December 2023

1. Definitions

Name	Definition
Accreditation	In the context of this document, and that of the OPRC Guidelines, and the Guidance Notes for Preparing Oil Pollution Emergency Plans, ‘Accreditation’ refers to the process of external audit and validation undergone by an Oil Spill Response Organisation to ensure that they comply with the minimum requirements to deliver Tier 2 oil spill response services in the UK, as outlined in the UK Standard (hereafter referred to as “the Standard”. The use of the word “Accreditation” in this document does not imply accreditation as defined in EU Regulation 765/2008 and is not to be confused with services provided by the national accreditation body for the UK, the United Kingdom Accreditation Service
Accredited oil spill response organisation	An organisation that has complied with the Standard and has undergone a process of external audit to verify this, conducted by an MCA/DESNZ approved Accrediting Body
Approved Accrediting Body	The ‘Accrediting Body’ is the organisation that reviews, checks and verifies that the Oil Spill Response Organisation seeking accreditation meets the Standard in the categories of response they are applying for. These organisations must have gained approval to carry out this activity from the MCA and DESNZ. Approval will be granted on the basis that the organisation in question is applying the Standard outlined in this document, fulfils the Accreditation Process Requirements in Appendix 4a and meets the specified minimum requirements for Accrediting Bodies in Appendix 5
Basic seamanship skills	The knowledge, skills and ability necessary for a responder to deploy counter pollution equipment efficiently and safely from a vessel. The type of ship will be different for each area of operation, but for each appropriate vessel type the responder should have a good knowledge of the layout and particulars, ship terminology, safe working practices, appropriate knots, lashings, wires, shackles, anchors and the impact of towing or deploying equipment on the characteristics of vessel handling
Client Risk Profile	A document which briefly outlines an OSRO’s client base, giving details of areas of operation e.g. a client base consisting of purely sheltered/enclosed water requirements
Sheltered / inshore / coastal / ocean boom	Due to the myriad of type and descriptions the assessor will draw from the definitions from the boom manufacturers
Short notice	Defined as less than 24 hours
Standard	The minimum requirements necessary to deliver Tier 2 service provision to UK ports, harbours, oil handling facilities and offshore installations
Temporary storage	This should be appropriate to the conditions in which the storage is being deployed i.e. if at sea, storage must be covered, sealed and secure to prevent secondary spills

2. Abbreviations

Abbreviation	Full name
DESNZ	Department for Energy and Net Zero
IAP	Incident Action Plan
IOGP	International Association of Oil and Gas Producers
IPIECA	International Petroleum Industry Environmental Conservation Association
ITOPF	International Tanker Owners Pollution Federation
MCA	Maritime and Coastguard Agency
OPEP	Oil Pollution Emergency Plan
OPRED	Offshore Petroleum Regulator for Environment and Decommissioning
OSCP	Oil Spill Contingency Plan
OSRO	Oil Spill Response Organisation
RoOMP	Responder of Opportunity Management Plan
SOP	Standard Operating Procedure

3. Introduction and application

3.1.1 The Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998 (SI 1988 No.1056) (as amended) state that certain UK ports, harbours and oil-handling facilities ^{[footnote 1]} and all offshore installations on the UK Continental Shelf must submit OPRC Plans to the Maritime and Coastguard Agency (MCA) (in the case of ports, harbours and oil handling facilities) or the Department for Business, Energy and Industrial Strategy (in the case of offshore installations or oil handling facilities which are pipelines) for approval.

3.1.2 As part of the approvals process for ports, harbours and oil handling facilities to which the Regulations apply, the MCA require contingency plans to detail the contract they hold with an accredited third-party Tier 2 Marine Oil Spill Response Organisation (hereafter referred to as “OSRO”).

3.1.3 DESNZ similarly require responsible persons of offshore installations and oil handling facilities which are pipelines to detail in Oil Pollution Emergency Plans (OPEPs) any arrangements in place with an OSRO.

3.1.4 This document outlines the MCA and DESNZ agreed minimum standard for OSROs. The Standard can only be applied by MCA or DESNZ approved accreditation bodies in their accreditation of OSROs for contracts held with UK ports, harbours, oil handling facilities and offshore installations. In their approval of OSCPs and OPEPs, the MCA and DESNZ will only recognise OSROs accredited under approved schemes which apply the Standard.

Nothing in this document supersedes or replaces requirements contained in MCA’s OPRC Guidance for Ports or DESNZ Guidance Notes for Preparing OPEPs.

3.2 Structure of the Standard

3.2.1 The Standard is in 5 parts, some parts relating to OSROs themselves and others to the Accrediting Bodies:-

1) Capability Assessments – this section outlines requirements for OSROs to manage the collective risk posed by their contractual obligations and assesses whether they have applied for the correct categories of response for their client base. The requirements for Capability Assessments are outlined in Appendix 1.

2) Foundation Requirements – this section lists the Foundation Requirements applicable to all OSROs. It requires OSROs to outline their overall capability (with some required information only applicable to specific response categories) and to ensure that this capability is supported by a reliable and competent organisational infrastructure. The Foundation Requirements are outlined in Appendix 2.

3) Category Specific Response Capability – OSROs must provide details on their response capability for each category of response they propose to provide. Categories are areas of operation or type of operation (e.g. oil containment and recovery, aerial dispersant application etc). Qualification for any one of the response categories is the minimum level of capability required to conduct a response operation in that category.

The response categories are:

1. Dispersant Application – marine and / or air deployed;
2. Dispersant Application – offshore oil and gas activities;
3. Sheltered/Enclosed Waters – ports, harbours, enclosed lochs etc.;
4. Coastal and Large Estuary – exposed shorelines, large estuaries etc.;
5. Offshore waters – all unsheltered waters;
6. Offshore Oil and Gas Activities (including pipelines) – locations arising from releases of oil into the sea during offshore oil and gas activities; and
7. Shoreline Clean Up – applicable to inter-tidal zones and includes all shoreline types

OSRO’s may wish to meet the standard in either a single category or multiple categories. Capability may be owned or contracted, both of which are subject to meeting the foundation requirements and, if applicable, the category specific capability requirements.

The minimum entry requirements for each defined category of response are detailed in Appendix 3.

4) Accreditation Process Requirements – this section details the checks which must be made by Accrediting Bodies when conducting accreditations/audits. The Requirements for the Accreditation Process can be found in Appendix 4.

5) Requirements for Accrediting Bodies – these are the minimum requirements for the Accrediting Bodies themselves, which must be met for any organisation wishing to be approved. The Requirements for Accrediting Bodies can be found in Appendix 5.

3.3 Accreditation process

3.3.1 Accrediting Bodies who intend for their schemes to be recognised by the MCA and DESNZ must apply the specific standards framework described in this document in their accreditations and meet the requirements outlined in Appendices 4 and 5. The accreditation process will conform to the following format:

• Accreditation will run for a 3-year period, with a grace period of 3 months for re-accreditation;
• Accreditation renewal dates will remain the same, the day accreditation was originally achieved, with a leeway of three months either side of that date to be re-accredited. For example, if accreditation is awarded on 31 March 2029, renewal audit can take place between 1 January 2032 and 30 June 2032, but the date of renewal will remain the 31 March 2032;
• At least once every three years the accreditation body, who may be accompanied by a qualified observer (for example a MCA Counter Pollution and Salvage Officer or OPRED Inspector) will observe an actual spill response or practical exercise deployment reflecting the OSRO’s Capability Statement. The exercise or actual spill response will not necessarily have to demonstrate every aspect of an OSRO’s capability; this may not be practical or appropriate where an OSRO is accredited in more than one category. Instead, the exercise or actual spill response should demonstrate that the OSRO can apply the equipment, techniques and strategies appropriate to the scenario in question within agreed timeframes (e.g. MCA/DESNZ requirements or contractual requirements), that personnel have the required level of knowledge, skill and professionalism and that the deployment is managed through effective command and control structures, good communication and demonstration of good health and safety practices; and
• If the observed exercise is being conducted on behalf of a port as a Tier 2 Mobilisation Exercise, additional minimum requirements should be met. Please refer to Appendix 10. OSROs should demonstrate interoperability with local and/or port authorities as part of the exercise. Where this is not intrinsic (for example, as part of a Tier 2 Mobilisation Exercise), it should be demonstrated by another means such as roleplay or by inviting another stakeholder to fill that role.
• OSROs should liaise with the Accrediting Body in the planning phase of exercises. This is especially true for those OSROs accredited to several Modules, in order to ensure that the planned deployment demonstrates capability appropriate to the range of accredited modules.

3.3.2 Exercise or actual response in lieu of certain audit checks

3.3.2.1 Exercises or actual incident response, attended by a suitably qualified auditor, may preclude the need for certain scheduled audit checks, providing the exercise or response in question effectively demonstrates the relevant components of the Standard. For example, an actual mobilisation for an offshore containment and recovery effort may effectively demonstrate not only the minimum requirements for that response category, but also a competent organisational infrastructure in terms of reliable logistics, staff knowledge and competence and established procedures (e.g. for health and safety).

3.4 Returns

The Accrediting Body has the right to carry out an interim assessment based upon any aspect of the Interim or Annual Return.

OSROs may find the Returns Template at Appendix 12 of use.

Note, that an Annual Return should not be considered a replacement for an Interim Return, which serves as the timeliest method with which to inform the Accrediting Body of significant changes affecting the accreditation status or capability statement of the accredited OSRO.

3.4.1 Interim Return The OSRO is to submit an Interim Return to the accreditation body if any significant changes to the OSRO’s Capability Statement have arisen from changes to risk profile and client base since the last accreditation/re-accreditation. A ‘significant change’ would be defined as a change in client base which has required a substantial adjustment of resourcing levels or the way in which the services are delivered. This could require, for example, an application for accreditation for another category of response. Details should be given of the change in client base and any corresponding adjustment to capability should be detailed.

3.4.2 Annual Return The OSRO is to submit an annual return to the Accreditation Body for the preceding year no later than 31 January of the subsequent year. This Annual Return should include details of the OSROs activities and relevant changes as described in Appendix 11.

3.5 Complaints

3.5.1 Complaints regarding the accreditation process, which have not been resolved via the Accrediting Bodies own complaints procedure, should be made in writing to the MCA Counter Pollution and Salvage Branch at:

Bay 2/2
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Or by email at: ukresponderstandard@mcga.gov.uk The MCA will follow its corporate complaints handling procedure when complaints are received.

Appendix 1: Capability Assessments

A.1.1 OSROs must be able to demonstrate that they have in place, and use, a procedure to review their capability against the specific risks and scenarios detailed in each of their clients’ OSCP/OPEPs. This procedure will provide confirmation to the client of the effectiveness of the OSROs capability and assurance of the response being commensurate with any Service Level Agreement between OSRO and client. Ultimately the decision, and responsibility, in selecting an appropriate OSRO rests with the client, however, they should be equipped to make that decision with an accurate and comprehensive picture of the OSRO’s capability and their ability to meet the client’s specific risks.

A.1.2 An OSRO would, however, be precluded from taking on a client whose requirement involves operations in a response category the OSRO has not applied and been accredited for. To demonstrate this has not taken place, OSROs must produce a Client Risk Profile for review by the auditor. The ‘Risk Profile’ is a broad (but brief) overview of the OSRO’s client base and their requirements i.e. areas of operation and/or type of operation. For example, an OSRO might state that their client base consists of ports whose jurisdictions include both coastal/large estuarine, sheltered/enclosed waters and shorelines, providing examples of these clients. The auditor will then be able to judge whether accreditation for the appropriate response categories has been applied for and achieved by the OSRO.

A.1.3 The Standard also requires OSRO’s to produce their own overarching risk assessment, demonstrating how they can meet their obligations, if they have multiple clients, when faced with two call outs simultaneously. Geographic threat should also be considered, for instance, if an OSRO holds contracts with several clients concentrated in a geographic area. It should be borne in mind that in this scenario a relatively small spill could impact a wide area. In this scenario more than two clients may expect a response. OSROs must demonstrate that they have considered this and have taken steps to both establish contingency plans and manage client expectations. This could be, for example:

• A procedure for resource allocation e.g. a first come first served system whereby every client has access to a percentage of what is available at the time they call. This procedure and the likely availability of resources in a multiple call out scenario should be made clear to all current and prospective clients;
• Memorandums of Agreement (MOAs) with other OSROs to provide mutual assistance;
• A procedure for scaling up capability e.g. by pulling non-specialist staff from other parts of the business; or
• A procedure for requesting assistance from the MCA (where the required capability is in place). It should be noted that this assistance will be chargeable to the requesting organisation. If costs are being passed on to a client, i.e. a port or polluter, this should be made clear to them.

A.1.4 Maintaining and renewing accredited status will depend on an OSRO being able to continue to deliver against their Capability Statement, the minimum Category Specific Requirements and their Client Risk Profile. Accrediting Bodies may review an OSRO’s Client Risk Profile or specific contractual obligations as a method of verification.

A.1.5 OSROs should be able to demonstrate, during accreditation renewal, that they have maintained relevancy by incorporating any new technology, response techniques and/or procedures in line with international best practice.

Appendix 2: Foundation Requirements

A.2.1 This section lists the Foundation Requirements applicable to all OSROs. It requires OSROs to outline their overall capability (with some required information only applicable to specific categories) and to demonstrate that this capability is supported by a reliable and competent organisational infrastructure.

A.2.2 Capability Statement

OSRO’s must detail their overall capability in a Capability Statement. Certain details are only required if the response category in question has been applied for.

This should detail, for each applicable item, as a minimum:

A.2.2.1 Organisation overview

1. a. The category(s) of service provision(s) being applied for. Please also include any other specialist types of marine response capability e.g. aerial surveillance/verification, modelling, fire boom for in-situ burning, subsea dispersant injection, wildlife rehabilitation;
2. b. The number of persons available at each level. This must include as a minimum:

Role title (or equivalents)	Description
Technical Advisor	Person present in response room assisting the client in planning and coordinating the response. Will also liaise with and direct responders on scene
Response Manager/On Scene Commander	Person responsible for overseeing on site operations, including conducting dynamic risk assessments and ensuring health and safety requirements are observed and maintained
Supervisors/Team Leaders	Those in charge of small teams during operations
Marine/Shoreline Operators	Those tasked with deploying equipment

c. Any response mobilisation times specified under contract or internal policy, e.g. call out time, mobilisation times, activation of subcontractors etc.

A.2.2.2 Aerial dispersant categories

1. a. The location, amount and type of dispersant stock available (must be a dispersant on the Marine Management Organisation (MMO) approved list at the time of purchase and proof of the date of purchase should be retained as evidence of this).
2. b. The number of aerial platforms, type and routine operational base location of all aircraft available for dispersant application;
3. c. Certification (from the Civil Aviation Authority) for each aircraft available to ensure that they are legally permitted fly with modifications to carry and spray dispersant in UK airspace;
4. d. The dispersant load capacity and flight range of each spraying aircraft;
5. e. The system for dispersant delivery, including the range, swath and rate of delivery as well as the droplet size. The spraying altitude should also be detailed;
6. f. Standard operating procedures for conducting aerial spraying operations; and
7. g. The method(s) and capability for detecting and monitoring dispersant application effectiveness ^{[footnote 2]}.

A.2.2.3 Vessel mounted dispersant categories

1. a. Appropriate certification/coding for any vessels, owned or under contract, so that they are permitted to operate in UK waters within safe manning regulations, or, for vessels of opportunity, an established procedure for ensuring that appropriate certification/coding is in place;
2. b. The location, amount and type of dispersant stock available (must be a dispersant on the Marine Management Organisation (MMO) approved list at the time of purchase and proof of the date of purchase should be retained as evidence of this);
3. c. The number of vessel mounted dispersant application systems;
4. d. Standard operating procedures describing the operational methods for coordinating at sea dispersant operations;
5. e. The method(s) and capability for detecting and monitoring dispersant application effectiveness^{[footnote 3]}; and
6. f. Where any of the above is sub-contracted to meet the Capability Statement, details of the subcontractor.

A.2.2.4 Sheltered, coastal, offshore waters and/or vessel mounted dispersant spraying operations

1. a. Appropriate certification/coding for any vessels, owned or under contract, so that they are permitted to operate in UK waters within safe manning regulations, or, for vessels of opportunity, an established procedure for ensuring that appropriate certification/coding is in place;
2. b. The amount of containment boom available and its type e.g. sheltered water, coastal or offshore;
3. c. The number of oil recovery skimmers and their suitability against different oil viscosities, as per Table 1 in the International Tanker Owners Pollution Federation’s Technical Information Paper Use of Skimmers in Oil Pollution Response;
4. d. The total temporary storage capability or details of any policy for clients to provide this; and
5. e. Where any of the above is sub-contracted to meet the Capability Statement, details of the subcontractor.

A.2.2.5 Offshore oil and gas activities

1. a. A description of the inventory of oil spill response resources (including dispersants and aerial surveillance/dispersant application resources) available for use to implement the oil spill response strategies detailed in client OPEPs.

A.2.2.6 Shoreline clean up

1. a. Any limitations on the types of shorelines the OSRO can respond to;
2. b. The quantity of shore-sealing boom the OSRO has access to;
3. c. Access arrangements to light craft to deploy shore sealing boom;
4. d. The ability to lead SCAT assessments as per UK guidelines;
5. e. The ability to procure the necessary equipment at short notice and scale up as required, this would include PPE, pressure washers, temporary storage, manual cleaning equipment (e.g. shovels), transport and low pressure flushing equipment; and
6. f. Any specialised beach cleaning equipment or logistical capability e.g. ATV’s, drones, aerostats, wildlife rehabilitation equipment, vacuum systems and command posts.

A.2.3 Capability Matrix

A.2.3.1 OSRO’s must complete a Capability Matrix, summarising the Capability Statement. Appendix 7 shows an example matrix. OSROs can use this template or provide other documents, such as published catalogues, which provide the same information in an easy to interpret format.

A.2.4 Alerting, activating and mobilisation to scene

A.2.4.1 OSROs must demonstrate that they have the procedures and infrastructure in place to deliver a 24hr emergency response service. This must include, as a minimum:

1. a. Access to the personnel, equipment and logistics to deliver the services described in the Capability Statement. This must include dedicated logistics staff, sufficient warehouse lifting equipment and 24hr haulage arrangements;
2. b. A duty roster system to ensure sufficient numbers of response staff are available at all times, i.e. 24/7, 365;
3. c. A call out procedure for clients, available 24/7, 365; and
4. d. A duty manager system to enable the coordination of a call out, 24/7, 365.

A.2.5 Response personnel selection and management

A.2.5.1 OSROs must demonstrate that they have processes in place to ensure their response staff are competent to perform their roles. This must include:

1. a. A programme of initial selection, training, fitness to work checks and continuous improvement for:
   1. Technical Advisor,
   2. Response Manager,
   3. Supervisors/Team Leaders/Beachmasters,
   4. Marine Operators,
   5. Others as relevant to the Capability Statement;

This ‘programme’ should be a combination of organised courses relevant to the industry, legally required vocational qualifications (e.g. forklift driving, power boat operation etc.) and formalised in-house training. A formalised in-house induction should take place for any new starter, to ensure that the trainee is safe and competent to perform their role as equipment operator in the UK.

Continuous improvement would consist of additional formalised in-house or external training opportunities designed to develop the responder into a marine oil spill response specialist, so that they may progress from their entry level role. This could include, but is not restricted to, training on equipment use and maintenance, training in oil spill response techniques, development of technical knowledge (maintaining relevancy) and development of management/leadership/training ability.

1. b. A programme of training and exercises in place to meet the Capability Statement and a process to review lessons learned and learning processes;
2. c. Fitness to work checks to guarantee the ability of the workforce to deliver services in the range of environments in which they are expected to be deployed; and
3. d. Procedures in place to ensure the health and wellbeing of their response personnel.

A.2.6 Equipment readiness

A.2.6.1 OSROs must have in place the procedures and infrastructure to ensure the operational readiness of their equipment. This must include:

1. a. A suitable storage location for the equipment that provides for security, ease of access and protection of the equipment; and
2. b. A preventative planned maintenance programme to ensure the legal, safe and reliable operation of the equipment specified in the Capability Statement.

A.2.7 Operations

A.2.7.1 OSROs must have a reliable and competent organisational infrastructure to ensure the effective and safe delivery of their services. This must include:

1. a. Managers and supervisors who have a thorough understanding of relevant oil spill response strategies, including the advantages, disadvantages and risks of each response strategy;
2. b. Supervisors and operators who have a thorough understanding of the tactical considerations for the response capabilities described in the capability statement;
3. c. Risk assessments for all response activities covered in the Capability Statement;
4. d. An operational process of safety management e.g. toolbox talks, time outs;
5. e. A recognised health and safety standard for example, ISO45001;
6. f. A set of standard operating procedures, relevant to the Capability Statement, that emphasise safe operations;
7. g. Managers and supervisors who can demonstrate a thorough understanding of the UK’s National Contingency Plan: A strategic overview for responses to marine pollution from shipping and offshore installations (NCP) and of relevant response agencies;
8. h. The ability to integrate into co-ordinated response structures;
9. i. Procedures for resource management e.g. record keeping, equipment usage;
10. j. A response management procedure in place that produces an Incident Action Plan for on water and/or shoreline operations. See Appendix 9 for minimum content; and
11. k. Managers and supervisors competent to instruct responders of opportunity, who may include crews on client vessels or vessels of opportunity, port staff or local authority staff.

A.2.8 Audit

A.2.8.1 OSROs should have review processes in please to guarantee the quality of the services being provided. This should include, as a minimum:

1. a. A process of internal audit/review that provides quality assurance for the services being delivered;
2. b. Where sub-contracted services are utilised to meet the Capability Statement, a programme to provide assurance of service delivery to internal management and accreditor; and
3. c. Assurance that post incident and exercise reports are conducted, with evidence that learning points are captured, tracked, shared and acted upon appropriately. These should be submitted as annual returns to the accreditation body.

For clarity, the above foundation requirements apply to directly operated and sub-contracted services.

A.2.9 Business continuity

A.2.9.1 OSRO’s must ensure that they have planned and prepared for crises which may affect service delivery, as a minimum this should include:

a. A business continuity plan that:

• identifies ‘crises’ which could affect service delivery e.g. warehouse fire, mass staff absence
• identifies steps taken to mitigate those hazards e.g. fire prevention/control systems and/or procedures
• identifies contingencies or workarounds to maintain service delivery (this could be an MoA); and
• outlines a procedure and communications plan to be applied in the event of a crisis which affects service delivery

Appendix 3: Qualifying entry requirements for response categories

This section contains the entry level requirements to be met by a prospective OSROs in either single or multiple categories applied for.

A.3.1 Items common to all response categories

A.3.1.1 PPE

PPE availability and resupply relevant to the response categories applied for, e.g. lifejackets, hardhats, respirators and gas detection equipment.

A.3.1.2 Logistics

Logistical services to support the delivery the category applied for including: transportation communications, storage, maintenance, repair and demobilisation.

A.3.2 Items specific to the response category applied for

Listed below are the minimum qualifying entry level capability requirements for each response category applied for.

A.3.2.1 Dispersant application

Vessel mounted	Aerial
Two sets of recognised vessel-mounted dispersant spraying systems which can be verified to produce the correct droplet size and application rate to effectively disperse oil, as per international best practice guidance [footnote 4]	Dispersant spraying aircraft
A stockpile of at least 5m3 of dispersant approved for use in the UK by the MMO at the time of purchase (proof of purchase date should be retained)	Dispersant control and oil spotting aircraft i.e. spotter plane
Vessel re-supply method statement/procedure (for example, arrangements with suppliers or other response organisations	Suitable airside facility to operate from
Dispersant effectiveness monitoring procedure and capacity [footnote 5] – as a minimum, this should be an aerial platform with trained observers	Capability to deploy and apply test spray
	Access to a stockpile of dispersant, sufficient for a meaningful aerial spraying campaign, approved for use in the UK by the MMO at the time of purchase (proof of purchase should be retained)
	Means to apply dispersant in the correct droplet size and application rate to effectively disperse oil as per international best practice guidance
	Dispersant effectiveness monitoring procedure and capacity – as a minimum this should be an aerial platform with trained observers.

Must have staff or guaranteed contracted access to persons sufficient to deploy the equipment specified. Responders must have the skills and experience to supervise the application, operate the equipment and monitor the dispersant’s effectiveness. Responders, Supervisors and Response Managers required to work on water must have basic seamanship skills appropriate to the area of operation.

Staff must be competent to instruct hired vessel crews, should additional contracted vessels be required, in the safe operation of the oil spill equipment. This should include the completion of a risk assessment.

A.3.2.2 Dispersant application – Offshore oil and gas

Definition: With specific regard to the application of dispersant for offshore oil and gas activities, the OSRO must be able to supply the dispersant, application equipment, trained personnel and logistical support as detailed in their Capability Statement and appropriate to the requirements of their offshore oil and gas client(s). The following minimum standards must apply to the application of dispersant for offshore oil and gas activities:

Vessel mounted	Aerial
Access to recognised vessel mounted dispersant spray equipment which can be verified to produce the correct droplet size and application rate to effectively disperse oil, as per international best practice guidance [footnote 6]	Access to a test spray aircraft
Means to re-supply each dispersant spraying operation at a rate commensurate with a large scale dispersant application programme	Access to an aircraft with a large-scale dispersant application capability commensurate with offshore oil and gas requirements
Immediate access to: Communications, e.g. radios, telephones. Safety equipment, e.g. gas detection, lifejackets	Means to apply dispersant in the correct droplet size and application rate to effectively disperse oil as per international best practice guidance
Dispersant effectiveness monitoring procedure and capacity [footnote 7] – as a minimum, this should be an aerial platform with trained observers	Access to dispersant control and oil spotting aircraft i.e. spotter plane
Access to a dispersant stockpile of sufficient size to treat an ongoing release of oil from an offshore installation which has been approved for use in the UK by the MMO at the time of purchase (proof of purchase date should be retained)	Access to suitable operational airbase facilities to accommodate and resupply dispersant application aircraft
	Capability to apply a dispersant test spray within 6 hours from time of mobilisation request
	Capability to commence dispersant application programme to the limits of the UK Exclusive Economic Zone/Continental Shelf
	Capability to re-supply aerial dispersant spraying operation at a rate commensurate with a large scale ongoing dispersant application programme
	Dispersant effectiveness monitoring procedure and capacity – as a minimum, this should be an aerial platform with trained observers
	Access to a dispersant stockpile of sufficient size to treat an ongoing release of oil from an offshore installation and consisting of products which have been approved for use in the UK by the MMO at the time of purchase (proof of purchase date should be retained)

Minimum staffing

Must have staff or guaranteed contracted access to persons sufficient to deploy the equipment specified. Responders must have the skills and experience to both supervise the application, operate the equipment and monitor the dispersant’s effectiveness.

Responders, Supervisors and Response Managers required to work on water must have basic seamanship skills appropriate to the area of operation.

Staff must be competent to instruct hired vessel crews, should additional contracted vessels be required, in the safe operation of the oil spill equipment. This should include the completion of a risk assessment.

A.3.2.3 Sheltered or enclosed waters

Definition: would include protected ports and harbours, sheltered parts of larger estuaries.

Minimum equipment

Must have owned or contracted access to oil spill response equipment and logistics to deal with marine oil spills.

Containment and recovery

• 200 metres of containment boom or a containment system suitable for inshore waters, with a level of redundancy i.e. spare boom sections, repair kits, spare reels;
• Access to workboats suitable for deployment of sheltered water booms and recovery devices. This could be an owned capability, a procedure to contract or a contractual term or condition for clients to supply;
• Skimmers to deal with a range of oil viscosities, suitable for sheltered enclosed waters. A level of redundancy should be maintained for each viscosity type, e.g. two brush skimmers, two oleophilic disk skimmers. Skimmer capability must be verified, i.e. with recognised certification;
• Temporary storage capability of oil oily/water recovered on water up to 30m3; or
• Arrangements/procedures for clients to provide vessel-based storage; and
• Arrangements/procedures for bulk oil removal capability of oil recovered to access point ashore.

Minimum staffing

Must have staff or guaranteed contracted access to persons sufficient to deploy the equipment specified. Responders must have the skills and experience to both supervise the deployment and operate the equipment. Responders, Supervisors and Response Managers required to work on water must have basic seamanship skills appropriate to the area of operation.

Staff must be competent to instruct hired vessel crews, should additional contracted vessels be required, in the safe operation of the oil spill equipment. This should include the completion of a risk assessment.

A.3.2.4 Coastal and large estuary

Definition: would include partially protected ports and harbours, large lakes, lochs, partially exposed shorelines, sheltered coastal zones and large estuaries.

Minimum equipment

Must have owned or contracted access to oil spill response equipment and logistics to deal with marine oil spills.

Containment and recovery

• 300 metres of containment boom or a containment system suitable for coastal waters, with a level of redundancy i.e. spare boom sections, repair kits, spare reels;
• Skimmers to deal with a range of oil viscosities, suitable for coastal areas or large estuaries. A level of redundancy should be maintained for each viscosity type, e.g. two brush skimmers, two oleophilic disk skimmers. Skimmer capability must be verified, i.e. with recognised certification;
• Temporary storage capability of oil recovered on water up to 30m3; or
• Arrangements or policy for clients to provide vessel-based storage (e.g. a bunker barge);
• Arrangements/procedures for bulk oil removal capability of oil recovered to access point ashore; and
• Access to workboats suitable for deployment of coastal and large estuary booms and recovery devices. This could be an owned capability, a procedure to contract or a contractual term or condition for clients to supply.

Minimum staffing

Must have staff or guaranteed contracted access to persons sufficient to deploy the equipment specified, who can assemble at a response staging area within the timeframe stipulated in every clients’ OPEP/OPRC Plan. Responders must have the skills and experience to both supervise the deployment and operate the equipment. Marine Responders, Supervisors and Response Managers required to work on water must have basic seamanship skills appropriate to the area of operation.

Staff must be competent to instruct hired vessel crews, should additional contracted vessels be required, in the safe operation of the oil spill equipment. This should include the completion of a risk assessment.

A.3.2.5 Offshore waters

Definition: All unsheltered waters

Minimum equipment

Must have owned or contracted access to oil spill response equipment and logistics to deal with marine oil spills.

Containment and recovery

• 300 metres of containment boom or a containment system suitable for offshore waters, with a level of redundancy i.e. spare sections, repair kits,
• Skimmers to deal with a range of oil viscosities, suitable for coastal areas or large estuaries. A level of redundancy should be maintained for each viscosity type, e.g. two brush skimmers, two oleophilic disk skimmers. Skimmer capability must be verified, i.e. with recognised certification.
• Minimum temporary storage capability of oil/water mix recovered of 50m3; or
• Owned or contracted vessel-based storage capability; or
• Arrangements for the client to provide this; and
• Access to workboats suitable for deployment of coastal and large estuary booms and recovery devices. This could be an owned capability, a procedure to contract or a contractual term or condition for clients to supply;

Spill surveillance would not necessarily be solely the responsibility of the OSRO and could be provided by the client or the MCA – this will depend on the requirements of a clients’ OSCP or ad-hoc response contract.

Minimum staffing

Must have staff or guaranteed contracted access to persons sufficient to deploy the equipment specified, who can assemble at a response staging area within the response time stipulated in every clients’ OSCP. Responders to have skills and experience to both supervise the deployment and operate the equipment.

Marine Responders, Supervisors and Response Managers required to work on water must have basic seamanship skills appropriate to the area of operation.

Staff must be competent to instruct hired vessel crews, should additional contracted vessels be required, in the safe operation of the oil spill equipment. This should include the completion of a risk assessment.

A.3.2.6 Offshore oil and gas installation activities (including pipelines)

Definition: For any OSRO wishing to hold a Tier 2 contract with an offshore operator, for oil and gas operations taking place UK Continental Shelf.

Minimum equipment

Aerial surveillance – oil spill verification

1. Capability for verification aircraft to be on site within four hours from time of mobilisation request. As a minimum, the following should be available on the verification aircraft:
   1. 1. Marine VHF radio;
   2. 2. Digital still and video capabilities;
   3. 3. Satellite telephone;
   4. 4. Suitable navigation equipment including a Global Positioning System (GPS) to ensure the accurate display of search areas and dispersant spray patterns and to control the activities of other resources during counter-pollution operations; and
   5. 5. Suitably trained and experienced personnel to ensure an adequate, continuous response capability.

Aerial surveillance – oil spill quantification

1. Capability for quantification aircraft to be on site within 6 hours from time of mobilisation request. As a minimum, the following should be available on the quantification aircraft:
   1. a) Marine VHF radio;
   2. b) Digital still and video capabilities
   3. c) Infrared imaging equipment;
   4. d) Ultra violet imaging equipment;
   5. e) Satellite telephone;
   6. f) Suitable navigation equipment including a Global Positioning System (GPS) to ensure the accurate display of search areas and dispersant spray patterns and to control the activities of other resources during counter-pollution operations; and
   7. g) Suitably trained and experienced personnel to ensure an adequate, continuous response capability.

Containment and recovery

• Access to sufficient oil spill response equipment to implement the oil spill response strategies detailed in clients OPEPs;
• Capability to transport, deploy to site and operate all oil spill response equipment; and
• Measures to maintain all oil spill response equipment in an operable condition.

Minimum staffing

Access to persons sufficient to transport, deploy and operate the equipment specified within the timescale stipulated in clients OPEPs/OPRC plans. All responders to be trained and competent in the operation and supervision of the oil spill response equipment that may be mobilised.

Marine Responders, Supervisors and Response Managers required to work on water must have basic seamanship skills appropriate to the area of operation.

A.3.2.7 Shoreline clean up

Definition: All intertidal shoreline types

Minimum equipment

The principle prerequisites are the strategic and tactical knowledge required, the levels of supervision and personnel, the ability to operate a Shoreline Clean-up Techniques (SCAT) programme and to lead a response after developing and following an Incident Action Plan, as defined in Appendix 9. For more information on SCAT, see the UK SCAT Manual.

There are no minimum equipment levels specified for shoreline clean up, but it should be commensurate with shoreline impact risks highlighted by clients. Contractors should have ready access to necessary clean up equipment:

• Shore sealing boom and ancillaries
• Light craft to deploy shore sealing boom
• Shallow draft and/or vacuum skimmer systems, pumps and necessary ancillaries
• All-terrain vehicles
• PPE
• Pressure washers
• Pit liners
• Shovels
• Low pressure flushing systems

This equipment can be owned, hired or purchased at short notice (< 24 hrs) but access to it and the ability to scale up should be a verifiable.

Minimum staffing

Contractors must be able to guarantee the availability of a sufficient number of personnel to deploy the equipment specified. Response personnel must have the skills and experience necessary to lead and supervise response operations where specialised techniques are employed.

Where small craft are used close to shore, staff should have the relevant seamanship skills and qualifications for these operations.

Appendix 4: Accreditation process requirements

A.4.1 Application for accreditation

1. Applications by OSROs for accreditation must include evidence that the OSRO can fulfil the basic requirements and the requirements of any specific category for which they are seeking accredited status.
   
   
2. Before accredited status can be granted, accreditation bodies must audit the base(s) and offices of the prospective OSROs, confirming that the stated capability of the OSRO exists.
   
   
3. OSROs will need to prove their technical expertise and how this will be maintained. This will be achieved through face to face questioning of response personnel during the audit and a scrutinisation of internal training material and procedural documents.
   
   
4. During audits an OSRO’s response requirements, as defined by their clients’ collective risk, will be compared to their Capability Statement.
   
   
5. Upon accredited status being granted to an OSRO for the first time, a probationary period of six months must be observed. During this time, the accrediting body must observe an actual spill response or attend a practical exercise reflecting the OSROs’ Capability Statement, for their accredited status to be upheld following the end of the probationary period. The exercise or actual spill response will not necessarily have to demonstrate every aspect of an OSRO’s capability; this may not be practical or appropriate where an OSRO is accredited in more than one category. Instead, the exercise or actual spill response should demonstrate that the OSRO can apply the equipment, techniques and strategies appropriate to the scenario in question, that personnel have the required level of knowledge, skill and professionalism and finally that the deployment is managed through effective command and control structures, good communication and demonstration of good health and safety practices.
   
   

A.4.2 Re-accreditation

For re-accreditation to be issued, the accrediting body must observe an actual spill response or attend a practical exercise, reflecting the OSRO’s Capability Statement within the 3-year accreditation period, or 3-month grace period. OSROs will be assessed on the appropriateness of their response to the scenario in question, including:

• timeliness of response against contractually agreed timeframes or OPRC guidelines stated timeframe (6 hours)
• use of correct response techniques and equipment for the scenario in question
• competent and safe deployment of the equipment

Where an OSRO is participating in a wider exercise hosted by another organisation, this participation can be considered as long as the OSRO’s own capability (in terms of personnel and equipment) is demonstrated.

Where an OSRO has a contracted capability as part of their Capability Statement this must be exercised, should it be required/appropriate under the exercise scenario.

Exercises or actual incident response, attended by the Accrediting Body, may preclude the need for certain scheduled audit checks, providing the exercise or response in question effectively demonstrates the relevant components of the Standard. OSROs are therefore encouraged to invite Accrediting Bodies to observe responses to prolonged incidents and/or planned training exercises throughout the period of accreditation.

A.4.3 Deficiencies and requirements following the re-accreditation process

Should a re-accreditation process highlight a deficiency or other issue in the level of service provision, the Accrediting Body will communicate requirements to the OSRO to rectify the problem.

The Accrediting Body will identify major or minor deficiencies in meeting the Standard of service provision. Corrective action for minor deficiencies may be able to be evidenced remotely e.g, by email confirmation or by video link. Major deficiencies will normally require an additional visit by the Accrediting Body to the OSROs premises, or to observe an exercise or elements thereof.

The Accrediting Body will determine the required timescale in which the deficiency should be remedied.

If a repeated re-accreditation exercise falls short of the Standard, then the MCA and OPRED will liaise with the Accrediting Body in order to determine appropriate next steps. This could include, but is not limited to, removal of a Module from the OSRO’s accreditation status, a further repeat exercise with oversight from the MCA and/or OPRED, or revocation of the OSRO’s accreditation status entirely.

Failure to do so enact requirements may result in accredited status of an OSRO being revoked by the Accrediting Body, following consultation with the MCA and DESNZ.

A.4.4 Changes to accredited modules or withdrawal from the scheme

Where an OSRO’s client base or business model has changed the OSRO may elect to add or remove a Module from its accreditation, or withdraw from the Scheme entirely.

Where this is the case, the OSRO should communicate this to the Accrediting Body in writing. The OSRO should inform any affected clients who can no longer use the OSRO’s services, and provide a reasonable notice period for this.

The Accrediting Body should issue a formal letter acknowledging the change in accreditation (whether a change in module or total withdrawal). The Accrediting Body will then inform the MCA and DESNZ of the change.

Appendix 5: Requirements for Accrediting Bodies

A.5.1 Auditing of accrediting bodies by MCA/DESNZ

It will be stipulated in the Memorandum of Agreement (MOA) between DESNZ, the MCA and the Accrediting Body that an audit of the Accrediting Body’s activities will be conducted every 3 years, based on the content of the Standard itself and of the corresponding MOA. The MCA/DESNZ will provide supporting documentation prior to the audit, which will detail the audit process and follow up activity.

Where the MCA/OPRED identifies deficiencies in the Accrediting Body at audit, these will be communicated and a timescale to remediate the issue will be agreed. Depending on the nature of the deficiency, the MCA/OPRED may take action to ensure deficiencies are not reflected in the activities of OSROs accredited by that Body.

Should an Accrediting Body choose to withdraw from the Scheme, providing there were no outstanding issue, the OSROs accredited by that Body will remain accredited until the end of their accreditation period.

A.5.2 List of requirements

The following is a list of requirements by the MCA and DESNZ for a body wishing to provide accreditation services.

• There must be no conflict of interest between the Accrediting Bodies and the OSRO industry. This must be demonstrated to the satisfaction of the MCA and DESNZ.
• The accrediting body will submit their proposed scheme of accreditation to the MCA and DESNZ for approval. The scheme of accreditation must comply with the framework outlined in the Standard. Only approved systems will be acceptable.
• The MCA’s and DESNZ’s approval for accreditation bodies to deliver their proposed scheme will be formalised in a Memorandum of Agreement (MoA). This document will outline the requirements for the accreditation body to deliver accreditation under the Standard. It will be in the form of a contract and will be the same for all Accrediting Bodies wishing to deliver the Standard.
• Fees for accreditation charged by the accreditation body are to be agreed with the MCA and DESNZ.
• The accrediting body must hold a recognised and in date quality management system e.g. ISO9001.
• The auditor(s) chosen to perform the accreditations are to be approved by the MCA and DESNZ; auditors’ CVs should be submitted as part of submissions for scheme approval. New auditors’ CVs should be submitted with annual returns. Auditors should be familiar with the marine oil spill response industry and have experience conducting audits. Follow up telephone interviews may be conducted with auditors to verify levels of knowledge and experience.
• The accrediting body will report to the MCA and DESNZ on all accreditations performed, including requirements fulfilled by the OSRO to meet the Standard. These reports are to be submitted as part of the annual returns.
• The accreditation body must have in place a complaints procedure.
• The accreditation body will report on general industry trends, as part of annual returns or annual scheme steering group meetings, pertaining to OSROs. This could include, but is not limited to:
  • Incidents involving UK OSROs; and
  • Major organisational developments, such as changes in specialisms and capability;

A.5.3 OSRO documentation retention

Accrediting Bodies should retain copies of certain documents from those OSROs that are accredited by them. These should be reviewed annually along with the OSRO annual return to examine any changes which could affect the service provision. These documents include but are not limited to:

• client risk profiles
• capability matrices
• significant sub-contractual documentation

A.5.4 Continuous professional development (CPD)

Accrediting Bodies’ auditors will be expected to demonstrate a current level of knowledge in the field of oil spill response through continuous professional development. This may take the form of deployment to incidents, participation in exercises, attendance at conferences, relevant training courses, or other means. CPD activities should be recorded, and evidence may be requested by MCA/DESNZ at audit.

Appendix 6: Currently approved Accrediting Bodies

The Nautical Institute

The Nautical Institute
202 Lambeth Road
London
SE1 7LQ

Tel: +44 20 7928 1351 Fax: +44 20 7401 2817 Contact: bernie.bennett@nautinst.org

www.nautinst.org

International Spill Accreditation Association (ISAA)

The International Spill Accreditation Scheme (ISAS) is a joint venture between ISAA and UKSpill Association.

Tel: +44 7710 378697 Contact: neil.marson@isasaccreditation.org or info@ukspill.org

https://www.isaa.org.uk/ https://www.ukspill.org

Appendix 9: Incident action plan template requirements

Applicable only if an OSRO is required to manage the incident on behalf of the client; in most cases the client will already have a contingency plan in place, detailed in their OPEP/OPRC Plan, which will describe how the OSRO will integrate into the client’s response structure.

The purpose of the Incident Action Plan is to provide the response organisation with a comprehensive documented plan of the work to be done (with supporting information) over an agreed forthcoming operational period. The plan would normally be prepared by the incident management team. It should be presented in a way that allows easy distribution to the field supervisors for implementation.

Content

The plan must contain, but is not limited to, sections covering:

(source: IPIECA-IOGP Incident management system for the oil and gas industry 2014)

• Incident objectives
• Response strategies and tactical work assignments
• Organisation chart
• Waste management plan
• Medical Plan
• Health and Safety Plan
• Communications Plan with incident radio details
• Maps, photographs or other graphics (e.g. oil trajectories)
• Resources

Additional content for shoreline operations

Responder of Opportunity Management Plan (RoOMP)
The content of the RoOMP should be consistent with the IPIECA-IOGP document Volunteer Management 2015 or later editions and contain sections on:-

• Selection of tasks for responders of opportunity
• Registration
• Induction and training
• Supervision
• Operational briefing (which should include decontamination and waste management)
• Resourcing
• Tasking documents (e.g. IAP, SOP’s)
• Health, safety and wellbeing
• Liaison

Appendix 10: Tier 2 mobilisation exercise requirements

10.1 Applicable if the exercise being observed by the auditor or other qualified person is a port or harbour Tier 2 mobilisation exercise. The observer should expect to witness, from the Tier 2 contractor, as a minimum:

• Input by the Tier 2 contractor into the exercise planning document.
• A test of the notification and mobilisation procedures for the Tier 2 contractor;
• Timely mobilisation and arrival at port/ harbour within 6 hours (or as agreed by the MCA) if a real-time test is being conducted, or else pre-mobilisation and exercise time compression;
• Mobilisation of appropriate Tier 2 resources (both in equipment and personnel) commensurate to the exercise scenario as agreed with the port or harbour;
• Participation in a briefing upon arrival, led by the port or harbour, followed by a health and safety / toolbox brief for the Tier 2 contractor, again, led by the port or harbour;
• Provision of response options advice from the Tier 2 contractor to the Port or Harbour Incident Commander and briefing on proposed actions to be taken;
• Tier 2 contractor input / presence in the Incident Management Team, if formed;
• Competent demonstration of Tier 2 equipment deployment and recovery, to the satisfaction of the harbour master or designated Incident Commander. (Ports are encouraged to validate existing / new booming plans in conjunction with their Tier 2 contractor); and
• Input by the Tier 2 contractor into the exercise hot wash up and post exercise report.

Appendix 11: Guidance on OSRO Returns to Accrediting Bodies

The accrediting body has the right to carry out an interim assessment based upon any aspect of the Interim or Annual Return.

Note that an annual return should not be considered as a replacement for an Interim Return which serves as the timeliest method with which to inform the Accrediting Body of significant changes affecting the accreditation status of the OSRO.

Interim Returns

The OSRO is to submit an Interim Return to the accreditation body if any significant changes to the OSRO’s Capability Statement have arisen from changes to risk profile and client base since the last accreditation/re-accreditation. A ‘significant change’ would be defined as a change in client base which has required a substantial adjustment of resourcing levels or the way in which the services are delivered. This could require, for example, an application for accreditation for another category of response. Details should be given of the change in client base and any corresponding adjustment to capability should be detailed.

The Interim Return should be sent to the Accrediting Body in good time following the change in circumstances.

Annual Returns

An Annual Return should be made to the OSRO’s Accrediting Body no later than 31 January of the year following that which the Annual Return covers. The Annual Return should cover information regarding changes to administration, operations, contracts, and anything else relevant to the accreditation. This could include, but is not limited to:

• Incidents responded to and associated post-incident reports
• Exercises conducted and associated post-exercise reports
• Evidence that learning points are captured, tracked, and acted upon appropriately
• Relevant changes in administrative details, such as points of contact
• Relevant changes in contractual agreements and/or insurance
• Relevant changes in procedures
• Relevant changes to response personnel, such as departures and recruitment
• Relevant changes in equipment stockpiles, vessels, vehicles, or premises
• Relevant changes in client base
• Any other information pertinent to the accreditation status of the OSRO

Appendix 13: List of Accredited Responders

The following organisations have been accredited to the UK National Standard for Martine Oil Spill Response Organisations.

“X” marks where modules are accredited.

Organisation	Module 1	Module 2	Module 3	Module 4	Module 5	Module 6	Module 7
Adler & Allan			X	X			X
Ambipar Response			X	X	X		X
Briggs Marine			X	X	X	X	X
EnQuest		X		X			X
JEMS Oil Spill Response			X	X
Lerwick Port Authority			X	X			X
Oil Spill Response (OSRL)	X	X	X	X	X	X	X
PD Ports (Teesport)				X			X
Pollution and Waste Services Ltd			X	X	X		X
Serco LTD			X	X

Organisations listed here may have specific limitations or restrictions to their services under the UK National Standard for Marine Oil Spill Response Organisations. This includes but is not limited to geographic limitations, or an in-house capability.

Module descriptors:

1. Dispersant Application (aerial/vessel)
2. Dispersant Application (Offshore Oil and Gas)
3. Sheltered/Enclosed Waters
4. Coastal/Estuarine Waters
5. Offshore Waters
6. Offshore Oil and Gas
7. Shoreline

1. For details on which ports and harbours the OPRC Regulations apply to, see: The Merchant Shipping (Oil Pollution Preparedness, Response and Co-operation Convention) Regulations 1998, Regulation 3: Application ↩

2. For example, the Special Monitoring of Applied Response Technologies (SMART) advocated by IPEICA. For more information see: https://response.restoration.noaa.gov/smart ↩

3. For example, the Special Monitoring of Applied Response Technologies (SMART) advocated by IPEICA. For more information see: https://response.restoration.noaa.gov/smart ↩

4. ITOPF, TIP 04: Use of Dispersants to treat oil spills, 2014 https://www.itopf.org/knowledge-resources/documents-guides/ ↩

5. For example, the Special Monitoring of Applied Response Technologies (SMART) advocated by IPEICA. For more information see: https://response.restoration.noaa.gov/smart ↩

6. ITOPF, TIP 04: Use of Dispersants to treat oil spills, 2014, https://www.itopf.org/knowledge-resources/documents-guides/ ↩

7. For example, the Special Monitoring of Applied Response Technologies (SMART) advocated by IPEICA. For more information see: https://response.restoration.noaa.gov/smart ↩