Short answer: Elements are the components that make up the EEP and yes, the annual drill includes “all” equipment that is listed in the EEP.
Discussion: The phrase “all elements of the Emergency Evacuation Plan” as listed in the emergency drill requirements has often been questioned as to what it really means. Let’s take a look…
33 CFR 146.125(c)(1) “At least once a year, all the elements of the Emergency Evacuation Plan (EEP) under §146.140 relating to the evacuation of personnel from the facility must be exercised through a drill or a series of drills. The drill(s) must exercise all of the means and procedures listed in the EEP for each circumstance and condition described in the EEP under §146.140(d)(9).” [emphasis added]
The term “element” was added to the regulation with the final rule (published 18Mar1989) by the USCG in an effort to address industry comments to the proposed rule (published 24Dec1987).
Please note that the first sentence in the cite states “elements of the EEP under §146.140 relating to the evacuation of personnel from the facility”. The requirements of the EEP relating to personnel evacuation are detailed in §146.140(d)(9) through (12) and include recognized circumstances that would place the facility or its personnel in jeopardy and for which a mass evacuation would be recommended. Fires, blowouts, approaching hurricanes and ice floes are specifically mentioned as examples of circumstances that would recommend an evacuation and collisions are another circumstance that is often included in typical EEPs that would initiate an evacuation.
The second sentence in the referenced cite states that “the drill(s) must exercise all of the means and procedures listed in the EEP for each circumstance” [emphasis added] to further stipulate what is required to satisfy the drill requirement.
Means and procedures are listed at §146.140(d)(12) as those for:
- retrieving persons from the water during an evacuation;
- transferring persons from the facility to the designated type of evacuation method (e.g. designated standby vessels, lifeboats or other evacuation craft);
- retrieving persons from the evacuation craft that they were transferred to in the previous requirement; and
- the ultimate evacuation of all persons to land, another facility or other location reasonably out of danger for the specific circumstance for the evacuation.
The District Eight OCS OCMI (responsible for the OCS activities on the U.S. OCS in the Gulf of Mexico) has interpreted §146.125(c)(1) “to mean that all lifeboats aboard a facility, shall, at a minimum, be launched with assigned lifeboat crew in order to fulfill the requirements of the annual emergency evacuation drill” in section 5, paragraph a, of D8(OCS) Policy Letter 01-2020, dated 19May2020. The policy letter goes on to discuss alternatives to this requirement in paragraphs 5.d through 5.f.
In the context of lifeboats/capsules, some have questioned if there is a need to test “all” of the boats for units or facilities with multiple boats, or if demonstrating the means and procedures with one, or a sampling of boats, would satisfy the intent. Note that the referenced cite states “all of the means and procedures” and the D8 OCS OCMI has reiterated this in Policy Letter 01-2020.
Also note that while the focus tends to be on lifeboats with this annual requirement, the cite requires exercise of all of the means and procedures for each circumstance that are stipulated in the EEP.