Blog: Filling the Response Gaps
In 2015 IPIECA and IOGP published their updated Good Practice Guide on Tiered Preparedness and Response. This was a seminal document which challenged the practice of defining Tiers based on spill volumes and instead “promotes a model for defining the three tiers according to the resources [1] required to respond to the incident, not the scale of the incident itself .” This approach is eminently sensible in that it removed somewhat arbitrary volumetric thresholds for the three Tiers. Instead it looks for a risk-based approach which considers not just the volume of oil spilt but also the oil type, location and local sensitivities.
The “difficulty” with this approach, such there is one, is that using a risk-based approach requires some thought and takes more explanation to regulators and other stakeholders than a simple volumetric calculation.
There are many excellent examples of excellent application of this Good Practice around the world.
One can see a flow through the Tiers, depend on the scale of the incident, for instance in Rotterdam port; where multiple operators within the port area have their own on-site (Tier 1) capabilities, which are supported by a good local Tier 2 contractor based in the port and, over the Channel, OSRL stand-by with Tier 3 resources available for deployment. We see a similar picture around the USA where there are many strong commercial and co-operative Tier 2 organisations which provide a bridge from the local Tier 1 resource to the National Tier 3 capabilities provided by MSRC.
This seamless picture, however, is not repeated everywhere in the world.
There are many cases where players, especially downstream entities, with significant nearshore risk in less developed countries, may have a Tier 2 gap. The problem is that, for instance within a port, a relatively small spill can have immediate and significant consequences. Deployment of Tier 3 resources from cooperatives such as OSRL or MSRC may be 48 to 72 hours away. Local Tier 1 capabilities are quickly overwhelmed and there is often not much more in terms of Tier 2 to step into the breech.
So how then can those holding the risk fill this potential Tier 2 gap?
There are a few possible solutions to filling the Tier 2 gap; all require a bit of work and some require funding too.
Mutual aid is everyone’s first thought and, on the face of it, it is a low cost, simple option. Sadly, if it were easy, there would be hundreds of fully-functioning mutual aid arrangements in place all around the world. Look around and you’ll find that there are not. For mutual aid to work, a series of conditions need to be met:
- Multiple local operators carrying similar risk profiles
- Those operators to have a similar motivation to close the tier 2 gaps
- A legal framework that provides suitable indemnities for all parties
- Someone(s) who drives the agreements and ensures that they are regularly exercised
If the mutual aid conditions are not met, and this is often the case for downstream installations such as terminals which may be the only significant oil spill risk in a port, then another approach is needed. The options pretty much boil down to either:
- Build (fund) commercial Tier 2 capability; or,
- Build an in-house Tier 1 response which negates the need for Tier 2.
The in-house options seems at first to be attractive, but there is both a direct financial cost to this, as well as the opportunity cost of ‘distracting’ personnel from the day job and so diluting profitability. What is more, this means investing time and resource in an area that is not the core business of the risk holder.
Peace of Mind Through Out-Sourcing
Outsourcing the Tier 1 / Tier 2 headache to a specialist will often be the solution that offers the best assurance to a risk-holder that this reputational risk is being well-managed. A great example of this can be seen in Lamor’s work with a client operating a maritime monobuoy and multibuoy Terminal in Peru.
Following a pollution incident, our client realised that the gap between Tier 1 and Tier 3 was too big, and it represented a non-acceptable risk in terms of environment, social, reputational and economic impacts to the Company. Working alongside the client, Lamor developed shoreline and offshore response capabilities and a smart tailored made solution as an out-sourced service for our client. This Tier 1 / Tier 2 provision includes:
- Specialized Oil Spill Response Vessels
- Offshore and ultra rapid deployment Boom systems, high recovery efficient skimmers, floating storage and barges.
- More than 20 dedicated personnel on an on-call rota
- Access to spill modelling and weathering software, SCAT, wider ICS support and additional Tier II and III Regional and Global response resources
With regular exercising and through a 24/7 dedicate service of this provision the client has peace of mind that the Tier 2 gap has been plugged.
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[1] When assessing the resources needed, we should consider personnel, equipment and other support needed to response to the incident.
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