the oil spill field operations guide - fog

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THE OIL SPILL FIELD OPERATIONS GUIDE (FOG)-NEW AND IMPROVED1CDR Kristy Flour deNational Strike Force Coordination Center1461 North Road StreetElizabeth City, North Carolina 27909

Jean R. Cameron LCDR Vickie HuyckStates/British Columb ia Oil Spill Task Force Comm andant (G-MO R)811 S. W. Sixth Avenue 2100 Second Street, S. W.Portland, Oregon 97204-13 90 Washington, District of Columb ia 20593-00 01ABSTRACT: The original oil spill Field Operations Guide(FOG ) was a product of the Standard Oil Spill Response Management System (STO RMS) Task Force comprised of representatives of the U. S. Coast Guard, California Department of Fishand Game Office of Spill Prevention and Response (OSPR), otherstates, the petroleum industry, oil spill response organizations,and local government. The STORMS Task Force produced thisfirst version of the "oilized" Incident Command System (ICS)FOG and Incident Action Plan (IAP) forms in 1994 and madesubsequent revisions in 1995 and 1996. With 2 more years of ICSexperience and facilitated by the States/British Columb ia OilSpill Task Force, a new group of representatives from federal andstate governments, the petroleum industry, and oil spill responseprofessionals met to review and update the 1996 FOG and IAPforms in October 1998. The overall goal wa s to remain con sistentwith the National Interagency Incident Management System(NIIMS) yet reflect the experience gained using ICS at actual oilspills and drills. The group met quarterly over an 18-monthperiod, working collaboratively to reach a consensus on numerous changes. Some of the changes included adding an Environmental Unit to the Planning Section, revising the planning cyclediagram for the oil spill IAP process, and revising the IAP formsas appropriate to reflect the way oil spills are managed. Allsignificant revisions/improvem ents will be highlighted in thispaper and poster.FO G u p d at e p rojec t b ack grou n d an d p roces s

The National Interagency Incident Management System(NIIMS) version of the Incident Command System (ICS), developed to integrate multiple firefighting units in a wildland fireresponse situation, has become the adopted model for oil spillresponse. ICS was developed in the 1970s for fire response tointegrate multiple response organizations and reduce confusionduring an emergency situation. By standardizing response roles,ICS provides for consistency. As recently as 1994, however, ICSwas being used only sporadically for emergency applicationsother than firefighting, including oil spill response. The first draftof the oil spill Field Operations Guide (FOG) was used in thePreparedness for Response Exercise Program (PREP) exercise inLos Angeles, California in fall 1994. It became very popular, anddemand for its use generated requirements for training programsand forms. The group known as the Standard Oil Response Man

agement System (STORMS) was organized to guide this effort.The STORMS Task Force produced the first official oil spill response-focused ICS FOG in 1996, which was published by California Department of Fish and Game Office of Spill Preventionand Response (OSPR) and the U.S. Coast Guard. Many federaland state emergency response agencies are now required to useICS. In addition, the response systems specified in vessel andfacility oil spill contingency plans are required by many regulatory agencies to be compatible with NIIMS ICS.The work of the STORMS Task Force was so successful thatthe oil spill FOG has only required "updating" to reflect ongoingfield experience as well as emerging response paradigms. Following the 1998 Spill of National Significance (SONS) drill inValdez, Alaska, it was agreed that the States/British Columbia OilSpill Task Force should facilitate a national workgroup focusedon updating the 1996 FOG for oil spill response. Similar "update"efforts already had begun. The Alaska Department of Environmental Conservation (ADEC) began an Alaska FOG update process in cooperation with Alaska industry and response organizations in 1998. In addition, the Coast Guard had adopted NIIMSICS for all emergencies and established a Response ManagementCoordination Council to coordinate uniform implementation anddevelop a generic ICS FOG for multiple contingencies, addingannexes for natural disasters, terrorism, and hazardous material

and oil spill incidents.By initiating and participating in the States/British ColumbiaOil Spill Task Force FOG Update Project, ADEC and CoastGuard helped align these efforts with a consistent outcome. Thetask force convened a FOG Update Project Workgroup in December 1998. The workgroup included representatives of the taskforce state agencies of the California Department of Fish andGame, the Texas General Land Office (TGLO), and the FloridaDepartment of Environmental Protection (FDEP). Other interested states around the United States were kept "in the loop"electronically.The National Strike Force Coordination Center, the Office ofResponse at Coast Guard Headquarters, and the Eleventh andThirteenth Coast Guard Districts on the West Coast representedthe US Coast Guard. Other U.S. federal agencies represented onthe workgroup included the Minerals Management Service(MMS), National Oceanic and Atmospheric Administration(NOAA), and Environmental Protection Agency (EPA). TheCanadian Coast Guard and the U.S. Fish and Wildlife Service(USFWS) sent observers to the first meeting and remained on the

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mailing/email list in an observer capacity. The Office of PipelineSafety (OPS) participated via email.Oil industry representatives on the workgroup included thosefrom ARCO, American Waterways Operators, BP Exploration,Chevron, Equiva Services, Exxon, Mobil, SeaRiver MaritimeInc., Tesoro, and Unocal. In addition, representatives from theNational Wildfire Coordinating Group participated as advisors onNIIMS ICS protocols. A complete list of the members of theFOG Update Project Workgroup is included in the final workgroup report2.There was a consensus within the FOG Update Project Workgroup at the first meeting for maintaining a standardized oil spillFOG nationwide. There was considerable discussion regardingwhether the oil spill FOG should follow NIIMS ICS, which is acomprehensive system with many facets, including forms andtraining. The workgroup ultimately agreed to base the FOG onNIIMS ICS principles, but did not commit to use of the entireNIIMS ICS system. Any application of NIIMS ICS principles tooil spill response must address a major difference between spillresponse and firefighting: the role of a responsible party (RP).An oil spill response is most likely to include responders from theregulated industry organization responsible for the spill as well asstate and federal spill response agencies. This dynamic tensionbetween the regulators and the regulated means that the standardization of response roles inherent in ICS is even more criticalto facilitating a rapid and effective response.All participants at the first FOG Update Project Workgroupmeeting were asked to brainstorm what had worked well with theoil spill FOG and what changes, if any, they would recommendfor further discussion. Six priority themes were drawn from thesebrainstormed issues; during discussion of these priority themes,the following points and decisions were made: The workgro up should concentrate its efforts in revisingthe FOG for oil spill response. The concept of a generic,all hazards FOG was only of limited interest to most attendees, at least as a priority need. The workgroup should review the NIIMS ICS positions

for oil spill checklist items and develop ICS oil positionsthat are not covered in the existing FOG. Examplesincluded the Environmental Unit, Legal, and Human Resources. The workgroup agreed, and a Positions Subcommittee was established to address this issue. Resource typing standards generally were acknowledgedas useful. However, this was not deemed a priority for theassembled group. Various spill response topics were not addressed in the1996 FOG, so new text was needed to address the JointInformation Center (JIC), Area Command, and the needfor an information flow diagram, for example. A TopicsSubcommittee was established to develop recommendations to the full workgroup. The workgro up agreed that establishing response qualifications is an important step in improving theprofessionalism of oil spill responders, but there wasconsensus that this was a bigger issue than this groupwished to address under the FOG Update Project3. The workgro up agreed that the FOG forms and processesshould be reviewed and possibly simplified. A subcommittee was established to review oil spill response formsand recommend changes based on the need for consistency among users as well as flexibility in the field.The full FOG Update Project Workgroup met for a total of six2-day sessions with the last in February 2000 in San Diego, California. Most subcommittee sessions also were held by conferencecall between workgroup meetings. Progress was reviewed anddiscussed at each quarterly workgroup meetings, with feedback

incorporated into final subcommittee recommendations compiledinto a FOG format, discussed in December 1999, and reviewedagain in February 2000.

Updates to the oil spill FOGThe revised FOG layout includes tables of contents in eachsection, modeled on the Firescope FOG; this makes position description references more efficient. In addition, the entire document was edited for consistency. The format of the FOG stillgenerally follows the previous versions now having the followingchapters: Introduction , Response Organization Development,Response Objectives and Strategies, Agency/Stakeholder Coordination, National/Regional Incident Command Responsibilities,Common Responsibilities, Incident Command, Operations Section, Planning Section, Logistics Section, Finance/AdministrationSection, Resource Typing Guidelines, Glossary and Acronyms,Incident Action Plan (LAP) Process and Meetings, ICS-OS FormsIndex, and Incident Situation Display. The substantive revisionsto the oil spill FOG, as agreed to by the FOG Update Project

Workgroup, are discussed below.The response objectives previously listed on the inside backcover have been moved to the inside front cover and are listed as"typical" response objectives. A statement underscoring theparamount importance of safety heads the page.The Standard Incident Command System organizational chartin the front of the 1996 FOG was moved to a new Section 2 andcombined there with the organizational guide information formerly in Section 9. The organizational chart is revised to reflectadditional changes described below and is titled "Example Response Organization."The Introduction section was revised as follows: Text was added to explain the relationship of the FOGwith the National Response System and the National Contingency Plan, as well as the role, resources, and authorityof the Federal On-Scene Co ordinator (FOSC). Text was added to explain that the FOG is not a regulatorydocument, but rather provides generic guidance that mustbe adapted to each specific response situation. Updated Web site addresses are listed for the U.S. CoastGuard and NOAA, with guidance regarding informationavailable at these sites.A new Section 3 is titled "Response Objectives and Strategies." It explains the differences am ong objectives, strategies, andtactics, and provides examples.A new Section 4 titled "Agency/Stakeholder C oordination" replaced the Multi-Agency Coordination System (MACS) section.The different roles of the Liaison Officer, Regional ResponseTeam, Area Committees, and MACS are explained as they applyto coordination of both agency and stakeholder concerns andresources, both before and during a spill response. Text also hasbeen added to underscore the importance of agency and stakeholder coordination, with guidance on how to address stakeholderconcerns.A new Section 5 was added, titled "National/Regional IncidentCommand." This section describes how the U.S. Coast Guardwill implement an oil spill version of the Area Command modelused for major/multiple incident management within NIIMS ICS.This section provides guidance to FOSCs regarding strategiccoordination during a SONS, consistent with the authorities outlined in the National Contingency Plan. As noted in the text"Based on the need for overall Federal coordination, a National orRegional Incident Command (NIC/RIC) organization may beactivated at the discretion of the controlling Federal authority."


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The section further explains that "...th e N IC/RIC will work withthe RP (responsible party) and other agencies (Federal, state, orlocal) to agree on an organizational structure that best ensureseffective strategic coordination." A NIC/RJC organizational chartis provided at the end of the section.The only change to the Common Responsibilities section wasto add the following statement: "Ensure continuity using in/outbriefings."The following revisions were made to the Command Section: Text was added to clarify the difference between an Incident Commander (IC) and Unified Command (UC). Text was added under the Information Officer's responsibilities to reference a JIC. The Liaison Officer's position description was expandedto include stakeholder coordination. Text was added to the Natural Resource Damage Assessment (NRDA) Representative description, as well as newlanguage referencing Incident Investigations, to indicatethat these functions are separate from, but concurrentwith, spill response. These are activities outside of the ICSstructure that must be coordinated with response activities.

Initial coordination through the Liaison Officer is recommended, but necessary coordination with the Environmental Unit Leader (EUL), the Wildlife Branch, theNOAA Scientific Support Coordinator (SSC), and Finance/Administration is acknowledged.Revisions to the Operations Section include the following: Text was added to reflect two new position s: a Dispersants Operations Supervisor and an In Situ Burn OperationsSupervisor. Related references were added to other position descriptions, as necessary. The words "Source Control" were added to the SalvageGroup Supervisor description to acknowledge the functionof source control for situations where the spill source isnot a vessel.The Planning Section was revised to include the following: Text was added to describe the following new position s:Environmental Unit Leader, Response Technologies Specialist (note that these are no longer considered Alternative Response Technologies), Weather Forecast Specialist,Shoreline Cleanup Specialist, Historic/Cultural ResourcesSpecialist, and Human Resource Specialist (this positionis described here with other specialists, although the position is normally assigned to the Finance/Administrationsection). The Glossary was revised for consistency with otherchanges, as well as to improve consistency with NIIMSICS. A list of acronyms was added to the Glossarysection. The FOG Update Project Workgroup approved incorporating the Resource Type List developed by the U.S.Coast Guard Research and Development Center into theoil spill FOG to replace the Resource Typing Section (11)in the 1996 oil spill FOG. Section 13, "Meeting s and Briefing s" was changed to"Incident Action Plan Process and Meetings," and is nowSection 14. The Plannin g Cycle Guides at the end of each functionalsection have been replaced with a new Operational PeriodPlanning Cycle graphic as shown in Figure 1. Text describing the Unified Comm and Objectives Meeting was moved from Special Purpose Meetings andinserted before the Tactics Meeting text. Under SpecialPurpose Meetings, there is now the Initial Unified Command Meeting. All other Special Purpose Meetings

remain, except that "Press Conference" is changed to"News Briefing."Edits were made in this section with regard to meetingattendance and agendas.

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Figure 1 . P lann ing cyc le .Consistent with the 1996 oil spill FOG, the ICS Forms Indexsection provides an overview of changes to the oil spill forms.Please see the discussion below.The only revision to the Incident Situation Display Section wasto add a page titled "Suggested Situation Map Information,"which lists types of information that may need to be displayed.The categories include Response Resources, Facilities, ResponseSites, and Public Facilities.

Revision to the oil spill ICS formsA Forms Subcommittee was established at the first FOG Update Project Workgroup meeting. Based on the feedback of thefull workgroup, this subcommittee labored through numerousrevisions to refine the oil spill ICS forms, with the goal of makingthe forms more user friendly. The subcommittee reviewed formsthat were developed by various industry groups and agencies andcaptured the best aspects of them all, with the goal of producingforms that would be used consistently by all spill responders.Consistent with the 1996 oil spill FOG, the ICS Forms Indexprovides an overview of changes to the oil spill forms. The specific changes/revisions to the forms are not discussed here but canbe found in the final workgroup report. The following National


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Fire Equipment System (NFES) forms have been slightlymodified for oil spill response, but either version can be used: 201 -OS: Incident Briefing 202- OS: Response Objectives 203-O S: Organization Assignment List 204-O S: Assignment List 205-OS: Incident Radio Communications Plan 206-OS: Medical Plan 207-OS: Organization Chart 209- OS: Incident Status Summary 210-OS: Status Change 213-OS: General Message 214-OS: Unit Log 215-OS: Operational Planning Worksheet 220-OS: Air Operations Summary 221-OS : Demobilization CheckoutThe following optional forms are new for oil spill response andhave no NFES equivalent: 204a- OS: Assignment List Attachment 205a-OS: Communications List 21 le-OS: Check-in List (Equipment) 211p-OS : Check-in List (People) 214a-OS: Individual Log 230-OS: Daily Meeting Schedule 231-OS: Meeting Summary 23 2- 0 S : Resources at Risk Summary 232a-OS: ACP Site Index An IAP cover sheet An Executive Summary A General Plan Initial Incident Information Sheet

Discussion of significant issuesThe final revisions to the oil spill FOG and the ICS forms thatare summarized above do not capture the comprehensive natureof the discussions held by the workgroup leading to these revisions. Nor did the workgroup consider the FOG itselfwhich isintended to be a pocketsize field guideto be the appropriateplace to summarize these discussions. Summary notes on thesetopics and issues can be found in the FOG Update Project Workgroup's final report. Major topics of discussion included the relationship of the FOG to the National Contingency Plan, AreaContingency Plans, Facility Response Plans, and Vessel Response Plans; the importance of maintaining and using one nationwide FOG; training recommendations; the shape of the Unified Command; the integration of salvage decision making intoUnified Command; NIC/RIC and Area Command issues; and therole of the deputy OSC.

Related endeavorsThe context of this effort to update the oil spill FOG includedtwo concurrent endeavors which have both shaped, and beenshaped by, the discussions and decisions of the workgroup. Theseconcurrent projects were the creation of the Alaska Incident Man-

1 The opinions or assertions expressed in this paper are solelythose of the authors and do not necessarily represent the views ofthe U. S. Coast Guard or the States/British Columbia Oil SpillTask Force.2 Contact Ms. Jean Cameron for information about obtaining theworkgroup's final report.

agement System Guide for Oil and Hazardous Substance Response, and a project by the National Response Team to applyNIIMS ICS principles to multiple emergency contingencies anddevelopment of a multicontingency FOG. Expanded discussion ofthese can be found in the working group final report.

Next s tepsThe revised oil spill FOG is available on the U.S. Coast Guardand NOAA Web sites4 or for purchase through the GovernmentPrinting Office. As noted on the last page in the Introductionsection of the revised FOG, comments and recommendations foradditional changes to the FOG should be sent to the U.S. CoastGuard's Office of Response (address provided in the FOG). Asnoted, the Coast Guard is working within the National ResponseTeam to develop a FOG that addresses multiple contingencies,not just oil spills. Therefore, the next update to the oil spill FOGis likely to be an update of what will actually be one section inthe multiple-contingency FOG.

Biograp h yCDR Kristy Plourde currently is serving as the Deputy Commander of the National Strike Force. She has managed numerousresponses and has served as Federal On-Scene Coordinators Representative/Incident Commander, Operations and Planning Section Chiefs, and other ICS roles during spill responses. She has 18years Coast Guard experience and has an M.S. in Chemistry fromthe University of Connecticut and B.S. in Physical Sciences fromthe U.S. Coast Guard Academy.Jean Cameron has served as the Executive Coordinator of theStates/British Columbia Oil Spill Task Force since 1993, whereher responsibilities include implementing Task Force projects,providing outreach to key stakeholders, facilitating meetings and

information exchange, and related administrative tasks. Jean iscurrently a member of the Navigation Safety Advisory Councilfor the U.S. Coast Guard as well as the U.S. Coast Guard/American Waterways Operators' Pacific Regional Quality Steering Committee. Ms. Cameron's Bachelor of Science degree inResource Development and Environmental Management wasreceived summa cum laude from the Department of Planning,Public Policy, and Management at the University of Oregon.LCDR Victoria Huyck is in a postgraduate training programand will be pursuing a M.P.A. at the George Washington University. She served most recently as the Chief of the Coast Guard'sResponse Operations Branch at Coast Guard Headquarters inWashington, D.C. She was responsible for the development andoversight of new and existing oil and hazardous materials response policy. A 1988 graduate of the U.S. Coast Guard Academy (B.S. in Applied Science), LCDR Huyck is also currentlyworking on an M.S. in Human Resource Administration. Prior tocoming to the Washington, DC area, she served as the PollutionResponse Branch Chief at Captain of the Port New York whereshe provided oversight and direction for hundreds of pollutioncases including over 80 federally managed cases.

3 Recommendations for spill responder knowledge and trainingare outlined in Appendix C of the Alaska Incident ManagementSystem Guide. Also available on-line at www.akrrt.org/aim.4 The FOG, forms, and job aids are available on-line at:www. uscg. mil/gq/g-m/nm c/response/fog.pdf orwww.uscg.mil/hq/nsfcc/nsjweb . The ICS forms only are availableon-line at response.restoration.noaa.gov/oilaids.htm
http://www.akrrt.org/aimhttp://www.akrrt.org/aimhttp://www.uscg.mil/hq/nsfcc/nsjwebhttp://www.uscg.mil/hq/nsfcc/nsjwebhttp://response.restoration.noaa.gov/oilaids.htmhttp://response.restoration.noaa.gov/oilaids.htmhttp://www.uscg.mil/hq/nsfcc/nsjwebhttp://www.akrrt.org/aim

the oil spill field operations guide - fog

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