US Pollution NRC and MSRC – MSRC Addendum Concerning Use of Dispersants 31 August 2011 No.11-010 Tank vessel owners Members will be aware that United States Coast Guard regulations now require vessel response plans for tank vessels to include an oil spill response organisation ("OSRO") capable of applying dispersants by air as part of a clean up operation. Pending finalisation of the implementation of these regulations both main OSROs - National Response Corporation (NRC) and Marine Spill Response Corporation (MSRC) - received permission to have their customers' plans continue without a dispersant capability until 21 August 2011. This period has now been extended to 30 September 2011. From this date operators of tank vessels must cite an OSRO with dispersant capability in their plans. Both MSRC and NRC confirm that they now have dispersant capability in all areas of the United States (US) with the exception of Hawaii where it will be necessary to cite Clean Islands Council in addition to either NRC or MSRC. On 10 August 2011, MSRC notified its customers of an amendment to its service agreement to include a "dispersant addendum". This addendum introduced liabilities on the vessel owner which fell outside the scope of club cover. After discussion with the International Group, MSRC has narrowed the scope of the addendum to only apply when there is an event involving dispersants. On 22 August 2011, MSRC sent a message to its customers requiring them to sign and return the revised Addendum by 9 September. Unfortunately the additional liabilities introduced still mean that the MSRC service agreement no longer conforms with International Group US vessel response plan guidelines (US VRP guidelines) because the liabilities are not reciprocal and the contract requires the owner to waive the right to limit in certain circumstances. (For the guidelines see Circular  No.09-002   of 22 June 2009.) Additional cover has been arranged in the market. Those owners or operato