How Marine Oil Spill Responses Are Organized and Managed
Training Marine Oil Spill Response Workers
Under OSHA’s Hazardous Waste Operations
and Emergency Response Standard
Marine oil spill response is organized and
managed according to the regulations found in
40 CFR 300, the National Oil and Hazardous
Substance Pollution Contingency Plan (NCP).
These regulations describe procedures for
responding to hazardous substance releases and
oil discharges. Appendix E of the regulation
specifically addresses oil spill response. The
U.S. Coast Guard (USCG) and the Environmental
Protection Agency (EPA) jointly led the
development of the NCP.
Marine oil spill response involves a network of
government agencies, community organizations,
industry groups, and contractors. Federal and/or
state agencies usually monitor the responsible
party (generally the owner or operator of the
vessel, facility, port, or pipeline involved in the
spill). The Federal Government can direct cleanup
operations if the responsible party does not
respond adequately, is not capable of taking
action, or is unknown.
An On-Scene Coordinator (OSC) acts as the
leader for response activities. In the coastal
areas of the United States, USCG serves as the
OSC for oil spill responses. In inland areas,
including rivers and other inland waters, EPA
generally takes the lead.
HAZWOPER requires that a senior official who
is present at the response site, an Incident
Commander, lead an emergency response
operation. For marine oil spills, the ranking Coast
Guard officer or EPA official at the spill scene
usually functions as the On-Scene Incident
Commander. The emergency response remains
in effect until the Incident Commander declares
it completed.
OSHA is responsible for assuring safe and
healthful working conditions for working men and
women. During marine oil spill response, OSHA
provides advice and consultation at the request
of other government agencies. If necessary,
OSHA uses enforcement action to assure that
workers are properly protected.
Emergency Response vs.
Post-Emergency Response
The HAZWOPER standard identifies two basic
phases of a response action: emergency response
and post-emergency response. Depending
on the size of the spill, these phases may be
managed differently. In addition, workers who
participate ONLY in post-emergency response
require different training than emergency
response workers receive.
Emergency response is “a response effort...to
an occurrence which results, or is likely to result,
in an uncontrolled release of a hazardous
substance” (29 CFR 1910.120(a)(3)). For marine
oil spills, an uncontrolled release is a situation in
which the oil and its associated airborne and
surface contamination hazards are releasing into
the environment or are in danger of releasing
into the environment and posing a worker
exposure hazard. Oil in grounded ships, which is
in danger of being released into the environment,
represents an emergency response situation. Onwater
containment, skimming operations, and
underwater oil recovery operations also are
considered to be emergency response activities
because the oil is still in danger of being released
into the environment. Shoreline cleanup
is normally considered to be a post-emergency
response unless the oil is below the high-tide
mark or storm surge boundary (active or forecasted)
and can reasonably be expected to be
re-released into the marine environment.