No. 2 - USA / Federal Non Tank Vessel Response Plans

Dear Sirs

USA / FEDERAL NON TANK VESSEL RESPONSE PLANS

With effect from the 8th of August 2005 , non tank vessels in excess of 400 gt operating in US waters must have in place a pollution response plan similar to that currently required for tank vessels.

The US Coast Guard ( USCG) has issued an interim guidance note which can be found on their website at www.uscg.mil/hq/g-m/nvic/index00.htm .

In summary , the regulations require the owner to have in place the following:-

1.  A vessel response plan approved by the USCG.

2.  Contracts with :

a.  a Qualified Individual ( QI) with authority to act on the owner’s behalf in authorising clean up and preventive measures

b.  a contract with an Oil Spill Response Organisation (OSRO)

c.  a contract with a provider of firefighting , lightering and salvage services

Whilst Members may choose to make their own arrangements to meet these new requirements, the Club is able to assist in the following way.

Under existing arrangements with the two leading US OSRO’s , National Response Corporation (NRC) and the Marine Spill Response Corporation (MSRC), members may name either company as their chosen OSRO without charge.

Members may contact the Club’s general commercial correspondent in the US , TBS Adjusting Inc, for assistance in preparing response plans. The charges of TBS will be paid by the Club in the first instance and shown as an expense on the Member’s claims record.

TBS will communicate with appropriate organisations who can assist in writing the VRP, and provide QI, salvage, firefighting and lightering services. * The charge for plan writing and QI services is likely to be around $150 per vessel, which will be for the member’s account. We understand that providers of firefighting, salvage and lightering services are currently prepared to be named in response plans for no charge for the calendar year 2005.

Members should be aware that the timetable is short. Vessels calling at US ports on or after August 9th should submit their plans to the USCG for approval no later than July 9th or no later than 30 days before the vessel’s arrival. The USCG is likely to be inundated with plans for approval and it would be prudent to submit plans at the earliest opportunity

Members requiring assistance should contact Cindy Del Valle at TBS in New Orleans at the following address:-

TBS Adjusting, Inc.
800 Energy Centre,
1100 Poydras Street,
New Orleans, Louisiana 70163-3400
Tel: 001 504 524 2301
Cindy Del Valle direct: 001 504 585 7977
Fax: 001 504 524 2203
E-mail: cdelvalle@tbs-adjusting.com
host@tbs-adjusting.com

Yours faithfully
West of England Insurance Services (Luxembourg) S.A.
(As Managers)

C A G Havers
Director