Who has the authority to grant an alternate procedure for oil transfer operations?
• Authority over oil transfer procedures in U.S. waters • Difference between Captain of the Port (COTP) and Officer-in-Charge, Marine Inspection (OCMI) roles • Where alternate or equivalent procedures are usually approved in 33 CFR Part 156 – Oil and Hazardous Material Transfer Operations
• Which Coast Guard position is specifically tied to inspecting vessels and facilities and approving deviations or alternatives to standard safety procedures? • Think about who signs off on equivalents or alternate procedures in the regulations – is it an operational/security role, or an inspection/marine safety role? • If a facility wanted to use a non-standard transfer setup, which office would review technical details and regulatory compliance?
• Look in 33 CFR 156.120–156.150 for language about alternate or equivalent procedures and note the specific title of the approving authority. • Verify which position (COTP, Area Commander, OCMI) is repeatedly named in fuel/oil transfer approval sections of 33 CFR. • Be sure the choice you pick is a specific regulatory title, not just a generic location like a nearby office.
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