California's Oil Spill Response Organization(OSRO) and Plan-Holder Unannounced Drill Programs haveprovided an opportunity for state, Federal, and industryrepresentatives to work together to ensure that the bestachievable response for the State of California is attained. As aresult of the success of these two initial programs, the Office ofSpill Prevention and Response (OSPR) considers unannounceddrills to be the cornerstone of response resource assessment.Unannounced drills present an opportunity to practice andimprove how the OSROs and plan-holders (tank vessels, non-tankvessels, and facilities) respond to oil spills by testing contingencyplans, reviewing the systems approach, and revealing issues thatmay hamper an oil spill response. The OSRO unannounced drillstest the OSRO's response capabilities for the first six hours of aresponse, while the plan-holder drills test the owner/operator'sability to initiate a response to a spill incident, based on theowner/operator's contingency plan, for the first three hours of aresponse. Unannounced OSRO and plan-holder drills bothrequire government agency notification, equipment activationand deployment, and response resources to be operated. Since theonly way to evaluate how a plan-holder's team will respond in anemergency is to evaluate them in a non-emergency, adding theelement of surprise allows the state to better make thedetermination as to the adequacy of their preparedness. Non-tankvessel, tank vessel, and facility operators are also required toconduct to plan-holder initiated drills, and these have also beenhighly successful. Part of the success of these drills is that theyhave revealed potential problems, for which plan-holder-initiatedsolutions or OSPR regulatory fixes have been identified andproposed. Through this process, the California UnannouncedDrill Program has evolved from being planning standard-basedto performance standard-based for OSROs. Under newlegislation that reflects the OSRO performance requirements(Government Code 8670.29), plan-holders must now contractwith one or more state-rated OSROs to meet contingency planrequirements and an OSRO will only be granted a state rating byparticipating in unannounced drills.
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