Vetting Salvage and Marine Firefighting and Lightering (SMFF) provider ...

This post aims to inform the reader about the process of vetting the Salvage and Marine Firefighting and Lightering (SMFF) providers and also to discuss the requirements which become effective on the 22nd of February, 2011. Shipowners, operators and/or managers, later referred to as Planholders, must perform SMFF audits in selecting SMFF provider, which has to follow at least 15 “adequacy” criteria as follows:

1/ the candidate for SMFF provider actually works in subject response; 2/ history in operations; 3/ SMFF owns or has contract for necessary equipment; 4/ trained personnel with experience; 5/ 24(7) availability and history of meeting response times; 6/ Ongoing training; 7/ Proof of successful participation in drills and exercises; 8/ Proof of approved SMFF plans from real accidents; 9/ Participation in National and/or International organizations; 10/ Insurance cover for work to perform; 11/ sufficient “up front” capital to support an operation; 12/ sufficient equipment in all regions where the coverage is provided; 13/ Logistical and Transport support to sustain ongoing operations; 14/ Safety support of safeguard health; 15/ Familiarity with SMFF protocols outlined in ACPs for regions they provide coverage; 16/ … ??? .

As per position of Coast Guard, the planholder is responsible for vetting all possible SMFF providers to determine the adequacy of each company and decide which best suits the needs and meets the minimum of SMFF criteria. Meanwhile, the Coast Guard reserves the right to request a proof from the Planholder, as to how the decision was made in selecting an SMFF provider.

In performing the vetting, each provider must prove compliance with each of the 15 criteria; if they have any gaps in coverage, this will require obtaining a waiver from the Coast Guard. Review of copy of their new SMFF contract and the funding agreement is a good idea. The funding agreement must be USCG and P&I club approved. You should also inquire about pricing.

Please note, the SMFF provider may request to review the SOLAS pre-fire plan (FP), along with Supporting documents Part II-2 Reg. 15. Once the FP is acceptable for the SMFF provider, it may also be integrated in the Vessel’s Response Plan (VRP)….