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Web alert: California – Amendment to Regulations Relating to California Certificates of Financial Responsibility [COFR] Requirements
News & Insights 22 January 2015
Members with vessels calling at Californian ports should note the change in requirements.
Members should note that the California (CA) Office of Spill Prevention and Response (OSPR) has recently amended the relevant provisions in the CA Code of Regulations (CCR) on evidence of financial security required for CA Certificates of Financial Responsibility (COFRs).
The previous stated requirement was that, on renewal of P&I coverage, vessel operators must submit a copy of their new Certificate of Entry (COE) within 45 days of expiration of the previous certificate. Within the section relating to evidence of insurance by means of entry in a P&I Club there was no reference to any additional provisions relating to renewal of P&I cover. There was a provision for evidence of financial security to be provided 10 days before operating in Californian waters but that appeared to be in the context of applications for new or renewed CA COFRs.
The new regulations now specifically state within this section that, where P&I coverage has expired, the operator must submit a copy of the new COE at least 10 calendar days before operating in Californian waters.
All P&I Clubs in the International Group have expressed strong concerns to CA OSPR, since the 10 day requirement wrongly assumes that all owners complete their renewal negotiations and will be in possession of their new COE well in advance of 20 February. However, CA OSPR has maintained this requirement in the amendments to the CCR.
Members with vessels calling at Californian ports on or around 20 February on this and subsequent years are therefore recommended to renew their P&I cover for the following policy year well in advance of this date in order to ensure that the new COE can be issued and submitted to CA OSPR in compliance with the regulations.
The full text of the regulations can be viewed here.
Members should contact the Managers should they have any queries regarding the above.