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COFR Guarantees

What is a COFR?
COFR is a vessel Certificate of Financial Responsibility (Water Pollution) issued by the National Pollution Fund Centre (NPFC) of the United States Coast Guard to a vessel applicant providing evidence of financial responsibility, in accordance with the Oil Pollution Act of 1990 (OPA 90) and CERCLA. The Coast Guard have transitioned to a paperless COFR, which is an electronic record accessible on their website when the COFR is issued. Operators will no longer be required to carry a paper COFR aboard the vessel. COFR validity will be verified electronically.
Who needs a COFR?
Vessel operators must have a COFR for vessels over 300 gross tons using the navigable waters of the United States. In addition, any vessel, REGARDLESS OF TONNAGE, that is LIGHTERING or TRANSSHIPPING oil in the Exclusive Economic Zone (EEZ) of the United States, must have a COFR. The only exceptions to this rule are public vessels and non-self propelled barges that do not carry oil as fuel or cargo, and do not carry hazardous substances as cargo. These two types of vessels do not require a COFR.
How long can an operator be inactive with the USCG before it's considered to be new?
90 days.
What documentation is required from the P & I Clubs for MISL to bind a new vessel?
MISL cannot bind a vessel without having received the 3 standard letters from the P&I Club: COFR COE, COFR Indemnity and COFR Undertaking (the only exception to this is Britannia who issue a one page confirmation). The named Operator on these letters should match the legal name of the operator as per the Vessel application.
What exactly is a bridging letter?
A letter whereby the Owner of the vessel(s) gives the bareboat charter permission to operate the vessel(s).
Which US Territories outside of the contiguous U.S.A. require COFRS?
American Samoa
Baker Island
Howard Island
Jarvis Island
Johnston Atoll
Kingman Reef
Midway Atoll
Northern Marianas
Palmyra Atol
Puerto Rico
Wake Atol
US Virgin Islands

NOTE: The Marshalls Islands are a US trust territory and not subject to OPA 90 as the US Federal Government does not have Constitutional authority over the Marshall Islands.
What are the COFR Limits (OPA90 and CERCLA)
The limits under CERCLA are the greater of $5,000,000 or $300 per gross ton. OPA90 Limits are as shown in the table below, reflecting the December 2015 Consumer Price Index adjustment.
Vessel TypeRuleOPA 90
Double hull tankerBase amount$2,200 per GT
Minimum liability if 3,000GT or less$4,699,200
Minimum liability if greater than 3,000GT$18,796,000
Single hull tanker
including double bottom and double sided
Base amount$3,500 per GT
Minimum liability if 3,000GT or less$7,048,800
Minimum liability if greater than 3,000GT$25,845,600
Non tank vesselBase amount$1,100 per GT
Minimum liability all non tank vessels$939,800
NOTE: OPA90 Limits may be subject to future periodic Consumer Price Index adjustments such as the December 2015 increase.
Which are approved P & I Clubs?
1. American Steamship
2. Brittania
3. Gard
4. Japan Shipowners
5. London Steamship
6. North of England
7. Shipowners
8. Skuld
9. Standard Steamship
10. Steamship
11. Swedish Club
12. UK Mutual
13. West of England

Following non-IGA P & I clubs approved by the reinsurers of Maritime Insurance Solutions: 

1. Noord Nederlansche P & I (NNPC)
2. British Marine
3. Hanseatic Pandi
4. Korea P & I
5. Hydor AS
6. Mitsui Sumitomo Insurance Co. Ltd.
7. Osprey – Thomas Miller Specialty
8. Försäkringsaktiebolaget Alandia (Alandia Marine)
9. Carina P & I
10. Norwegian Hull Club
11. EF Marine
Which are the International Association of Classification Societies?
The members of IACS are:
1. American Bureau (ABS)
2. Bureau Veritas (BV)
3. China Classification (CCS)
4. Germanischer Lloyd (GL)
5. Indian Register (IRS)
6. Korean Register (KR)
7. Lloyds Register (LR)
8. Nippon Kaiji Kyokai (NK)
9. Der Norske Veritas (NK)
10. Registrano Italiano (RINA)
11. Russian Register (RS)
12. Polish Register (PRS)
13. Croation Register (CRS)
How is a Voyage Defined?
A voyage is defined as "each movement carrying cargo to or from any port or place in or involving transfer of such cargo at a place within United States Waters, and/or the EEZ as defined in the Oil Pollution Act of 1990 (OPA 90) and the relevant Presidential Proclamation. Even if a part cargo is loaded, discharged, or transferred within the EEZ, it will be considered a voyage. However the loading, discharging, or transferring of the same cargo in ports or at multiple ports will not be treated as multiple voyages." Notwithstanding the above, the voyage is deemed to attach upon the vessel's entry into U.S. Waters/EEZ and to terminate on the earlier of the vessel's departure from U.S. Waters/EEZ or the expiry of 30 days from the time and date of entry. Should the vessel remain in U.S. Waters/EEZ beyond the 30th day, a new voyage will be deemed to attach and will terminate on the earlier of the vessel's departure from U.S. Waters/EEZ or the expiry of 30 days from the time and date of reattachment and so forth.

Any vessel that discharges at LOOP and then proceeds into port(s) is not considered to have performed a LOOP voyage.

A vessel can go into US waters for 30 days and call multiple ports for loading/discharging and that is ONE call. If the vessel stays beyond 30 days, a second voyage is deemed ommenced and if it is still continuously in US waters for another 30 days, a third is deemed commenced and so on until it eventually leaves US waters.
What are the USCG Vessel Type Classifications?
10 Breakbulk freighter
11 Containership
12 Roll on-roll off
13 Barge carrier (e.g. lash, seabee)
14 Combination breakbulk containership
15 Combination roll on-roll off containership
16 Combination barge carrier containership
17 Tanker
18 Dry bulk carrier
19 All other self-propelled cargo vessels
20 Oil/bulk/ore carrier (OBO)
30 Passenger vessel31 Combination passenger/cargo vessel
32 Ferry
40 All types of pleasure craft
50 Tank barge
51 Tug and towboat
52 Barge and Scow
53 Drilling Rig
54 Fishing vessel
55 Factory vessel
56 Research vessel
57 All other utility craft
60 Vessels not otherwise specified
What constitutes Dirty (PERsistent) Cargo?
Dirty cargo types are

Fuel Oil
Base Oil
GTL Base Oil
380 CST

A full listing of cargo types can be found here
Policyholder Dividend Program?
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