The Irish Coast Guard – Department of Transport
Environmental Protection Agency (EPA)
Department of the Environment, Heritage & Local Government
The County & City Managers Association
Irish National Accreditation Board
National Standards Authority of Ireland

Northern Ireland Environment Agency
Maritime & Coastguard Agency (UK)
Irish Harbour Masters Association 

International Spill Accreditation Association

1 Name and Application of the Scheme
2 Purpose of the Scheme
3 How the Scheme is organized and administered
4 General description of Scheme
5 Accreditation Application Procedures
6 Accreditation categories
7 Clean-up standards
8 Premises and spill site visits
9 Specialist equipment requirements
10 Equipment maintenance
11 Training
12 Upgrade procedure
13 Complaints procedure
14 Accreditation fees
15 SRO’s accreditation suspension
16 Indemnity
17 Use of sub-contractors
18 Documents to accompany application
19 Code of Practice
20 Storage of Data
21 Guide to Accreditation Levels
 

The Scheme in Ireland is called the “International Spill (All-Ireland) Accreditation Scheme.”
The “ISAA All-Ireland” Scheme has scope in Northern Ireland and the Republic of Ireland but accredited status granted under the “ISAA All Ireland” Scheme is also recognised in other countries where ISAA Accreditation is recognised by relevant governmental authorities and other stakeholders.

The Scheme is applicable to Spill Response Organisations (SROs), defined as Spill Response Contractors in the private sector and other Spill Response Organisations including those operated by government agencies and industry.

Currently, the Scheme addresses the accreditation of SROs involved in Oil Spill Response. An international ISAA-ISCO Working Group of experts is engaged in the development of accreditation standards for response to spills of Chemical / Hazardous Noxious Substances (HNS) and it is planned to introduce the availability of Chemical / HNS response accreditation in 2010.
 

In the private sector the purpose of the Accreditation Scheme is to raise standards of performance within the oil spill response industry and thus to give customers confidence that they will receive a high standard of professional and cost effective performance from those contractors who have gone to the trouble and expense of seeking and achieving accreditation.

For governments and industry operators of spill response organisations, the Accreditation Scheme provides a means of verifying that their directly managed spill response operations are continuing to provide the required high standard of response capability.

The Scheme Assessor is there to give all accredited SROs advice and help rather than simply drawing attention to shortcomings.
 

Accreditation can apply to spills impacting on the marine environment, (docks, harbours estuarial and inshore waters), shorelines, inland surface waters (rivers, lakes, canals, streams), spills onto the ground in both domestic and industrial situations, spills that have impacted the groundwater, and spills resulting from accidents involving road and rail tankers. Besides setting standards of clean-up the Scheme also addresses safety issues, waste disposal procedures and waste minimisation.

Details of all ISAA accredited SROs are given on the ISAA website. ISAA has compiled a mailing list of regulators, local authorities, councils, oil fuel distributors, loss adjusters, insurance companies and other interested parties, and a reference booklet with information on SROs accredited under the ISAA All-Ireland Spill Accreditation Scheme is sent annually to everyone on the mailing list.
 

5.1 SROs wishing to gain accredited status should complete the Application Form and return one copy to ISAA. Alternatively a SRO may request the Scheme Assessor to visit its premises with a view to completing the form and dealing with any questions.

5.2 When the Application Form has been completed and any queries clarified, a visit will be arranged to both the applicant’s main base and any other bases included in the application. The purpose of these visits is to verify the information provided and to further assess the applicant’s spill response capacity and competency.

5.3 The applicant will be advised what level of accreditation has been awarded on the basis of the completed application form, examination of required documentation, inspection of the SRO’s premises, and the completion by the Assessor of the assessment matrix.

5.4 An appeal procedure will enable applicants to contest the level of assessment awarded.

5.5 The initial accreditation lasts for three years thereafter re-accreditation will need to be applied for.

5.6 In order to maintain the validity of Accredited Status over this three year period, in each of the years between three yearly accreditation assessments, visits are made by the Scheme Assessor to witness the SRO’s performance during an actual response operation or internal exercise and verify that accreditation requirements continue to be fully satisfied. If it is not possible for the Scheme Assessor to witness performance of an SRO during an actual response or internal exercise, the requirement may be met by interview and a performance assessment made by the Scheme Assessor during participation by the SRO’s personnel in practical exercises organised by ISAA as part of the annual training days event organised by the Association.

Accredited Status of an SRO found not to be in compliance with minimum requirements may be withdrawn or downgraded.

5.6. Additional interim assessments may be required as a result of:
Request for upgrade by an Accredited SRO
Results of spill site or response exercise assessment
Request of the Regulatory Authorities.
Material change in accredited SRO’s circumstances, either financial or operational.
 

Applicants may be accredited in any or all of the following categories (disciplines)

Marine (M) OPRC Tier 1 and 2 response to oil spills in the marine environment, (docks, harbours, estuarial and inshore waters)

Shoreline (SL) Response to oil pollution of the shoreline.

Freshwater (FW) Response to oil spills on inland surface waters (rivers, lakes, canals, streams)

On Land (OL) Response to oil spills onto the ground in domestic and industrial situations, highways, agricultural and other land.

Groundwater (GW) Response to oil spills that have polluted the ground water and underground aquifers.

Tanker Rollover (TRO) Response to oil spills resulting from road/rail tanker roll-over, collisions, derailments or road traffic accidents.

Technical competence in each discipline will be assessed by the applicant’s responses during a detailed assessment process.
 

Taking samples for analysis

The “All-Ireland” Scheme has adopted the EU code of practice for taking samples for subsequent laboratory analysis and only appropriately accredited laboratories experienced in carrying out the type of analysis required, should be used.


Completion of Work Certificate

Upon completion of work, a Completion Certificate confirming that work has been completed to the required standard should be presented by the SRO for signature by an authorised person. This person may be the authorised representative of the client, his insurers or the regulatory authority.
 

The Scheme requires the Scheme Assessor to assess each accredited contractor at least once a year. This can be done during a visit to the contractor’s premises or a spill/exercise site visit, or by the Scheme Assessor carrying out a compliance verification interview and evaluating performance during an exercise held during the annual ISAA Training Days event.

In the three year accreditation period the Assessor must inspect a spill/exercise site or witness performance during an exercise in each category for which the contractor is accredited. Where the contractor has more than one accredited base this requirement applies to each base.

A report will be issued by the Scheme Assessor each time a site is visited or exercise witnessed. These reports can be used by the contractor if required for issue to third parties as proof of competence. A copy of each report may be sent by the assessor to the relevant Authority.
 

In assessing availabilties of specialist equipment and materials the Scheme Assessor will be considering the types and quantities held to verify that they meet minimum requirements that are relevant to the discipline/s in which the candidate is seeking to gain accreditation. The following list is not prescriptive and actual holdings may vary in content provided that the required overall capability of response is maintained.

9.1 Freshwater (FW1) – Minor Spills
SROs should, as a minimum, hold equipment for retaining and removing oil from surface water including: oil absorbent materials, 20 metres oil retention booms (minimum size 25cm overall height), oily waste bags.

9.2 Freshwater (FW 2 and FW3) – Intermediate and Larger Sized Spills
SROs should, as a minimum, hold equipment for retaining and removing oil from surface water including: oil absorbent materials, 20 metres small oil retention boom (minimum size 25cm overall height) oily waste bags, 50 metres medium inflatable oil retention boom (minimum 45cm overall height), efficient weir or oleophilic skimmer with related pump, emergency recovered product holding tanks.

9.3 On Land (OL)
SROs should, as a minimum, be able to mobilise suitable equipment for spill recovery, spill site decontamination and temporary storage. Such equipment may include vacuum systems for recovery of liquids and solids, sorbent materials, brushes, spades and shovels, mechanical diggers, tipper trucks, vacuum tankers, skips, portable tanks and transfer pumps, non-emulsifying hard surface cleaning agents, hot / cold high pressure washers, drain cleaning equipment, oily water separators, biological treatment agents and applicators. Depending on level of accreditation being sought the Assessor may accept evidence of call-off arrangements with third parties in regard to some of the larger equipment items listed.

9.4 Groundwater (GW)
SROs should, as a minimum, hold equipment for recovering hydrocarbons from groundwater including, as a minimum: excavation or bore hole drilling equipment, down well pumps, oil/water filters, emergency holding tanks, sampling equipment, oil absorbent materials.

9.5 Marine (M1) – Small Port
SROs should, as a minimum, hold equipment for retaining and removing oil from surface water including: oil absorbent materials, 200 metres minimum 60cm rapidly deployable oil retention boom with associated ancillary equipment (anchors etc). Small boat to assist with boom deployment, oil skimmer with minimum 10 tonnes/hr capacity of design suitable for the pollutant viscosities likely to be encountered, emergency holding tanks – minimum storage capacity 14 tonnes, 2 x 10 metres lengths water ballasted shore seal boom.

9.6 Marine (M2) – Medium Port
SROs should, as a minimum, hold equipment for retaining and removing oil from surface water including: oil absorbent materials, 400 metres minimum 60cm rapidly deployable oil retention boom with associated ancillary equipment (anchors etc). Small boat to assist with boom deployment, two oil skimmers each with minimum 10 tonnes/hr capacity of design suitable for the pollutant viscosities likely to be encountered, emergency holding tanks – minimum storage capacity 28 tonnes, 4 x 10 metres lengths water ballasted shore seal boom.

9.7 Marine (M3) – Large Ports, Estuaries, Inland Waters
SROs should, as a minimum, hold equipment for retaining and removing oil from surface water including: oil absorbent materials, 400 metres minimum 60cm rapidly deployable oil retention boom with associated ancillary equipment (anchors etc). 200 metres minimum 70cm rapidly deployable oil retention boom, two boats to assist with boom deployment and evidence of a contract with a local tug operating company, adequate radio/telephone communication facilities, two oil skimmers of at least 10 tonnes and 20 tonnes capacity respectively of design suitable for the pollutant viscosities that may be encountered, emergency holding tanks – minimum storage capacity 50 tonnes, 4 x 10 metres lengths water ballasted shore seal boom.

9.8 Shoreline (SL)
SROs should, as a minimum, hold stocks of suitable PPE for shoreline cleaning personnel, hand tools (rakes, shovels, scoops, squeegees), portable bins, heavy duty plastic bags, rolls of plastic sheeting for pit-lining, sorbent materials, oil skimmers, portable tanks, recovered oil transfer pumps and hoses. SROs seeking higher levels of SL accreditation would be expected to own or have contingency arrangements for hiring in additional equipment – waste skips or mini-skips (with drainage holes sealed), front loaders, mechanical diggers, road tankers or tank trailers, portable liquid pick-up vac units, mobile toilets with washing facilities, changing room / shower trailers, shelter and messroom facilities, water bowsers, hot and cold water pressure cleaners, high volume, low pressure flushing pumps. Other potentially useful items include biological treatment agents and applicators (biodegradation treatment), inshore oil boom and interconnecting shore line sealing boom with accessories (for prevention of oil spreading to uncontaminated areas), disposable plastic skip liners, waterproof skip covers, heavy duty rubber strips and clamps (converting front loaders for use as mechanical squeegees), transportable road track (for facilitating vehicle movement on soft terrain).
 

Equipment requires protective storage and careful maintenance. The Scheme Assessor will need to inspect your equipment, storage and maintenance facilities, your Planned Preventative Maintenance (PPM) system and your maintenance records.
 

It is expected that all employees will have received immediate response training in-house. Beyond that however, training will depend on the size and resources of the contractor and on his past experience in responding to spills. The assessor will accept within the accreditation scheme process the capacity of the applicant to carry out in-house training but the acquisition of external training for key personnel is regarded as essential.

Contractors seeking accreditation for the first time will therefore have to undertake that their key operational staff attend an approved external training course in each category for which the contractor is accredited within 12 months. In addition thereafter all key staff should attend an approved external training course at not less than three yearly intervals.

For those contractors seeking marine and/or shoreline accreditation at Level 2 or above it is a requirement that staff have attended an appropriate IMO or MCA/NI training course.

Advice on approved training courses and course providers may be obtained from the Scheme Administrator.

Each individual employee’s training must be renewed at least every three years in order to maintain validity for accreditation purposes.
 

12.1. SROs can ask at any time for their accreditation level to be reviewed. Similarly any of the Regulators can, at their own expense, carry out an inspection which may result in the accreditation level being lowered or removed. A spill site or exercise visit may also result in accreditation being lowered or removed. However, it should be noted that the object of the spill site visit is to assist SROs to maintain or improve their accreditation levels and assistance will be given as appropriate to achieve this by the Scheme Assessor.

12.2. The Regulators are not required to give any warning that an inspection is to be carried out but they must furnish the SRO and the Scheme Assessor with a copy of any resulting request for accreditation levels to be amended. Such request will then be discussed between the Regulator and the Scheme Assessor and acted upon as appropriate.

12.3. A SRO wishing to increase his level of accreditation may apply to do so at any time but may be charged a fee irrespective of whether the upgrade application is successful.
 

Complaints can take various forms from failure of a particular SRO to perform in accordance with the required standards to a SRO using a non-accredited sub-contractor.

Complaints are dealt with in the strictest confidence and neither the name of the complainant or the SRO being complained about, are revealed to non-ISAA employees. Each complaint is dealt with by giving it a case number which is then referred to throughout. The Scheme Assessor will not become involved with commercial aspects of any dispute but will only look at the technical aspects of the complaint. However where gross overcharging is apparent the Scheme Assessor may make appropriate representations to the SRO for a reduction in costs. Following investigation a contractor may have their accreditation levels cancelled.

If a SRO is not satisfied with the results of the investigation, the SRO may appeal in writing to the ISAA board. Following a review of the case by the Board and, if necessary, a meeting with the SRO concerned, any decision subsequently reached will be final.
 

(Note: Fees stated are in Euros with figures in Pounds Sterling being shown in brackets. Fees may be subject to VAT)

Accreditation lasts for three years and fees are payable in advance. The scale of fees is as follows:

The cost of the initial accreditation assessment or re-assessment after three years is €500 (£500) per base

The annual cost of maintaining accredited status is €500 (£500) per base plus the cost of fees for spill site or spill exercise visits in intervening years which will be charged at €300 (£300) per visit.

SROs may request additional site visits which would be charged at €500 (£500) per visit.
 

SROs may be suspended or have their accreditation withdrawn for the following reasons:
15.1 Failure to meet agreed clean-up standards
15.2 Upheld complaint
15.3 Failure to pay any fees due under the scheme within the prescribed period
15.4 Failure to have spill/exercise visits / assessments carried out by the due date
15.5 Failure to fulfil regulatory requirements
15.6 Bankruptcy or coming under administration
 

The SRO shall be liable for and shall indemnify ISAA and the Regulatory Agencies, their Officers, Servants, Employees, Assessors, and Agents against liability, loss, claim or proceedings whatsoever arising under any statute or at common law arising out of or in the course of or in connection with the provisions of the SRO’s Services or by use of the SRO or its assessors and other staff, except insofar as such damage or injury shall be due to any act or neglect of ISAA and the Agencies, their Officers, Servants, Employees, Assessors and Agents.
 

Details of any regular sub-contractors used must be provided. It should be noted that the Applicant’s quality procedures and insurance liability must cover the sub-contractor. If accreditation is to be granted any sub-contractor left to handle a spill clean-up operation without being supervised by an accredited SRO, the sub-contractor must also be accredited. Under normal circumstances the use of non-accredited subcontractors for spill response operations is not acceptable.
 

SROs should ensure that the documents (1) to (3) below are submitted with the completed application form -

1) Health and Safety Policy

2) Copies of relevant insurance certificates or statement from broker or insurance company confirming levels of Public Liability, Employers Liability and, where appropriate, Professional Indemnity, Insurance

3) As applicable, copies of waste carriers licence, mobile plant licence/s, and any other licences or permits that are necessary in order for the SRO to operate in compliance with the law.

If convenient, applicants may also enclose some or all of the documentation listed in (4) to (14) below.

If not submitted with the application, the documents listed below should be looked out and held available ready for inspection by the Scheme Assessor at the time of the Assessment Visit

4) Detailed call-out procedures

5) Risk assessment procedure for spill sites including details of Health & Safety and PPE requirements

6) Copies of ISO 9001 and ISO 14001 Certificates or a written copy of quality and environmental procedures

7) Detailed inventory list of equipment and materials held on a base-by-base basis

8) Statement of equipment maintenance procedures, including post-use routines.

9) Schedule of company’s oil spill response personnel indicating details of training received (listing dates), qualifications and experience. Also detail of any procedures for employees’ personal development.

10) Copies of staff training certificates issued by external training organisations

11) Schedule detailing customer liaison procedures

12) Statement on proposed geographic areas of work and/or named specific locations to be covered by the application.

13) Copy of job time sheet or form used for recording work inputs.

14) List of regularly used sub-contractors (Used for emergency response assistance or waste disposal) NB Wherever possible only oil spill accredited sub-contractors should be used.

The Scheme Assessor will also wish to see the following –

15) Waste disposal documentation

16) Accident book

17) Equipment maintenance records.

It is important to have all of the requested documentation ready for inspection.
 

The Scheme has adopted the following Code of Practice to which all accredited contractors are expected to comply:

19.1 Private sector accredited SROs will give a schedule of rates before commencing an emergency clean-up or give a price estimate for the work to be undertaken before starting work.

19.2 Accredited SROs will use best practice in effecting a clean-up taking into account environmental considerations and health and safety requirements.

19.3 Any clean-up will be carried out expeditiously in the least possible time, taking into account specific site considerations.

19.4 On-land accredited SROs involved with clean-up of oil contaminated land at domestic premises must issue, or have issued on their behalf, a Validation and Site Assessment Certificate stating that the property has been returned, so far as contamination has been determined, to an acceptable oil free condition.

19.5 Private sector SROs will give clients, as a minimum, a detailed weekly update of costs and a report on work done to-date, together with an estimate of the length of time required to complete the job.

19.6 SROs will comply with all waste disposal legislation and have up to date licences as may be required.

19.7 Contractors will carry appropriate insurance cover relevant to the work being undertaken.

19.8 Before commencing work SROs will carry out a site specific Risk Assessment and draw up a clean-up plan. Copies of both of these should be held on site for inspection if required.

19.9 SROs agree to be subject to the accreditation scheme complaints procedure and agree to produce justification for costs, if requested.

19.10 SROs agree to submit spill sites for inspection by the Accreditation Assessor if so requested.
 

Please note that any information received as a result of an accreditation application and any subsequent accreditation correspondence may be stored electronically on a database held by the Scheme Administrator.
 

Accreditation Levels

Level 1

Able to respond to smaller spills where the required action does not need high level resources of equipment and manpower

Level 2

Able to respond to intermediate size spills demanding more resources but not large scale events that are complex and difficult to deal with

Level 3

Able to respond to larger spills that demand higher levels of equipment, manpower, knowledge and experience

NOTES

(1) These are generalised level awards based on an overall assessment in the identified response disciplines.

(2) Some SROs have high level specialised capabilities in certain types of work that, because not recognised as a separate accreditation disciplines, are not reflected in accreditation level awards.

(3) All SROs accredited under the All-Ireland scheme are encouraged to co-operate with each other in order to ensure that all necessary resources and skills can be brought to bear on the work in hand.

(V.5 Revised July 2010)