OSPR Drills and Exercises - Frequently Asked Questions

The Frequently Asked Questions on this page specifically refer to OSPR's Drills and Exercises Unit (D&E) and regulations (14 CCR § 820.1), unless otherwise noted.

(a) Applicability and Definitions

What is the difference between a CalTriVEX and a CoreVEX?

CalTriVEX and CoreVEX apply to vessel plans, only. Once every three years, a vessel plan holder must hold a CalTriVEX to test and successfully achieve all the Tier I objectives described in subsection (c). In the other two years, a CoreVEX must be held, where only the two CoreVEX objectives described in subsection (c)(12)(A) must be tested and successfully achieved.

(b) Type and Frequency of Drills, Exercises, and Additional Notifications

For a contingency plan holder that operates statewide, is it required to meet all the objectives in each region in a three-year period?

No, a statewide contingency plan holder must hold an annual tabletop exercise in the north, central, and south regions of the state within any consecutive three-year period; but, the objectives can be collectively tested and achieved across al three of those exercises. D&E's website contains a link to Plan Holder Resources, including the Rolling 3-year Cycle Handout that describes a consecutive three-year period.

(c) through (e) Tabletop Exercises

(1) Notifications

When does the 30-minute clock start for the Notifications objective?

In an actual spill, the 30-minute clock would start as soon as the spill is discovered; so, for a drill or exercise, the 30-minute clock starts as soon as the scenario has been briefed. The call to the qualified individual (QI) is included in that 30-minute window.

When documenting regulatory notifications can we simply write "see attached notification form" on our ICS 201 page 2?

No, all required notifications need to be documented on the actual ICS 201 page 2 to be eligible for credit.

When notifying the QI, if they are on-site, do you still need to call them?

Yes, an actual telephonic notification needs to be made to the QI and documented on the ICS 201 page 2 to be eligible for credit.

If OSRO and SMT phone numbers are incorrect in the contingency plan, will credit for the Notifications objective be withheld?

No, incorrect OSRO and SMT phone numbers will not negatively affect credit eligibility. The Notifications objective only requires all notifications to be successfully initiated within the 30-minute time frame and documented on the ICS 201 page 2. However, if contact information is incorrect, OSPR's expectation is that information would be updated prior to the subsequent exercise, as described in subsection (l)(4).

(2) Staff Mobilization

Do text messages or emails count as "telephonic notifications" to activate a spill management team (SMT)?

No, an actual telephonic notification means that a phone call needs to be made to at least one member of the SMT and then that person can make further notifications using text messages or emails.This telephonic notification requirement is consistent with the contingency plan regulations.

(3) Incident Command System

Do all exercise players, including contractors and agency participants, need to be represented on the ICS 201 page 3, ICS 203, or ICS 207?

Yes and no. Response personnel from all participating organizations and agencies must be incorporated on the organization chart (ICS 201 page 3 or ICS 207) to achieve the objective requirements and have the ICS form be in compliance with subsection (k)(2). If there are more exercise participants than fit on a single organization chart, then all the participants necessary to complete the ICS form in its entirety must be included.

(3.1) Unified Command

What are some examples of emerging concerns?

Discussing emerging concerns is an opportunity to have a conversation about pertinent, real-world issues that could impact a spill response. Some examples of emerging concerns are COVID-19, security issues, concerns related to the unhoused population, potential flooding, or active construction near the incident.

(4) Safety Officer

For a Tier I exercise, the ICS 208 must be approved by Unified Command (UC); however, for a Tier II exercise, the ICS 208 just needs to be submitted for UC approval. Is submission of the ICS 208 to UC sufficient for the relevant objective credit?

For a Tier I exercise, the ICS 208 must be submitted to and approved by the UC. For a Tier II exercise, the ICS 208 must be submitted to the UC for their approval, but does not need to be approved to be eligible for credit.

(4.1) Safety of the Public

How can I get the contact information for the local Certified Unified Program Agency (CUPA) appropriate for my exercise scenario?

Local CUPAs can be identified by utilizing the Unified Program Regulator Directory.

If a contingency plan covers all three regions of the state, do we need to list all regional air quality management districts and regional water quality control boards for the whole state?

No, the objective requirements is to identify and document other relevant public health agencies, so you only need to identify and document those agencies that are relevant to the exercise scenario.

(6) Liaison Officer

If a plan holder identifies an inaccurate contact from the local Area Contingency Plan (ACP), does that count as a Liaison failure? How will the ACP leads get notified?

Testing contact information in an ACP will not lead to the Liaison Officer objective being ineligible for credit. If a plan holder identifies a wrong number in an ACP and makes the drill coordinator aware of it, then the drill coordinator will reach out to the OSPR ACP Coordinator to make an update.

Is there a minimum number of actual stakeholder calls tat need to be made in order to be eligible for credit for the Liaison Officer objective?

No, but while there is not a minimum number of calls that need to be made in order to be eligible for credit for the Liaison Officer objective, all the types of stakeholders specified in the objective verbiage need to be identified, documented, and contact initiated in some way. This should be treated as an opportunity to truth phone numbers in a low stress environment.

(8) Planning Section

When facilitating an operational planning cycle meeting, does the agenda in the Incident Management Handbook (IMH) need to be addressed in the exact order it is written in?

Per the objective requirements, meetings need to be facilitated following the agendas described in the IMH. For further clarification, reach out to your regional drill coordinator. Regional drill coordinator names and contact information can be found on D&E's website and the first page of the online drill calendar.

(8.1) Situation Unit

What ICS form is recommended for an incident status summary?

An ICS 209-OS (NOAA rev. 06/00) is a commonly utilized incident status summary and satisfies the regulatory requirements as long as it's completed in its entirety

Is an electronic situation status display acceptable or does it need to be a physical situation status display?

An electronic situation status display may be used if all the forms and information required by the regulations is easily accessible to all response personnel and drill coordinators.

(8.2) Resource Unit

What ICS form is recommended for a sign-in sheet?

An ICS 211p-OS (NOAA rev. 06/00) is a commonly utilized sign-in sheet and satisfies the regulatory requirements, as long as it's completed in its entirety and both email addresses and phone numbers are provided as contact information.

Can a plan holder use an Excel spreadsheet instead of the specified ICS 201 page 4 to display resources on the situation status display?

No, the ICS 201 page 4 specified in the regulations must be utilized to be eligible for credit. In addition to utilizing that form, the plan holder may also maintain an Excel sheet to track resources, if preferred.

(8.3) Environmental Unit

Can trajectories be requested through a contractor?

Yes, but there must be a process for response personnel to request those trajectories before they are disseminated. The process to request trajectories should be documented as evidence that the trajectory request process was utilized.

Is there anything specific that needs to be included on trajectories that are inland versus marine?

No, OSPR expects the relevant trajectories to be developed with consideration to the current and forecasted weather, tides, and currents (where tides and currents are applicable) for time frames that are appropriate for the scenario.

(9.3) Response Infrastructure

Is there a minimum internet bandwidth expected? If internet is slow, do we fail the objective?

No, there is no minimum bandwidth expected, but the wireless internet provided must be sufficient to meet the objective requirements of being, "accessible by all response personnel and can support all response activities at the incident command post" to be eligible for credit.

(f) Equipment Deployment Drills

When doing an equipment deployment drill, what does "secured at both ends" mean?

The way boom is secured at both ends depends on the equipment listed in the oil spill contingency plan and the immediate containment strategies plan holder and/or oil spill response organization staff would utilize to effectively deploy the boom. Options for securing the boom include securing to a boat, anchor, dock piling, etc.

Can a Sensitive Site Strategy Evaluation Program (SSSEP) deployment qualify as an equipment deployment drill for an oil spill response organization (OSRO)?

Section 820.1 regulates plan holders and tests their oil spill contingency plan, so SSSEP deployments to not apply towards any regulatory requirements described in Section 820.1. As described in subsection (b)(4), response services are verified through equipment deployment drills pursuant to subsection 819.03(d) which are not managed by the Drills and Exercises Unit. For more information on OSRO ratings and drills, please visit OSPR's OSRO website.

(g) Additional Notifications (formerly "quarterly notifications")

If a plan holder has an actual spill that is not eligible to receive spill credit, could it potentially count toward the Facility Notifications requirement if all the necessary notifications are made and properly documented?

Yes, if the required calls are made to the qualified individual and the rates oil spill response organization within 30 minutes of spill discovery and documented by the plan holder it would count towards the Facility Notifications requirement for that region. The requirements for an actual spill to qualify as a substitute for a drill or exercise are described in subsection (m).

For Facility Notifications for plan holders operating in different regions, how do those need to be documented?

There are no specific documentation requirements for Additional Notifications, including both Facility Notifications and Vessel Notifications. As long as the time stamps and associated control numbers are documented in some way that can be provided to OSPR upon request, then the documentation is in compliance with the regulations.

Can I use a government initiated unannounced exercise (GIUE) for Facility Notifications credit?

Yes, if the required notifications are made and documented then they may be used for Facility notifications credit.

(i) Scheduling (drills and exercises)

If I need to reschedule a drill or exercise, how should I contact the D&E Unit?

Check the online drill calendar for date availability before requesting a new date. You can cancel the originally scheduled event and submit a DFW 1954 Notification Form for the new event by emailing osprdrills@wildlife.ca.gov. The online drill calendar can be found on D&E's website which also contains a link to the Regulatory Forms, ICS Forms, and Job Aids page that contains the DFW 1954 form.

The regulations say that a maximum of two drills and two exercises per week per region can be scheduled, so if there is no equipment deployment drill scheduled for a given week, could four exercises be scheduled?

No, the limitation of scheduling a maximum of two drills and two exercises per week per region ensures OSPR's workload is distributed in a way that supports the proper staffing coverage needed to design, travel, evaluate, and process credit requests throughout the course of the year.

Are there date limitations when scheduling a CoreVEX?

No, as described in subsection (l)(2)(C), CoreVEX do not have any scheduling limitations because OSPR staff will not be in attendance. CoreVEX do, however, require a DFW 1954 Notification Form be submitted to osprdrills@wildlife.ca.gov to inform D&E of the exercise. D&E's website contains a link to the Regulatory Forms, ICS Forms, and Job Aids web page that contains the DFW 1954 form.

(j) Design (includes planning meetings)

Do all drills and exercises require a planning meeting prior to the event?

Yes, the plan holder is responsible for reaching out to the appropriate drill coordinator to plan and discuss exercise design, scope, and staffing needs prior to the drill or exercise. If you are unsure which drill coordinator to reach out to, please email osprdrills@wildlife.ca.gov and ask who your point of contact should be. Planning meetings may consist of a virtual meeting (e.g., MS Teams), phone call, or an in-person meeting.

Do initial notifications need to be witnessed by a drill coordinator?

Notifications may be incorporated into an exercise in different ways, which warrant discussion during the planning meeting(s) required by subsection (j). During this discussion, the drill coordinator may request to witness the initial notifications.

If a plan holder would like to achieve an objective that requires an OSPR participant (i.e., SOSC or LOFR) and an OSPR player is unable to attend, can we still receive credit?

Yes, if it is determined during the planning meeting(s) required by subsection (j) that an OSPR participant is to be invited by the drill coordinator, but they are unable to attend, the plan holder would need to achieve the regulatory requirements for that objective to be eligible for credit. Plan holders should never directly invite OSPR staff to participate, that needs to be handled by the drill coordinator, only.

The regulatory language states that all exercises must meet the Notification objective at every single exercise. Does this preclude a reactive phase exercise from being done one year and then moving to a proactive phase exercise in subsequent years?

No, notifications are required at every exercise, but that does not mean that every exercise must start with the reactive phase. If a plan holder would like to start an exercise with the proactive phase instead of the reactive phase, it is possible to design the exercise so notifications are made prior to exercise kickoff. This is something that should be incorporated into the planning meeting required by subsection (j).

Which operational planning cycle meetings are required during an exercise? Are plan holders expected to produce an Incident Action Plan (IAP) at each exercise?

There are no specific operational planning cycle meetings that are required, so as long as the deliverables described in the objectives are produced, plan holders are allowed flexibility in the scope of the exercise. The completion of an IAP is not required to be eligible for credit for any objective.

(k) Documentation

Where can I find the correct versions of the ICS forms required for use at exercises?

D&E's website has a Quick Links section that contains a link to the Regulatory Forms, ICS Forms, and Job Aids web page. This page contains links for the Word and/or Excel versions of each of the approved ICS forms that are required during an exercise. PDF versions of specific ICS forms can be requested by emailing osprdrills@wildlife.ca.gov.

Can I have pre-populated/pre-loaded information on specified ICS forms?

Yes, you may have pre-populated or pre-loaded information on ICS forms if that is part of exercise design; for example, an ICS 201 is populated because the exercise is starting with an ICS 201 Incident Briefing. Any information populated on ICS forms prior to the start of the exercise will not be eligible for credit; although you may include prompts and placeholders for certain information to ensure the information makes it onto the forms.

Are the ICS form versions listed in the regulatory text the only ones accepted?

Yes, the ICS forms that are specifically listed in the regulatory text are required for that objective to be eligible for credit. Form layout cannot be changed, but information can be added to forms in existing blank space as needed.

Can electronic software be utilized during an exercise?

Yes, but the output of the software must match the specified ICS forms required by the regulations to be eligible for credit.

EPA ICS forms that are linked on the D&E website are for revisions older than those stated in 820.1 regulations, will the OSPR site be updated with the correct form versions?

The revision dates on the Word versions of the EPA forms is 02/10 compared to the PDF versions, which have a revision date of 05/18. Since the Word forms are the same as the PDF forms other than the file format, they will be eligible for credit if they are utilized.

(l) Credit

If you do not successfully achieve all required objectives during a CalTriVEX, what happens?

As described in subsection (l)(3), if one or more mandatory objectives were not successfully achieved during a CalTriVEX, a partial credit approval letter and after action report detailing exercise deficiencies will be issued to the plan holder. The plan holder may have a single makeup exercise within 180 calendar days as long as a makeup exercise has not occurred within the previous two calendar years.

(m) Substitution

Can I get drill or exercise credit from the state of California for a federal Government Initiated Unannounced Exercise (GIUE)?

No, the only unannounced events eligible for credit are events with participation from OSPR's Drills and Exercises Unit; these events are considered to be OSPR Initiated Events (OSPRIEs).

(n) Reconsideration

What if we feel we missed credit for an objective we think we should receive credit for?

You may reach out to the drill coordinator that evaluated your drill or exercise to discuss the evaluation, credit decision, and your available options. One such option is making a formal request for reconsideration, which is described in subsection (n).

Regulatory Terminology

What is the difference between "approved by Unified Command" and "for Unified Command approval"?

Developing something "for Unified Command approval" indicates that the product was completed after the Unified Command (UC) was formed and not during the initial response phase and that we expect that product to move through the UC approval process. "Approved by Unified Command" indicates something was developed for UC approval, and was then submitted to, reviewed by, and approved by the UC.

Additional Resources

Where can I find the PowerPoint presentation given by D&E at the regional regulatory workshops held in Spring of 2023?

D&E's website contains a link to Plan Holder Resources, including the Plan Holder Workshop Presentation.

Do you have any resources available that better illustrate the rolling 3-year cycle, the event scheduling process, and the credit approval process?

D&E's website contains a link to Resources, which include the Rolling 3-year Cycle Handout, Scheduling Decision Process, and Credit Approval Process.

Is there a checklist that can be provided to ensure all regulatory requirements are met?

No, but the Section 820.1 objective verbiage describing the specific objective requirements can be used to create your own checklist or used to make it more visually appealing to better fit your needs.

Additional Questions?

Additional Questions?

If you have a question that was not answered here, please send an email to osprdrills@wildlife.ca.gov.


Jennifer Linander
Email: Jennifer.Linander@wildlife.ca.gov
Phone: (916) 580-9781

Office of Spill Prevention and Response
Mailing: P.O. Box 944209, Sacramento, CA 94244-2090
(916) 375-8580 for OSPR Information

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