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FUNDING & AGREEMENTS : GUARAN -TEES & CHANGESAs non-tank vessel owners are re- quired to enter into funding agree- ments with salvors and marine Þ re- Þ ghting resources, it will be the Þ ne print of those documents that matter most. According to Malen, the bottom line is relatively simple and not neces- sarily burdensome for cash-strapped operators. ÒThe Funding Agreement is actually a facet to ensure that we as SMFF respond to an incident with no delay in negotiating a contract as that contract (the Funding Agreement) is already in place. The owners must list a provider, but depending on the provid- er, the cost is relatively low.Ó She adds, ÒIt is more of the time and task as well as cost of vetting the SMFF provider, which is the ownerÕs responsibility.Ó For the typical nontank vessel opera- tors, some things will change and others will remain unchanged. For example, as operators choose the SMFF provider, they will also have to vet the provider. Unlike OSROÕs, which are classiÞ ed by the Coast Guard, it is the responsibility of the shipowner to verify that the salvor and Þ reÞ ghter have capabilities mea- sured against 15 criteria listed in Annex 2 of the rules. But, this will allow them an opportunity to truly engage their salvor, something which is not usually done. MRAÕs Malen says, ÒThis is a pro- active approach that I think is beneÞ cial to the entire industry. The owner/opera- tors will also have to exercise various drill requirements with their QIs, SMFFs, OSROs, and even random drills with the USCG.Ó From the regulatory side, vessel response plan particulars are now more likely to be enforced. From MRAÕs perspective, a proactive approach with clients includes in-house drills and training, as well as additional training through their lightering part- ner, Marine Pollution Control. At their Red Anchor training school, opera- REGULATORY REVIEW Vessel Capacity SpeciÞ c Requirements 1>2,500 bbl. Funding Agreement + Pre-Fire Plan 2250 Ð 2,500 bbl. Must have a contract with SMFF. 3>250 bbl. Must list an SMFF, but no PFP is required. NTVRP Requirements www.marinelink.com MN 37MN Dec2013 Layout 32-49.indd 37MN Dec2013 Layout 32-49.indd 3711/25/2013 12:49:59 PM11/25/2013 12:49:59 PM
