Incident Management Matters
An irregular blog with thoughts and challenges on all aspects of Crisis Management, Emergency Preparedness & Response, Incident Risk and anything else that comes to mind.
Plugging the Tier 2 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.
[1]When assessing the resources needed, we should consider personnel, equipment and other support needed to response to the incident.
There are many excellent examples of excellent application of this Good Practice around the world.
One can see a flow through the Tiers, dependent on the scale of the incident, for instance in Rotterdam port. Here 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
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.
With the Tier 3 resources of OSRL 48 to 72 hours away, the local Tier 1 capabilities are quickly overwhelmed and there is often not much more in terms of Tier 2 to step into the breech.
I know from bitter experience that often the response is to push OSRL to respond more quickly or even to (for no additional cost of course) provide more local resources; basically asking OSRL to become a free Tier 2 service.
So how then can those holding the risk fill this potential Tier 2 gap?
For these locations the Tier 3 resource is almost always OSRL; and their capabilities and timescales for deployment are well defined. Operators can and should plan ahead to help OSRL speed up their deployment by working through the local logistics choke-points. Especially around visas/work permits for personnel and customs clearance for equipment. This may close the gap a little, but additional immediately-deployable resources will still be required.
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 who drives the agreements and ensures that they are regularly exercised
Before I left OSRL, they and Offshore Energies UK saw through a Mutual Aid Framework for the UK Continental Shelf operators. This was an excellent piece of work, but it took a lot of time and energy to get it over the line (massive kudos to Lucy Bly for this by the way).
If Mutual Aid isn't an Option, then what?
If the mutual aid conditions are not met, and I am thinking especially about 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.
In most locations there will be waste management contractors, a vessel supplier or maintenance/general labour organisations that the risk holder can work with. The contractor will need help though in building oil-spill response capacity. They will need a contract term and renumeration that makes it economically sensible to invest in equipment purchasing and personnel training. They will also need contract conditions that do not saddle them with disproportionate levels of liabilities in the event of a spill response.
All of this is an anathema to many purchasing teams, but it is needed if the capacity is to be created.
The alternative is to invest in-house with additional equipment and more personnel training in oil spill matters. There is a direct financial cost to this as well as the opportunity cost of ‘distracting’ personnel from the day job and so diluting profitability.
In both cases the need for good quality training and regular exercising cannot be over-stated. As with the mutual aid option; what may sound easy and straightforward is far from it.
Whichever route is chosen; it requires funding where there was none before, which in a world of budget constraints, requires strong advocacy from a champion within the senior leadership of risk-holding organisation.
It is the job of the Emergency Response professionals to find the air time with and gain the commitment from these senior leaders to plug the Tier 2 gaps.
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