Question 61 TV01 - Towing Vessels - Oceans or Near Coastal

The Correct Answer is B. ### Explanation of Correct Option (B) Option B states: **"The Plan cannot be implemented without approval."** This is the true statement regarding significant amendments to a Shipboard Oil Pollution Emergency Plan (SOPEP) or Shipboard Marine Pollution Emergency Plan (SMPEP). A SOPEP/SMPEP is a required document under MARPOL Annex I, Regulation 37, and, for U.S. compliance, falls under the jurisdiction of the U.S. Coast Guard (USCG). When an approved plan is significantly revised (e.g., changes to response procedures, contact lists, vessel particulars, or required pollution response resources), the revision must be reviewed and approved by the regulatory authority (in this case, the USCG) before the revised plan can be officially put into use or relied upon for compliance. Implementing a revised plan without this regulatory approval means the vessel is operating with an emergency plan that has not been confirmed to meet all statutory requirements, rendering the vessel non-compliant. ### Explanation of Incorrect Options **A) Submit only changes six months before the end of the approval period** This is incorrect. There is no standard requirement to submit changes specifically six months before the end of the approval period. While plans often have a 5-year approval cycle, mandatory revisions must be submitted as soon as significant changes occur (e.g., change in operator, response contractor, or vessel design), regardless of when the approval period ends. Furthermore, minor non-substantive changes (like updating contact numbers) may not require immediate resubmission or approval. **C) Submit changes one month before the anniversary date of the plan** This is incorrect. Similar to Option A, waiting for an anniversary date is not the rule for mandatory plan revisions. Significant changes must be submitted promptly, often within 30 days of the change occurring, to ensure the validity and effectiveness of the plan. **D) The Plan can be implemented without immediate approval as long as final approval is received within six months of submission** This is incorrect. While the regulatory review process may take several months, the vessel must typically continue to operate under the *previously approved* plan until the USCG formally grants approval for the revised plan. Operating under an unapproved, revised plan, based on the assumption that approval will eventually be granted, constitutes non-compliance because the legal requirement is to have an **approved** plan on board and in use.