Recommendations to enhance preparedness and response for ship source oil spill in haiphong port waters

Until now, petrol companies, ports, shipping companies and local authorities as well have been good practices in oil spill preparedness and response such as building up oil spill conting

PREFACE

Being situated on the coast of the South China Sea, Haiphong is the most crucial commercial and transportation hub of the North and the Nation, connecting the Northern provinces with the world market through its seaport, and lies at the important point of “Two economic corridors – One economic ring” Nowadays, thanks to the favorable conditions for port activities, there are over 40 ports operating along the Cam – Bach Dang River Over the last several years, along with Vietnam’s impressive and consistent economic growth, there has been a significant increase in exporting and importing cargoes throughout Haiphong ports There is no denying that this tendency has contributed dramatically to maritime sector development in Haiphong city, nonetheless, it would pose immense threats to the environment Although large spills from vessels or barges have become less frequent in the last few decades, accidents with medium spills still happen in Haiphong Port Waters Such incidents have serious effects on marine ecosystems and can cost over millions of dollars in oil-spill cleanup According to United Nations Secretary-General Kofi Annan, “Prevention is not only more humane than cure; it is also much cheaper” Therefore, good practice in emergency preparedness and response is able to minimize potential danger to human health and the environment by ensuring a timely and coordinated response In this research paper, some recommendations are offered to enhance preparedness and response for ship-source oil spill in Haiphong Port Waters

To sum up, I declare that this report is my own unaided work It has not been submitted before If violated, I am solely responsible for and bear the punishments of the Institution and University

Student Name and Signature

TRAN THI THU HA

ACKNOWLEGEMENT

Foremost, I would like to especially express my sincere gratitude to my lecturer Mr Tran Hai Viet for the excellent supervision, continuous support and collaboration during the entire period of my dissertation He always spent his time

on answering all of my questions concerning with this research paper He also helped with grammatical corrections, documentation and coached me a lot by giving me feedback and tips on how to handle and approach situations, how to use English writing, how to build up and arrange ideas for its

My special thanks also go to Vu Ba Cong – being the Deputy Director at Department of Natural Resources and Environment, for offering me the internship opportunities in Department of Natural Resources and Environment

I also owe many thanks to Mr Nguyen Van Can (being a manager of Sea & Island Branch, belonging to the department of natural resource and environment) and Mr Mai Duc Long (being a Head of Sea & Island Branch, belonging to the department

of natural resource and environment), who were very helpful and always willing to give me lots of advice, feedback, materials The face-to-face conversations and conversations through email with them are also important learning moment for me during my internship

Last but not least, I would like to thank my family for their support during four and one-half years of my studies I would especially thank my father, Mr Tran Minh Tan, who has inspired me through years and my mother, Ms Nguyen Thi Minh Nguyet, who has helped me immensely during my studies

TABLE OF CONTENTS

PREFACE i

ACKNOWLEGEMENT ii

ABBREVIATIONS v

LIST OF TABLES vi

LIST OF FIGURES vii

INTRODUCTION 1

CHAPTER 1 4

LITERATURE REVIEW 4

1.1 Oil spill 4

1.1.1 Definition of Oil 4

1.1.2 Oil pollution 4

1.1.3 Definition of oil spill and Types of oil spill 4

1.1.4 Ship-source oil spill 4

1.1.5 Causes of oil spill accident from vessels 4

1.1.6 Impacts of oil spill 5

1.2 Legal basis 7

1.2.1 International conventions 7

1.2.2 Vietnamese laws, circular, decree, decision, branch standard 9

CHAPTER II 20

INTRODUCTION OF SEA AND ISLAND BRANCH AND OVERVIEW OIL SPILL SITUATION AND EVALUATION OF CURRENT STATUS OF OIL SPILL PREPAREDENESS AND RESPONSE IN HAIPHONG PORT WATERS 20 2.1Introduction of Sea and Island Branch 20

2.1.1 Geographical location & History 20

2.1.2 Position &Function and Duties & Powers of Sea and Island Branch 20

2.1.3 Organizational structure of Sea and Island Branch 21

2.1.4 Personnel 22

2.2 Haiphong Port Waters 22

2.3 Overview oil spill situation 22

2.3.1 International oil spill situation 22

2.3.2 Vietnamese and Haiphong oil spill situation 24

2.4 Evaluation of current status of oil spill preparedness and response in Haiphong Port Waters 26

2.4.1 Oil Spill Response Organizational Structure in Haiphong 26

2.4.2 Responsibilities of stakeholders in Oil Spill Response Organizational Structure 28

2.4.3 Evaluation of current status of oil spill preparation in Haiphong Port Waters31 2.4.4 Evaluation of current status of oil spill response in Haiphong Port Waters 40

CHAPTER III 45

RECOMMENDATIONS TO ENHANCE PREPAREDNESS AND RESPONSE FOR SHIP-SOURCE OIL SPILL IN HAIPHONG PORT WATERS 45

3.1 Recommendations to Department of Natural Resource and Environment – Sea and Island Branch 45

3.2 Recommendations to Oil Spill Response Companies 48

3.3 Recommendations to Manufacturers of oil spill containment booms 49

3.4 Recommendations to Organizations who are obligatory to have OSCP 50

3.5 Recommendations to Local Authorities 51

3.6 Recommendations to Vietnam Maritime Administration – Department of Legal Affairs…… 52

CONCLUSION 53

Appendices 54

Reference: 75

LIST OF TABLES

TABLE 1: International conventions 7 TABLE 2: List of oil spill accidents in Haiphong Port Waters from 2004 to 2014 24 TABLE 3: Oil concentration of Vietnamese ports 26 TABLE 4: Four main clean-up methods 35 TABLE 5: Oil spill response equipment in Northern Oil Spill Response Center 37 TABLE 6: Oil spill response equipment in Northeastern Oil Spill Response Company 38 TABLE 7: Oil spill response equipment in Hoa Anh Joint Stock Company 39 TABLE 8: Oil spill response time of ship-source oil spill in Haiphong Port Waters 40 TABLE 9: List of companies being approved oil spill contingency plan since 2013 60 TABLE 10: List of international and domestic shipping companies being approved oil spill contingency plan since 2013 62

LIST OF FIGURES

FIGURE 1: Organizational Structure Diagram of Sea and Island Branch…………21

FIGURE 2: Number of Oil Spills between 1970 and 2014 in the world………… 22

FIGURE 3: Oil Spill Response Organizational Structure……….26

INTRODUCTION

Necessitation

The development of maritime transport industry poses immense threats to environment in Haiphong which is one of largest seaports in Vietnam and especially lies at the important point of “Two economic corridors – One economic ring” Currently, there are over 40 ports operating along the Cam- Bach Dang River in Haiphong Due to large scale shipping activities, Haiphong Port Waters is at high risk for oil spills effecting significantly to environment, economy, tourism industry, and human health Although there have been few ship-source oil spill accidents in Haiphong Port Waters over the last several years, such accidents still happen primarily due to human activities approximately 90 per cent Until now, petrol companies, ports, shipping companies and local authorities as well have been good practices in oil spill preparedness and response such as building up oil spill contingency plans, organizing training courses, conducting oil spill drills which assist oil spill response rapidly and effectively Nonetheless, in the case of actual accidents, some companies still become relatively unconfident perhaps because of subjective thinking In addition, because the methods for responding to oil spills are constantly evolving and each oil spill provides an opportunity to learn how to better prepare for future incidents, the preparedness and response are also constantly evolving and improving – ensuring increased protection for human health and environment from these accidents For such reasons, this research paper becomes necessary for organizations with regard to oil spill response

develop the interpersonal relationship that can mean so much to the smooth functioning of a response It is hope that with the application of this, the impact and damages on the marine environment caused by an oil spill will be very much minimized if not totally avoided

2013 Though the oil spill preparedness and response is divided into 3 tiers: Tier 1- Grassroots spills and provincial spills, tier 2- regional spills and tier 3- national spills, this writing paper only concentrates on Tier 1 response: Provincial spills (means beyond capability of Grassroots spills)

Research Method

Both Descriptive - quantitative and qualitative methods were used in this study to gain unique and important insights into the research problem In particular, this research provides descriptions of preparedness and response for ship-source oil spill by using direct observations, document review, face to face conversations with Sea and Island Branch Moreover, numerical descriptions also were offered clearly

in this dissertation such as figures for oil spill accidents in Haiphong Port Waters as well as in the world

Research Findings

This research provides readers with a whole picture of ship-source oil spills

in Haiphong Port Waters Particularly, oil spill accidents, which have occurred irregularly in Haiphong Port Waters over the last several years and the majority of oil spills is only medium oil spills, which has total amount of spilled oil from 20 to

500 tones pursuant to the Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response; caused by broken equipment, collision, shipwreck and grounding In addition, the similar

pattern is repeated in global oil spill but such incidents still happen and eventually lead to dramatic dangers to marine environment as well as human health With regard to oil spill preparedness and response, most of organizations being shipping companies, ports, petrol companies and others had their own oil spill contingency plans; conduct oil spill response drills and organize training courses on oil spill response However there have been some issues which need to handle them as soon

as possible with the sake of minimizing impacts and damages caused by oil spill accident These issues will be mentioned more detailed in chapter 2

CHAPTER 1 LITERATURE REVIEW

1.1 Oil spill

1.1.1 Definition of Oil

The International Convention for the Prevention of Pollution from ship, 1973(MARPOL 73/78) defines as follows: “Oil as petroleum in any form including crude oil, fuel oil, sludge, oil refuse and refined products (other than petrochemicals which are subject to the provisions of the Annex II of the Convention for the Prevention of Pollution from Ships) and without limiting the generality of the foregoing, includes the substances listed in Appendix I to Annex 1of the 1973 Convention”

1.1.2 Oil pollution

Oil pollution is one of the most conspicuous forms of damage to the marine environment Oil enters the seas not only as a result of spectacular oil tanker or oil rig disasters, but also – and primarily – from diffuse sources, such as leaks during oil extraction, illegal tank-cleaning operations at sea, or discharges into the rivers which are then carried into the sea.(1)

1.1.3 Definition of oil spill and Types of oil spill

An oil spill is a form of environmental pollution It is the release of a liquid petroleum hydrocarbon into the environment as a result of human activity.(2)

There are three types of oil spill being spills from ships, spills from offshore

drilling and spills from pipelines.(3)

1.1.4 Ship-source oil spill

An oil spill is a form of environmental pollution It is the release of a liquid petroleum hydrocarbon into the environment from the vessels Costs incurred for removing oil spills are relatively high, and it may take several months or in some

cases many years to clean up the spills.(4)

1.1.5 Causes of oil spill accident from vessels

Oil spills can arise from a number of different sources ranging from a collision or grounding of vessels carrying crude oil and product in local ports or coastal waters and from breaking down of equipment in the tanker or vessels They can also arise from tankers or barges operating on inland waterways, or from exploration and production operation and tankers operating in international waters Furthermore, ship-source oil spill also happen due to other reasons, some of these

are:

- Acts of terrorism, whereby there is intentional oil spills;

- Hostile acts: When two nations are at war, one may decide to dump gallons

of oil into the other national’s oceans;

- Natural disasters such as hurricanes (5)

It is obvious that the majority of such reasons involve in human errors (approximately 90 per cent)

1.1.6 Impacts of oil spill

a) Environmental effects

First of these is the environmental effect The animal life that lives in the water or near the shore is the ones most affected by the spill In most cases, the oil simply chokes the animals to death Others that live face a number of other problems The oil works its way into the fur and plumage of the animals Consequently, both birds and mammals find it harder to float in the water or regulate their body temperatures

In addition, many baby animals and birds starve to death, since their parents cannot detect their natural body scent Birds that preen themselves to get rid of the oil accidentally swallow the oil and die due to the toxic effects In many cases, the animals become blind due to repeated exposure to the oil Dolphins, sea otters, fish, countless species of birds and many oceanic mammals face these consequences Countering these effects and cleaning the oil can take anywhere between a few weeks to many years, depending on the damage caused (6)

b) Effect on economy

The second major effect of the oil spill is seen on the economy When precious crude oil or refined petroleum is lost, it affects the amount of petroleum and gas available for use This means more barrels have to be imported from other countries Then it comes to the process of cleaning the oil spill, which requires a lot

of financing Although the company must be responsible for the oil spills and their effects have to clean it up, there is a lot of government help required at this point Furthermore, the workers that are brought on board to clean up the spill or relate directly to cleaning up oil spill face to tremendous health problems later in life as well Their medical treatment has to be paid for and becomes the responsibility of the government Putting all the methods of recovery into place and monitoring them takes away resources from other more important work and hits the economy in subtle but powerful ways.(7)

c) Effect on tourism industry

The local tourism industry suffers a huge setback as most of the tourists stay away from such places Dead birds, sticky oil and huge tarballs become common sight Due to this, various recreational activities such as bathing, boating, angling and diving for shorter or longer periods of time cannot be performed in shorter or longer periods of time.(8) Therefore, attractive coastal beaches and resorts are affected the costs could be high As a result, hotel and restaurant owners, and others who have their income from recreational activities in the coastal zone — boat renters, diving tour operators, angling tour operators and many more — may suffer significant economic losses.(9)

d) Social-economic effects

In terms of fisheries and aquaculture: An oil spill can have a number of direct and indirect effects on fisheries Valuable fishing and shellfish areas may be closed for fishing for shorter or longer periods because of the risks of the catch being tainted by oil Concentrations of petroleum contaminants in fish and crab tissue, as well as contamination of shellfish, could pose a significant potential for adverse human health effects, and until these products from near shore fisheries or aquaculture have been cleared by the health authorities, they could be banned from human consumption Indirectly, the fisheries sector will suffer a heavy loss if consumers are either stopped from using or unwilling to buy fish and shellfish from the regions affected by the spill (10) After that, a large number of fishermen can

cope with jobless situation and then the unemployment rate also might climb dramatically as well

e) Effects on human health

People’s health could be adversely affected by oil either when inhaling or touching oil products, or when eating contaminated sea food

When cleaning up oil products from the water surface or the shoreline, one must always take certain precautions One needs to wear a face mask or filter mask

be protected from inhaling vapors from oils One also needs to use protective clothing to avoid getting in skin contact with the oil — and protective clothing means oil- and waterproof gloves and oil- and waterproof clothes that cover at least the front of one’s body, as well as strong rubber boots The same safety precautions,

in principle, apply to people who risk coming into contact with lingering oil on beaches — one should always avoid touching it, and in an acute phase one should

be careful not to inhale vapors from oil slicks (11)

1.2 Legal basis

1.2.1 International conventions

TABLE 1: International Conventions

Convention Objective

1 CLC PROT 1992 / Protocol

of 1992 to amend International Convention on

Civil Liability for Oil

2 OPRC 1990, International

Convention on Oil Pollution

Prevention, Response and

Cooperation

This convention makes provision for contingency plans for ships, offshore platforms, coastal terminals and ports, and for the development of national response

plan

It also encourages the development of international cooperation in spill preparedness and response

3 MARPOL 73/78,

International Convention for

the Protection of Pollution

from Ships 1973 as modified

by the Protocol 1978

It sets out a wide range of procedures and ships design and operating requirements aimed at reducing pollution of the sea from ships - Annex 1 deals with oil pollution

5 Intervention 1969,

International Convention

relating to the intervention on

the high seas in cases of oil

pollution casualties, 1969

This Convention affirms the right of a coastal State to take such measure on the high seas as may be necessary to prevent, mitigate, or eliminate danger to its coastline

or related interest from pollution by oil or the threat thereof, following a maritime

casualty

Source: 7f1709553a71/Oil+Spill+Response+and+Preparedness-eng.pdf?MOD=AJPERES

1.2.2 Vietnamese laws, circular, decree, decision, branch standard

For Vietnam, which currently is in the group of the poorest nations, the first priority is given to the economy However, in parallel to the rapid development, Vietnam is facing a number of environmental issues With the early awareness of such challenges, the Government of Vietnam (GOV) has had a focus on environmental protection, specifically in protection of the marine environment and oil spill response This is shown via legislative documents as follows:

- Circular No 31/2010/TT-BGTVT announcement about the port waters within Haiphong territory, explained more detailed about Haiphong Port Waters definition;

- Law No.23/2004/QH11 dated June 15th 2004 of the Constitution of Socialist Republic of Vietnam on inland waterway navigation;

- Environmental protection law No: 52/2005/QH11 dated November 29th

2005 of the Constitution of Socialist Republic of Vietnam;

- Vietnam Maritime Code No: 40/2005/QH11 dated June 14th 2005 of the Constitution of Socialist Republic of Vietnam;

- Law No 18/2012/QH13 dated June 21, 2012 of the National Assembly on Vietnamese sea;

- Law No 27/2001/QH10 of June 29th 2001 on Fire Prevention and Fighting;

- Law No.10/2008/QH12 of June 3rd 2008, amending and supplementing a number of article of the Petroleum Law;

- Decree of Government No 25/2009/ND-CP on integrated management of natural resources and environmental protection of the sea and islands;

- Decree of Government No 179/2013/NĐ-CP of November 14th 2013 on the regulations for penalties for violations against environmental protection;

- Decree of Government No.48/2000/NĐ-CP of September 12th 2000 detailing the implementation of the petroleum law;

- Decree of Government No 113/2010/NĐ-CP of December 3rd, 2010, providing for the determination of environmental damage;

- Circular No 2262/TT-MTg of December 29th 1995, issued by MOSTE regulating temporarily for responding to oil spill incident;

- Decree of government No.21/2012/ND-CP of March 21st 2012 on management of seaports and navigable channels;

- Decree of Government No.35/2003/ND-CP of April 4th 2003 detailing the implementation of a number of articles of the Law on fire prevention and fighting;

- Decision of Prime Minister No 41/1999/QĐ-TTg of March 8th 1999, promulgating the regulation on safety control in petroleum activities;

- Decision No 800/QĐ-UBND dated May 7th 2009 of Haiphong People’s Committee on issuing regulations on organizing and operating the department of flood and storm prevention and searching and rescue;

- Letter No 69/CV-UB dated 31/5/2005 by National Searching and Rescue Committee on guiding to establish and update Oil Spill Response Plan and ESI Map for coastal provinces and cities;

- Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response;

- Decision of Haiphong People’s Committee No.587/QĐ-UBND dated March 13th, 2014 on building up plans for oil spill response in some places in Haiphong city;

- Decree No 80 /2006/ND-CP detailing and guiding the implementation of a number of articles of the Law on environmental Protection;

- Decree of government No 07/2005/QĐ-BGTVT dated January 7th 2005 on the regulations for managing port operation, including regulations for banning means of transportation, vessels from discharging garbage, dirty sewage, other toxic substance;

- Decision No 50/2006 QD-BGTVT of December 28, 2006, Promulgating Branch Standard 22 TCN 264-06 Regulations on Prevention of Pollution Caused by Inland Waterway Means of Transport;

- Branch Standard 22 TCN 264-2000 includes rules and regulations for prevention of pollution from River-going ships;

- Branch Standard 22 TCN 281-01 consists of rules and regulations for construction and classification of dangerous chemical small Steel bulk Carrier

However, among all of these, preparedness and response activities for source oil spill are given clearly in Decision No 02/2013/QĐ-TTgdated January

ship-14, 2013 of the Prime Minister to promulgate the regulation on oil spill response Some definitions and the contents of preparedness and response are presented more detailed as following:

a) Preparedness and response

 Preparedness:

- The development, appraisal and approval of Oil Spill Contingency Plan (OSCP) at Tier 1, Tier 2, Tier 3, Provincial People’s Committee approves OSCP at Tier 1, Vietnam National Committee for Search and Rescue approves OSCP at Tier

2 and Prime Minister approves OSCP at Tier 3

- Oil spill response capacity building: organizations that may cause oil spill incident have to make investment of oil spill response equipment or to sign oil spill response service contract with service providers or oil spill response regional centers

- Regular training and exercise: Provincial People’s Committee is responsible for conducting regular training course on oil spill response for provincial environmental officers and persons in charge of oil spill response from companies that may cause oil spill incident; regional centers are responsible for organizing training on oil spill response according to training plan approved by Vietnam National Committee for Search and Rescue; Vietnam National Committee for Search and Rescue is responsible for conducting national oil spill response exercise (12)

 Response:

Oil spill response: Oil spill notification and report in oil spill response Oil spill response at Tier 1, Tier 2, and Tier 3: the polluter is responsible for mobilizing resources to combat oil spill If the spill exceeds the response capacity of the polluter, the provincial People’s Committee is responsible for spill response, mobilizing response resources of regional center and other organizations based in the province to deal with the spill In case the province is not capable of combating the spill, the provincial People’s Committee will report to the Vietnam National Committee for Search and Rescue for direction and cooperation with relevant agencies in organizing the response If the oil spill goes beyond the response of domestic resources, the Vietnam National Committee for Search and Rescue shall propose the Prime Minister to consider and decide on the request for international assistance (13)

b) Oil Spill Classification

Pursuant to the Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response, in chapter I, article 6, the size of a spillage is grouped into three levels as following:

- Level 1: Minor oil spill: is an oil spill which has total amount of spilled oil under 20 tones

- Level 2: Medium oil spill: is an oil spill which has total amount of spilled oil from 20 to 500 tones

- Level 3: Major oil spill: is an oil spill which has total amount of spilled oil over 500 tones

The classification of 3 levels of oil spill incidents helps to build up oil spill contingency plan, determine the level of equipment investment, resources, personnel in order to prepare and response timely toward each tiered- response (14)

c) Concept of Tiered Response

Pursuant to the Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response, in chapter I, article 5, it states that National Oil Spill Response System is divided into 3 tiers: Tier 1, Tier 2, Tier 3 with specific responsibilities, corresponding to 3 resources: governmental, provincial and private industry resources

 The oil spill preparedness and response is divided into three tiers: Tier 1, Tier 2, and Tier 3:

- Tier 1 response: Grassroots spills

 Ship-source oil spill at sea:

Pursuant to the Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response, in chapter 3, article 14- oil spill response due to ship-source oil spill at sea, it states that: When ship-source oil spill occurs, ship must carry out immediately methods of treating oil spills in accordance with the oil spill contingency plan to mitigate the amount of oil spilled into environment, and must report instantly to the local authorities as pointed out in Article 12

In the case of that oil spill arising from shipping accidents (collision, shipwreck, and grounding), oil spill response must be carried out as following:

- The regional oil spill response center (in Haiphong: Northern Oil Spill Response Center – the 128 one member limited Liabilities Company) has to implement service contract as required by captain, ship-owner or agent of ship-owner In addition, it also must have responsibility of co-operating with the Department of Flood and Storm prevention and searching and rescue of City and People’s Committee of City

- The commander in this case will have to enough oil spill response experience and capability and will be appointed by the competent authority

In the case of that oil spill is caused by many vessels, vessels must operate to deal with consequences together and comply with guidance of Port Authority and on-scene commander

co-If oil spill happens on the large scale, the commander has to report to the Vietnam National Search and Rescue Committee to supervise oil spilled by radar, helicopter …

 Ship-source oil spill in or near ports (close to shore)

Ship-source oil spill in or near ports means that oil spill arising from operational accidents such as those that might occur during loading, discharging and bunkering or from shipping accidents like ship collision with wharf, or ship collision with each other near or at port

Pursuant to the Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response, in chapter 3, article 16- oil spill response in or near ports It states that:

Inland ports involve in many activities such as exporting, importing, using oil and oil products Therefore, such ports have to build up, and implement plans for oil spill response and sign the service contract with Northern Oil Spill Response Center or other oil spill response companies when oil spill take place If oil spill incidents are beyond the capabilities of inland ports, they have to contact with oil spill response companies that signed service contract in advance and Provincial People’s Committee for being supported in case of need; this circumstance is called

“Provincial spills”

The Port authority has to co-operate with stakeholders to supervise and evaluate oil spill response effectively If port’s oil spill response is not effect or oil spill incidents could pose a significant potential for adverse consequences, the port authority must report immediately to the Local People’s Committee in order to direct oil spill response

In case of need, the Port authority is able to keep recycling oil temporary after collecting them and preserve them in order to ensure compensation as well as damages for ship- source marine oil spill Handing over such collected oil is based on the compensation agreed and undertaken with the ship-owner If the ship-owner

causes oil spill without setting up compensation funds, the Director of the Port Authority, Authorized Parties, Response Forces are entitled to sue these ones for damages for the sake of compensating cleanup costs and other losses for oil spills

Oil spill response at naval ports and inland ports are applied to above regulations With regard to naval vessels, government-owned ships, which cause oil spills, are not applied above regulations including: keeping recycling oil temporary after collecting them or put in a claim for damages as mentioned cases (15)

- Tier 2 response: Regional Spills

If oil spill extends capabilities of tier 1 response or oil spill occurs with unclear reasons and oil drifts out to seashore of other provinces, they are called

“Tier 2 response: Regional Spills”

Vietnam territory is divided into 3 regions for oil spill response:

The Northern region: it covers all the northern provinces and cities southward to the end of Quang Binh province; the entire sea area in Tonkin Gulf within the scope of coping with oil spill incidents stretching to parallel 17◦10’N

The Central region: it covers all the provinces and cities of the Central Vietnam from Quang Tri province to Ninh Thuan province’s southernmost point; the entire sea area within the scope of coping with oil spill incidents from parallel 17◦10’N to 11◦20’N

The Southern region: it covers all the southern provinces and cities from Binh Thuan province to Ca Mau and Kien Giang provinces’ southernmost points; the entire sea area from parallel 11◦20’N, stretching southward, to the southern limit

of this national plan’s scope of coping with oil spill incidents

Each region has to establish a regional oil spill response center; the regional response center organization is regulated below:

The Provincial People’s Committee, where takes place oil spill, has to be responsible for taking the leading role in order to organize oil spill response according to the Regional Emergency Plan Based on oil spill situation, the Provincial People’s Committee urgently commands and supplies necessary resources of departments, ministries, branches to respond timely If oil spill

incidents spread out other provinces, the Provincial People’s Committee, in which happens oil spill incident, must take initiative in reporting the Provincial People’s Committee, which is able to be affected by oil spill, for oil spill response cooperation, as well as the National Search and Rescue Committee for preparedness

of supportive projects in case of need (16)

Three response forces in three regions:

- Navy No.128 Company (FOR THE NORTH)

Assigned temporarily to respond to oil spill incident in the north

Main working area: Haiphong port, Ha Long Bay

Personnel: a small response team (90 personnel)

Experiences: 2 years with real incidents

- Autumn River Company (FOR THE CENTRE)

Officially launches its operations as a NORC in 2003

Main working area: Da Nang Port, Nha Trang and Vung Ro Bay

Personnel: 10-15 persons

Experiences: 2 years with real incidents

- PV Drilling: ( FOR THE SOUTH)

Assigned temporarily to respond to oil spill incident in the South

Main working area: all oil fields in Vietnam territory and oil transfer area on rivers in Vung Tau, Ho Chi Minh, Dong Nai…

Equipment: diverse and enough to cope with a spill (booms, skimmers, tanks, chemicals, bio-degradable adsorbent, auxiliaries)

Experience: since 1994, carry out such exercise (6-10 times/ year) and respond to real incidents (17)

- Tier 3 response: National Spills

National Spills: This will cover major incidents, the scale and scope of which

is beyond the capabilities of the Tier 2 response

In such case, National Search and Rescue Committee guides directly oil spill response in accordance with National Emergency Plan Moreover, the responsibilities of National Search and Rescue Committee are:

- Directs and co-ordinates national centers;

- Reports to the Government the result of response operations

National Oil Spill Response centers have to:

- Conduct directly the response operations;

- Co-ordinate and control directly with response teams from other resources attending to the response operations;

- Report response results to the National Search and Rescue Committee;

- Contact to international cooperating operations if oil spill incidents exceed the capabilities of national force

Response teams of the National Oil Spill Response Center take charge of preparing and arranging equipment, personnel, and vehicles to carry out response operations (18)

 Note: Nonetheless, This paper only researches on Tier 1 response: Provincial spills (means ports, vessels, or petrol companies cannot respond oil spill

by itself)

d) Oil Spill Contingency Plan

The Oil Spill Contingency Plan has to be built up in advance with the purpose of minimizing the potential effects on marine and shoreline environments that could result from a marine oil spill

The OSCP ought to illustrate responsibilities, duties and relationship between organizations, agencies, other stakeholders in oil spill response operations

It also must show spill scenarios, oil spill response organization along with response

technologies, equipment, personnel, vehicles and finance in order to handle effectively oil spill as soon as possible (19)

Relating to organizations which must have OSCP, according to legal requirements, in Vietnam there are 28 coastal provinces and each with its own contingency plan The Local authorities are responsible for dealing with acute spills that may occur within the province and exceed the response capacity of private industry Moreover, There are also other organizations who are obligatory to have oil spill contingency plan, these includes oil companies who carry out offshore drilling campaign, refineries, ports, oil tankers, ships, companies trading refined oil, thermal power plants, or companies who uses the large amount of oil in production activity such as Dai Hai Oil and Gas Limited Liability Company, DAP VINACHEM Joint Stock Company, Trading and Transport Materials Import Export Join Stock Company, 19-9 Join Stock Company, Haiphong Cement Packing Joint Stock Company, Haiphong Thermal Power Joint Stock These organizations also have to sign service contracts with oil spill response service providers or to procure adequate equipment with well-trained personnel capable of operating the equipment (20)

Regarding the content of OSCP, pursuant to the Decision No UBND dated May 13th, 2014 of Haiphong People’s Committee 2014 on building up plans for oil spill response in some companies in Haiphong City, it points out that OSCP must include in 8 chapters:

587/QĐ-Chapter 1: The general issue

Chapter 2:Economic conditions, Social economic, Ecological environment Chapter 3: The location of production activities, oil spill sources

Chapter 4: Means of transport, oil spill response equipment, response personnel

Chapter 5: Oil spill response organizational structure, responsibilities of stakeholders in oil spill response

Chapter 6: Oil spill response process

Chapter 7: Compensation

Chapter 8: Training, drills, investing oil spill response equipment

A formal OSCP will must be approved by People’s Committee of City according to the Decision No 587/QĐ-UBND To understand deeply about OSCP,

a sample of OSCP of Vietnam Maritime Safety Company – North (Wharf 22B) is illustrated clearly in Annex15

2.1 Introduction of Sea and Island Branch

2.1.1 Geographical location & History

Sea and Island Branch is located at 195 Van Cao Street, Hai An District, Haiphong City It was established on June 27th 2011 according to the Decision No 968/QĐ-UBND of People’s Committee of Haiphong City

2.1.2 Position &Function and Duties & Powers of Sea and Island Branch

a) Position and Function

Pursuant to Decision No 176/QĐ-STN&MT dated July 16th

2015 of Department of Natural Resource and Environment issuing regulations on function, duties, powers and organizational structure of Sea and Island Branch, in article 1,prescribes position and function of Sea and Island Branch: Sea and Island Branch is under directly Department of Natural Resource and Environment, being an organ of the Government which has the function to assist the Director of Department of Natural Resource and Environment advising the People’s Committee of Haiphong City on hydrometeorology, climate change, management on sea and island The Sea and Island Branch is a unit of legal person status, be used own seals, be opened

account at the State Treasury

b) Duties and Powers

Duties and Powers of Sea and Island Branch is mentioned particularly in article 2, decision No 176/QĐ-STN&MT dated July 16th 2015 of Department of Natural Resource and Environment issuing regulations on function, duties, powers and organizational structure of Sea and Island Branch However, in preparedness and response for ship-source oil spill, they will:

 Preparedness:

Some major activities are given as following:

- Organizes training course on oil spill response;

- Co-ordinates with oil spill response company to conduct oil spill drills;

- Issues certificates of participating in the training course on oil spill response;

- Provides advices on building up Oil spill contingency plan of Haiphong City;

- Inspects oil spill response preparedness of organizations which are obligatory

to have OSCP in Haiphong

- Convenes stakeholders to examine oil spill response costs;

- Makes procedures

2.1.3 Organizational structure of Sea and Island Branch

Figure 1: Organizational Structure Diagram of Sea and Island Branch

Source: Sea and Island Branch

Manager Nguyen Van Can

Nguye

Deputy Manager Pham Van Lang

Sea and Island

Division

Administrative Division

Climate Change Division

2.1.4 Personnel

Currently, Sea and Island Branch has 14 civil servants including 5 females and 9 males Among them, there are 10 people who are the regular member of Sea and Island Branch; 5 masters and 9 bachelors

2.2 Haiphong Port Waters

Pursuant to Vietnam Maritime Code No: 40/2005/QH11 dated 14June 2005

of the National Assembly, in Chapter IV- Seaports- Article 59, shown in annex 18, Port waters is defined: being a delimited water area for the establishment of waters

in front of wharves, area for vessels’ maneuvers, area for anchorage, area for lighterage, storm-shelter area, area for embarkment and disembarkment of pilots, quarantine area, area for fairways, and other aids

2.3 Overview oil spill situation

2.3.1 International oil spill situation

Each year, there are thousands of oil and chemical spills in the world The size of a spillage is grouped into three categories: less than 7 tonnes; 7-700 tonnes; and more than 700 tonnes of oil spilled In general, the majority of incidents belonged to the smallest category of spillages and the number of large (>700 tonnes) oil spills caused by tankers according to the International Tanker Owners

Pollution Federation (ITOPF) (21) Nonetheless, this study only shows the data on

the number of large spills (>700 tonnes) from 1970 to 2014 in the world in the following Figure 2:

FIGURE 2: Number of large spills (>700tonnes) between 1970 and 2014 in

the world

 Following page:

Source: ITOPF

Overall, in the world, the number of oil spills, followed a downward trend over the past four decades Specifically, in the first nine years, there were 24.5 spills per year on average and the highest figure was recorded in the year of 1979 with nearly 33 incidents It is clear that, that period was seen to be the most terrible one

as compared with the whole period and a well-known disaster can be pointed out here was the major oil spill occurring on July in 1979 near Trinidad and Tobago caused by the Atlantic Empress The spill allegedly resulted in the largest oil spill of 287,000 metric tonnes of crude oil ever to be recorded (22)

Over the next ten years, only 9.4 spills per year on average occurred in the world Nonetheless, at that time, there was a large oil spill called Exxon Valdez Oil Spill taking place on March 24th, 1989 Particularly, the tanker Exxon Valdez grounded on Bligh Reef in Alaska’s Prince William Sound, rupturing its hull and spilling nearly 11 million gallons of Prudhoe Bay crude oil into a remote, scenic, and biologically productive body of water. (23)

Subsequently, the figures decreased gradually with less than 1.7 spills over the next decade Despite of its, in this phase, a second biggest oil spill in history

namely: Gulf War Oil Spill, spewed an estimated 8 million barrels of oil into the Persian Gulf after Iraqi forces opened valves of oil wells and pipelines as they

retreated from Kuwait in 1991 It spilled approximately 1,360,000 -1,500,000 tons

The oil slick reached a maximum size of 101 miles by 42 miles and was five inches thick (24)

Likewise, there was a twofold decline in the quantity of incidents being approximately 3.4 spills per year on average from 2000 to 2009 With regard to the final period, it witnessed a significant drop in number of spills with just 1.8 spills per year on average Especially, the year of 2012 saw the lowest oil spillage on record so far with no large spill (>700 tonnes) In last year (2014), one large spill (700 tonnes) was recorded Particularly, in January a small tanker sank in the South China Sea loaded with a cargo of approximately 3,000 tonnes of bitumen Four medium spills of various oils, including crude oil, were also recorded, totaling five spills of 7 tonnes and over This figure is still far below the averages for previous decades and is in line with the trend of the last four years (25)

2.3.2 Vietnamese and Haiphong oil spill situation

According to the Institute of Marine Environment and Resources (IMER) and Vietnam Academy of Science and Technology, from 1989 to the present, there have been approximately 100 oil spills occurring with tens or hundreds of tons of oil being spilled into the Vietnamese territory water Moreover, the oil spills arise from a number of different sources ranging from a collision or grounding of vessels carrying crude oil and product in local ports or coastal waters and from breaking down of equipment in the tanker or other vessels (26) Haiphong seaport is considered as a potential place for oil spill due to large scale shipping activities with over 40 small-medium and large-sized ports Until now, the ship-source oil spills happening in Haiphong Port Waters have become less frequent over the last few years but it still occurs mostly with medium oil spills from 20 to 500 tonnes In particular, oil spills from vessels in Haiphong Port Waters in the period of ten years are shown in Table 2 as following:

TABLE 2: List of small-medium-large oil spill accidents in Haiphong Port Waters

from 2004 to 2014

Date and name

of vessel

Outline of accident

Place of accident The amount of oil

Cat Ba Island 150 tonnes DO and

50 tones FO (only collected 65 tonnes of oil)

2 May 14th 2010

Shun-An Xing

Shipwreck

20ᵒ39’48’’N-106ᵒ52’12’’E Hon Dau Island

57,7 tonnes FO and 6,8 tonnes DO, 3 tonnes lubricating oil

Nam Trieu Sea Gate

Near Cua Cam Port, Northern East channel, May Chai province, near to Soft-SCC chemical Company

Hon Bia 200 tonnes including

150 tonnes FO and

50 tonnes DO

Source: Department of Natural Resource and Environment

As can be observed from table 2, it is apparent that until now, there was no major oil spill occurring in Haiphong Port Waters and the most common reasons for oil spill came into ship collision or crashing into hidden rocks; grounding; shipwreck and broken equipment and probably human activities were the major causes leading to oil spills in Haiphong Port Waters Moreover, the majority of

vessels causing oil spill came from the domestic shipping companies such as My Dinh or Minh Tuan 68 vessels whereas only two of six ships originated from foreign ones Besides, there was only one incident taking place near port being Cua Cam port while other ones occurred at sea

Consequently, oil pollution at Vietnam Sea has been placed on full alert, especially at costal area:

TABLE 3: Oil concentration of Vietnamese ports

Oil

concentration

(mg/l)

Source: VFEJ VN – Vietnam Environment Forum – 2014

As can be seen from table 3, oil content of Vietnamese seawater went beyond permitted limit from 4-70 times according to QCVN 10:2008/BTNMT-QCVN with coastal seawater while oil content has to be smaller than 0.1 mg/l Particularly, the largest amount of oil content belonged to Vietsopetro port with 7.57 mg/l whereas the smallest one was Haiphong port with 0.42 mg/l However, all ports extended the permitted oil content and this is probably a result of oil spill incidents in the past

2.4 Evaluation of current status of oil spill preparedness and response in Haiphong Port Waters

2.4.1 Oil Spill Response Organizational Structure in Haiphong

Pursuant to the Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response, ship-source oil spill response is pointed out clearly in Tier 1(presented in Chapter 1) More particularly, the oil spill response organizational structure in Haiphong in the case

of provincial spills (co-operation between the company and stakeholders) is illustrated clearly in following diagram:

FIGURE 3: Oil Spill Response Organizational Structure < Following page>

Source: Department of Natural Resource and Environment of Haiphong city

OIL SPILL

Detector, identifying oil spill, speak loudly “OIL SPILL” by megaphone, alert gong, or phone

Report to:

Oil spill response command board Oil spill response team

Report to stakeholders: -Maritime Administration

of Haiphong

- People’s Committee of Haiphong City

- Northern Oil Spill Response Center

- Department of Natural Resource and

Environment

- Fire Prevention, Fighting and Rescue Police Department

- Department of Environmental Protection Police

-Sea Police Department

- Haiphong City Department of Health

Carry out oil spill response operations:

Prevent oil from spreading out; Rescue and Salvage;

Fire Prevention and Fighting; Boom Deployment and Oil Skimming; Environmental Cleanup; Spot Report Making; Regular report on oil spill response

Compensation & Calculating oil spill cleanup

costs

Environmental impact assessment

Complete Oil Spill Response

Assessing incident (128 one member limited liability Company &

Department of Flood and Storm prevention and searching and rescue)

Predictions of movement

of spilled oil Identifying sensitive zones

Evaluating response resources

 Note: Sensitive zone: areas can be affected immensely by oil spill

such as fishing area, tourist sites, salt production areas, marine sanc- tuaries and unique habitats, especially those that are home to endangered species

2.4.2 Responsibilities of stakeholders in Oil Spill Response Organizational Structure

2.4.2.1 Responsibilities of Oil Spill Response Command Board

- Inspects actually again oil spill incidents whether it occurs or not;

- Proposes fast oil spill response approaches;

- Organizes fast oil spill response forces;

- Reports to the General Director, divisions of company, and local authorities;

- Assesses response operations, current response techniques and suggest to add resources;

- Solves problems concerning with Local authorities, Communication media;

- Guides specialized knowledge and settles issues involving in legislation;

- Leads to handle compensation

2.4.2.2 Responsibilities of commander on the spot

- On-site commander is the person who commands directly oil spill response operations, co-operates with the oil spill response team leader in order to minimize damages as well as comply with general techniques given by oil spill response command board

- Leads directly oil spill response team;

- Takes responsibilities of controlling oil spill operations;

- Takes charge of calculating resource demand;

- Assists the oil spill response team leader with oil spill response technology and inspects response effectiveness on the spot;

- Assesses response effectiveness and current oil spill response plan, then proposes supplying resources or changes in oil spill response plan if necessary;

- Builds up plan and suggests solutions for oil collection treatment and to be responsible for seeking for temporary storage;

- Reports to commander of Northern oil spill response center for oil spill situation, current oil spill response when he arrives on the scene;

- Co-operates with the commander of Northern oil spill response center in taking part in response and ensuring necessary conditions if oil spill response is able

to be extent;

- Co-operates with stakeholders in order to complete oil spill response well

2.4.2.3 Responsibilities of Oil Spill Response Team

- Disseminates oil spill situation and assigns duties to members in oil spill response team;

- Prevents immediately oil from spreading;

- Co-ordinates logistic division, deploys rescue force and arranges necessary equipment;

- Ceases activities to ensure safety and isolate all resources which are able

to endanger;

- Commands evacuation of assets and people in case of need;

- Organizes and leads the use of oil spill response equipment;

- Reports regularly to on-site commander for oil spill response effectiveness, especially capabilities of storage of collected oil;

- Organizes shoreline clean-up under technological guidelines offered by environmental counselors

2.4.2.4 Responsibilities of Local Authorities

If the oil spill is beyond capabilities of the company, the company will combine stakeholders to support oil spill response timely

a) People’s Committee of Haiphong City

- Leads specialized agencies to support timely oil spill response

b) Maritime Administration of Haiphong

- Assists command board of the company in responding oil spill;

- Makes records and arrest vessels in case of need;

- Finds root causes of accident and propose competent authorities to handle violations

c) Northern Oil Spill Response Center

- Provides the Command Board with resources, oil spill response equipment;

- Co-ordinates with the company to clean up environment after oil spill response

d) Department of Flood and Storm prevention and searching and rescue of Haiphong City

- Recues injured people in accident, looks for missing ones (if any);

- Protects and prevents oil from spreading to aquaculture zones;

- Support oil spill control

e) Fire Prevention, Fighting and Rescue Police Department

- Salvages and rescues (Rescue people and extinguish burning ships);

- Finding causes of accident

f) Department of Natural Resources and Environment (the sea & island Branch)

- Conducts survey, takes photos, takes water samples to evaluate effects of oil spill on environment;

- Co-ordinates with specialized agencies to carry out environmental impact assessment of oil spill, gathers and inquires economic damages and environmental cleanup after oil spill;

- Convenes stakeholders to examine oil spill response costs;

- Makes procedures

g) Haiphong Border Defense Force

- Assists in rescuing and salvaging;

- Ensures security at area occurring oil spill

h) Department of Water police

- Divides traffic flow;

- Ensures security at the place where happens oil spill;

- Co-ordinates to rescue people, vehicles and assets (if any);

- Makes initial records of oil spill;

- Co-ordinates to handle violations causing oil spill

k) People’s Committee of District

- Organizes security forces;

- Co-ordinates with Department of Natural Resource and Environment on investigating, inspecting and assessing environmental impact of oil spill

l) People’s Committee of Ward

- Organizes security forces;

- Identifies economic damages caused by oil spill

Port Waters

Thanks to establishment, amending and supplementing of laws, decisions, decrees, letters, branch standards undertaken by competent authority especially for the Decision No 02/2013/QĐ-TTgdated January 14, 2013 of the Prime Minister to promulgate the regulation on oil spill response, in general oil spill response preparedness in Haiphong Port Waters has grown better despite existing some drawbacks In particular, an array of activities for oil spill preparation in Haiphong Port Waters, have implemented including building up oil spill contingency plan, conducting oil spill drills, organizing training, being described more detailed as following:

There is no denial that OSCP plays a significant role in developing a suitable spill response capability that is in compliance with the local regulatory framework and commensurate with oil spill risks of an organization or facility A positive sign

is recorded since 2013 that all of vessels belonging to both domestic and international shipping companies operating in Haiphong Port Waters had their own OSCP and signed service contracts with oil spill response companies as illustrated

in table 10- annex 14 according to regular inspection of Maritime Administration of Haiphong Even then, only 29 ports of the total over 40 ports built up OSCP as shown in table 9- annex 13 until now coupled with the fact that the majority of companies, which consume large amount of oil for production activities or involve

in exporting and importing oil, have not built up OSCP and signed service contracts with oil spill response companies as well yet, according to regular inspection of the

Department of Natural Resource and Environment The LAB spill, taking place last year, was a memorable lesson for not only Soft- SCC Chemical Company but also Local authorities on oil spill preparedness and response Two of the main reasons for this LAB spill were that the Soft-SCC Chemical company had not built up OSCP and signed service contract with oil spill response companies, this caused tardy oil spill response and very high oil spill clean-up cost It is apparent that tardy oil spill contingency planning might contribute dramatically to ineffective oil spill response and immediate and long-term impacts caused by oil spill are absolutely inevitable Relating to the content of OSCP of organizations, in chapter six of oil spill response process- in the part of building up spill scenarios, some companies, like the OSCPs of Vietnam Maritime Safety Company- North (Wharf 22B) and Duc Hoa Port (Duc Hoa International Joint Stock Company) as illustrated in annex 16, have not provided predictions of movement of spilled oil for each spill scenarios, that is one of compulsory requirements in building up OSCP Meanwhile, trajectory analyses play a significant role in identifying areas that are most vulnerable to the oil so that equipment to contain the oil spill can be dispatched to where it will be most effective because oil not only causes immediate contamination but also has long-term effects on coastal ecosystem However, PTSC Dinh Vu Port Company is one of brilliant mirrors for detailed OSCPs since it provided more detailed about predictions of movement of spilled oil for each spill scenarios as illustrated in annex

17

Moreover, according to the Decision No 02/2013/QĐ-TTgdated January 14,

2013 of the Prime Minister to promulgate the regulation on oil spill response, Haiphong is building up the oil spill contingency plan of Haiphong City which assists oil spill response at “Provincial spills” in being rapid, effective as well as developing the interpersonal relationships that can mean so much to the smooth functioning of a response Nonetheless, so far this plan has not completed yet, as a result, if oil spill occurs in Haiphong Port Waters in the near future, the response community (stakeholders) is not able to work together in a harmonious way, then the immense impact and damages on the marine environment, social-economic and even human health caused by an oil spill will be not totally avoided

Besides, the spill response training course, is an indispensable part of an array of activities for oil spill preparedness, which equips trainees with theoretical knowledge of oil spill response such as legislative documents, oil spill response organizational structure, boom deployment…With the early awareness of its

importance, three training courses have been organized for organizations which are obligatory to have oil spill contingency plan like ports, domestic shipping companies, petrol companies, and other ones since 2013 Annual such organizations are required to appoint their staffs to participate in the training course on oil spill response being organized by the Department of Natural Resource Environment in conjunction with Marine Spill Response Company After the end of the course, trainees will be issued the certificate of participating in the training course on oil spill response by the Department of Natural Resource and Environment A photo (illustrated in annex 1) expresses clearly a training course on oil spill response, occurring on October 8th, 2015, being organized by Hoa Anh Joint Stock Company and Sea & Island Branch belonging to Department of Natural Resource and Environment, with the participation of ports, petrol companies, domestic shipping companies and other ones in Haiphong City

As being observed directly in this training course happening on October 8th,

2015, it seems that the quality of this course was out of expected, even though many efforts on organizing a well-rounded training course have been chaired by both Sea

& Island Branch and Hoa Anh Joint Stock Company Particularly, in terms of trainees ‘attitude, nearly a half of trainees didn’t pay attention on lessons and talked continually in class and even some leaved off this training course since their most concern of such trainees is to receive the certificate of participating in the training course on oil spill response given by the Department of Natural Resource and Environment Perhaps, organizers also should be partly responsible for low-quality training because the number of trainee was rather crowed (over 100 people) as well

as the lesson planning had not created interests for trainees yet, especially there was

no connection between trainees and lecturers For such reasons, this training course

on oil spill response became ineffective and could not reach its expected goals

In addition, pursuant to the Decision No 02/2013/QĐ-TTgdated January

14th, 2013 of the Prime Minister to promulgate the regulation on oil spill response, it states that the oil spill drill has to happen twice a year However, there have been only three times of organizing oil spill drills in Haiphong since 2013 In these drills, the Department of Natural Resource Environment has combined with Marine Spill Response Companies to conduct exercises which enable response personnel to become knowledgeable and proficient in oil spill response; keep on scene commanders and decision makers in combating oil spill incidents or might help