The U.S. Coast Guard recently issued interim guidance for the development and review of oil spill response plans for nontank vessels. Since 1993, tank vessels have carried oil spill response plans. A recent legislative change will soon mandate similar response plans for most other ships. The problem is that the legislation requires nontank vessels to have the response plans sooner than the Coast Guard can promulgate regulations in accordance with standard procedures. Thus, the agency is unofficially advising stakeholders on how to comply with the legislation. Stakeholders will ignore the unofficial advice at their peril. The legislation has real teeth.
