COFR Solutions

COFR Guarantees
FAQs

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 100 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 excluded vessel types 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?

Hawaii
American Samoa
Baker Island
Guam
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 for vessels carrying hazardous substances as cargo are the greater of $5,000,000 or $300 per gross ton. Current OPA90 Limits are as shown in the table below, as amended, to reflect the increase in the Consumer Price Index since they were last adjusted in 2019. The new rates as at 23rd March 2023 are shown for your ease of reference, these rates reflect the recent Consumer Price Index adjustment announced by the final rule of the USCG on the 23rd December 2023.

Vessel Type	Rule	Current OPA 90	With CPI Increase
Double hull tanker	Base amount	$2,300 per GT	$2,500 per GT
	Minimum liability if 3,000GT or less	$4,985,900	$5,380,300
	Minimum liability if greater than 3,000GT	$19,943,400	$21,520,000
Single hull tanker including double bottom and double sided	Base amount	$3,700 per GT	$4,000 per GT
	Minimum liability if 3,000GT or less	$7,478,800	$8,070,400
	Minimum liability if greater than 3,000GT	$27,422,200	$29,591,300
Non tank vessel	Base amount	$1,200 per GT	$1,300 per GT
Non tank vessel	Minimum liability all non tank vessels	$997,100	$1,076,000

NOTE: *CERCLA limits remain unchanged basis additional $5,000,000 or $300 per GT whichever is the greater, if a vessel is carrying hazardous substances as cargo.

Which are approved P & I Clubs?

1. American Steamship
2. Brittania
3. Gard
4. Japan Shipowners
5. London Steamship
6. NorthStandard
7. Shipowners
8. Skuld
9. Steamship
10. Swedish Club
11. UK Mutual
12. 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
12. Amlin

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?

Each MISL voyage is defined as the entry into the US EEZ for a period of up to 30 days. The voyage will terminate on the earlier of expiry of the 30 day period or departure from the EEZ. On expiry of the 30 day period, in the event that the vessel is still in the US EEZ, a new voyage will be deemed to commence. The number of ports visited within the 30 day period is not pertinent for the purposes of this definition.

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
XHVI-8
GTL XHVI
380 CST

A full listing of cargo types can be found here

Policyholder Dividend Program?

See our FAQ on the Program.