First meeting this year of the USCG Chemical Transportation Advisory Committee (CTAC)

The U.S. Coast Guard (USCG) Chemical Transportation Advisory Committee (CTAC) held its first meeting this year on 21 April 2005. Agenda items included a final report from the CTAC National Fire Protection Association 472 Subcommittee, reports from the Hazardous Cargo Transportation Security (HCTS) Subcommittee and the Outreach Subcommittee.

 The National Fire Protection Association 472 Subcommittee presented its final report to the full Committee. The work of this Subcommittee culminated in the development of a draft marine emergency responder chapter to NFPA 472 (Professional Competence of Responders to Hazardous Materials Incidents). It is the hope of the Subcommittee that this guideline will be used by the USCG (by reference) in the development of its pending OPA '90 Hazardous Substances Response Plan (HSRP) regulations. The USCG has indicated that it will most likely not be auditing hazardous substance responders in the same way as oil spill response entities. The Committee voted to approve the draft submitted. This addition to NFPA 472 will not take place until mid-2007. In the meantime, the NFPA will be looking for participants with expertise in this area for its relevant Technical Committee.  

The HCTS Subcommittee report discussed the work to date as well as the issues discussed at the subcommittee meeting held the previous day. These issues included the activities of the newly formed National Maritime Security Advisory Committee (NMSAC); its subsequent work groups and the merits of the Policy Advisory Counsel. The next meeting of the NMSAC will be held on 6 June 2005. During the HCTS Subcommittee meeting: 

-                  A presentation was made by the USCG National Response Center (NRC) on how it functions and its policies and procedures for Oil and Hazmat Spills, rail emergencies, and security incidents.

-            The USCG Inspector Maritime Security Training DVDs were distributed. Separate guides have been created for facilities vessels. The Subcommittee noted that both of these may be useful in preparations for internal audits. Copies will be made for distribution.

-            There was a discussion on Section 892 of the Homeland Security Act re the sharing of Security Sensitive Information, draft regulations and the development of a video in this regard.

-            A draft USCG Facility/Vessel Security Audit Report was discussed and will be reviewed by the Subcommittee.

-            There was a short but quality discussion on the continued importance of integrating security aspects into other emergency response exercises.

Various Declaration of Security (DoS) Scenarios continue to be developed. The next teleconference for DOS Working Group scenarios will be on 11 May 2005.

Other issues voted on by the full Committee included the rejuvenation of the CTAC Outreach Subcommittee, to be chaired by John Temperilli of Garner Environmental. The consensus of the Committee was that CTAC needs to be more involved in both national and international activities. Previous tasks assigned to this Subcommittee focused solely on industry awareness. INTERTANKO will be participating in the meetings of this Subcommittee. One of the early objectives of the Subcommittee is to create a vehicle for coordinating information. This will most likely be web-based. Changes were also agreed to the CTAC Charter, in order to incorporate security matters, make the scope more flexible, as well clarify some administrative aspects of the document. 

A number of presentations were made to the Committee including a Ballast Water Update by the USCG staff. INTERTANKO Chemical Manager, Margaret Doyle, updated the group on the MARPOL Annex II Revisions. A representative of the USCG Investigation and Analysis Program, responsible for overseeing the Coast Guard's field-level marine investigations, gave an excellent overview of its function within the USCG as the latter continues to change in scope.  

The USCG Office of Response gave an update on the status of the Hazardous Substance Response Plan Regulations. It is evident that this project has been overtaken by events within the USCG and it will be necessary for the USCG to issue a Supplementary Notice of Proposed Rulemaking (SNRPM), as much has changed since the NPRM and public hearings in 1999. CTAC Executive Director CDR Bob Hennessy, in his regulatory update, indicated that because of resource constraints, other regulatory projects, including the NPRM for Vapor Control, do not have a definitive timeline.  

James Prazak (DoW) discussed the work of a parallel working group under the Houston-Galveston Navigation Safety Advisory Committee (HOGANSAC) umbrella. The aim of this work is to upgrade the Declaration of Inspection, to make it more international in scope, to incorporate security/CDC issues into it, and reduce redundant check lists.

 The next meeting will probably take place on 7 November 2005 in Galveston, to coincide with the Clean Gulf Conference, 9-10 November 2005.  

Contact: Margaret Doyle