MASTERS GUIDE TO COMPLIANCE IN US WATERS

24-Hour Emergency Assistance +1 985 781 0804

2012

!!! WARNING !!! This is a practical guide for Masters to assist in compliance with US laws and regulations. It is not an official document and is not required for compliance. It is intended to provide useful direction for Masters. It does not replace any document required by law or regulation. It does not replace direction provided by the ships owner/manager/operator. This guide may be modified as required to be in harmony with policies of the owner/manager/operator. Questions about this guide should be directed to OBriens Response Management Inc. at inquiry@obriensrm.com

Revision 0

Masters Guide to Compliance In US Waters

2012

TABLE OF CONTENTS INTRODUCTION ............................................................................................................ 3 EMERGENCY RESPONSE ............................................................................................ 4 COMMUNICATING WITH OBRIENS ............................................................................ 6 COMPLIANCE ................................................................................................................ 8 ON BOARD DRILLS AND EXERCISES ....................................................................... 11 TESTS BEFORE ENTERING OR GETTING UNDERWAY IN US WATERS ............... 13 NOTICE OF ARRIVAL/DEPARTURE ........................................................................... 13 AVERAGE MOST PROBABLE DISCHARGE (AMPD) COVERAGE ............................ 15 CALIFORNIA INCREASED ON-WATER RESPONSE REQUIREMENTS AND SHORELINE PROTECTION COVERAGE.................................................................... 16 CALIFORNIA EMISSION REDUCTION REGULATIONS ............................................. 18 EPA NPDES VESSEL GENERAL PERMIT (VGP) COMPLIANCE .............................. 19 SUGGESTIONS / COMMENTS / CLARIFICATIONS ................................................... 21

OBriens Response Management Inc.

Masters Guide to Compliance In US Waters

2012

INTRODUCTION The Master of any vessel making a call to the United States faces a number of regulatory issues that are specific to the US. Your vessel is enrolled with OBriens Response Management Inc. (OBriens) to ensure compliance with a number of US federal and state regulations. This guide is intended to help the Master effectively and efficiently face these issues. Use of the directions in the guide will allow OBriens to better serve you. Information designed to save you time and effort is present in red italics

OBriens Response Management Inc.

Masters Guide to Compliance In US Waters

2012

EMERGENCY RESPONSE Notification The USCG must be notified if there is a discharge of oil onto the water or if there is a substantial threat of a discharge into the water. Under USCG

interpretation, many things are considered a substantial threat including:

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. Grounding or stranding even the slightest touch of the bottom Collision and allision including a hard bump by a tug or a hard landing at a dock Spill on deck any quantity that is enough for the oil to flow toward the rail Hull failure Excessive list Containment system failure Submerged and foundered Wrecked and stranded Hazardous vapor release Machinery / Equipment malfunctions steering, auxiliaries, fire pump, life boat, radar, radio, compass, cargo handling gear, etc. Explosion Fire

US law says that a person in charge of a vessel must notify the USCG if any of these situations exist. This person in charge can be the Master, the owner/operator, the DPA, the QI or another person who your company policy says is in charge of your ship. The regulations say that this person must make the notifications as soon as possible. It is well established that the Qualified Individual may make the required notifications on behalf of the Master. So, essentially you should contact OBriens if you are in doubt and well help determine whether the USCG and other agencies should be notified. Our contract with you requires us to ensure compliance with all laws and regulations. Please allow us to do this for you.

OBriens Response Management Inc.

Masters Guide to Compliance In US Waters

2012

Masters Actions Upon discovery of one of the above situations you should proceed as follows: 1. 2. See to the immediate safety of the crew and vessel Make an initial assessment of the situation Do not delay notification while trying to determine cause, fault or blame. This will be determined by a later investigation Call the QI at +1 985 781 0804 Contact the owner/manager/operator keep this conversation brief since the QI will be trying to contact you in the next 10 15 minutes Wait for a return call from the QI after you have received the return call from the QI you will have time to communicate with others When the USCG and/or other authorities arrive, inform them that you have notified the QI and the QI is responding to the situation

3. 4. 5. 6.

What the QI needs to know In order to provide the help you need, the QI will ask you for some important information. This includes: 1. 2. 3. 4. 5. 6. 7. 8. 9. Your Name Telephone number, fax, email or other means of communication Vessel Name P&I Club membership Time and date of incident Exact location such as latitude and longitude if anchored or underway; port, slip and berth designation if in port Brief description of situation Type of oil spilled try to be as specific as possible, but knowing if it is clear or black is enough for the QI to get started Estimated Quantity we know this is difficult we are looking for your best estimate. It is important for us to know if this is a very small spill, a very large spill, or something in between. Death / Injuries to the crew Damage to the ship Any other information or concerns you have

10. 11. 12.

OBriens Response Management Inc.

Masters Guide to Compliance In US Waters

2012

COMMUNICATING WITH OBRIENS Telephone Emergency calls should go to our Command Center at our 24-hour number: + 1 985 781 0804 All other calls should be directed to the OBriens Vessel Services Office: +1 609 275 9600. Our normal office hours are 0800 1700 US East Coast time. After hours all calls are automatically forwarded to our Command Center where you will get assistance. Email OBriens has established a list of email addresses to ensure effective and efficient assistance to you. Each address has a specific purpose. Use of the proper address will ensure a quick response from OBriens. If possible, do NOT mix several requests of different types in the same email as this may delay proper action on your request. Please use the primary email addresses below when communicating with OBriens. Additional emails are identified on the next page. Email Address Purpose

canada@obriensrm.com

Canadian coverage requests or questions Follow up information relating to an oil spill or other emergency Do not use this address for routine communications it is reserved for emergencies only Questions you dont know where else to send Panama Canal SOPEP All general correspondence regarding plans (Except Panama Canal SOPEP)

commandcenter@obriensrm.com

inquiry@obriensrm.com pcsopep@obriensrm.com vrp@obriensrm.com

OBriens Response Management Inc.

Masters Guide to Compliance In US Waters

2012

Additional Email Addresses ampd@obriensrm.com casp@obriensrm.com cofr@obriensrm.com mediarelations@obriensrm.com noad@obriensrm.com

Purpose AMPD coverage requests or questions California Shoreline Protection coverage requests or questions Certificate of Financial Responsibility OBriens public relations and news media services Notice of arrival and departure for US and Canada Use this address for other emails to OBriens relating to the position, loading status, SOF and other such documents Conducting a Qualified Individual Notification Exercise by email (NOT for confirmation of voice QI Notification Exercise) The USCG strongly recommends that the QI Notification Exercise be conducted by voice To include in copy when communicating with Salvage and Marine Firefighting resource providers To request vessel technical assistance and schedule vessel attendance prior to a potential compliance inspection/exam EPA Vessel General Permit eNOI submission requests EPA One Time Report submission requests

QI-exercise@obriensrm.com

smff@obriensrm.com

vesselboardings@obriensrm.com

vgp@obriensrm.com vgp1xreport@obriensrm.com

OBriens Response Management Inc.

Masters Guide to Compliance In US Waters COMPLIANCE Required Documents The following documents are required in the US in addition to the normal international documents: TANK VESSEL 1. 2. 3. 4. 5. *Certificate of Financial Responsibility (COFR) issued by USCG Vessel Response Plan for Tank Ships (T VRP) hard copy USCG Approval Letter for the VRP EPA Vessel General Permit Notice of Intent (NOI) and Certificate of Coverage Salvage and Marine Firefighting (SMFF) Pre Fire Plan, Pre Fire Certificate, Contract and Funding Agreement NONTANK VESSEL 1. 2. 3. Certificate of Financial Responsibility (COFR) issued by USCG Vessel Response Plan for Non-Tank Ships (NTVRP) hard copy USCG Interim Operating Authorization (IOA) Letter; OR USCG electronic receipt of the NT VRP Submission to USCG Headquarters for review and approval 4. EPA Vessel General Permit Notice of Intent (NOI) and Certificate of Coverage

2012

Most USCG VRP are NOT approved for Alaska, Guam, American Samoa or Pago Pago. If you will operate in or transiting one of these areas when bound for or departing from a port or place in the U.S., ensure that your vessel has the required VRP or NTVRP approved. Approval will be listed in the Vessel Specific Appendix. If the ship is not covered, or you have questions, contact OBriens immediately. *The USCG no longer issues a hard copy COFR. COFR validity can be verified on the USCG National Pollution Funds Center (NPFC) website: https://npfc.uscg.mil/COFR/default.aspx All of these plans are required for compliance with laws and regulations. There is little information in the required plan that is useful for the Master. Keep the plans updated as required and available for boardings by the authorities and vetting inspectors. [If you know the OBriens emergency telephone number and your owner/manager/operators telephone number, thats all you need in a real emergency.] OBriens Response Management Inc. 8

Masters Guide to Compliance In US Waters

2012

State of Alaska In addition to the federal documents, if calling an Alaska port you must have an Alaska COFR and an Alaska Oil Discharge Prevention and Contingency Plan (ODPCP). 1. 2. Tank vessels usually receive the necessary coverage from the charterer (i.e. terminal). Nontank vessels must apply for the COFR and ODPCP prior to entering Alaska waters.

The port of Red Dog is outside Alaska waters so an Alaska COFR and Alaska ODPCP are NOT required. State of California In addition to the federal documents, if calling a California port you must have: 1. 2. 3. 4. Certificate of Financial Responsibility (COFR) issued by California Vessel Contingency Plan (VCP) either Tank or Nontank vessel Plan Approval Letter must be in the front of the binder with the VCP California Emergency Notification Checklist Placard

State of Hawaii In addition to the federal documents, TANK vessels calling Hawaii must have: 1. Obtain OSRO coverage for dispersant services from Clean Islands Council. Documentation of coverage must be on board the vessel to be made available to local USCG officials upon request.

Contact Ms. Kyle Jacobi at kyle@cleanislands.org to obtain Clean Islands Council services State of Michigan In addition to the federal documents, if calling a port in Michigan you must have: 1. General Permit for Ballast Water Discharge It is required that the application for this permit be submitted at least 30 days prior to arrival in Minnesota waters.

Michigan does not allow the discharge of ballast water unless it is first treated by an approved ballast water treatment system.

OBriens Response Management Inc.

Masters Guide to Compliance In US Waters

2012

State of Minnesota In addition to the federal documents, if calling a port in Minnesota you must have: 1.
General Permit for Ballast Water Discharge It is required that the application for this permit be submitted at least 30 days prior to arrival in Minnesota waters.

Minnesota does not allow the discharge of ballast water unless it is first treated by an approved ballast water treatment system. State of Oregon In addition to the federal documents, if a commercial
vessel is calling a port in Oregon you must have: 1. Field Guide This document is provided by the Marine Fire and Safety Association (MFSA) for ports on the Columbia and Willamette Rivers or the Coos Bay Response Corporation in Coos Bay.

These arrangements are routinely handled by your local agent.

State of Washington In addition to the federal documents, if a commercial

vessel is calling a port in Washington you must have: 1. Field Guide This document is provided by the Washington State Maritime Cooperative (WSMC) for vessels entering Puget Sound ports and the Marine Fire and Safety Association for vessels call Washington ports on the Columbia River. Notification Placard Should be displayed on board

2.

These arrangements are routinely handled by your local agent State of Wisconsin In addition to the federal documents, if calling a port in Wisconsin you must have: 1. Ballast Water Discharge General Permit To obtain permit authorization it is required to submit a copy of the EPA Vessel General Permit NOI no later than July 31, 2010 or at least 30 days prior to discharging in Wisconsin waters.

Wisconsin does not allow the discharge of ballast water containing seawater without it being significantly diluted.

OBriens Response Management Inc.

10

Masters Guide to Compliance In US Waters ON BOARD DRILLS AND EXERCISES

2012

Qualified Individual Notification Exercises This exercise must be conducted at least once each quarter. The intent is that the Master knows how to contact the Qualified Individual (QI). If you have a real emergency, you must contact us by voice. 1. 2 3. Call the 24-hour emergency number +1 985 781 0804 State you are conducting a Qualified Individual Notification Exercise. The Command Center will ask you a couple questions and will make a record of your call.

It is permissible to do this exercise by email or fax, but we recommend making voice contact. Exercise initiated by email or fax will not be considered complete until you have received a return email or fax acknowledgement from the QI. The USCG strongly recommends that this exercise be conducted by voice.

Documentation Regulations require official records of these exercises be kept on board the ship. This is best done by making an entry in the Ships Log: 1. 2. A log entry that you successfully contacted the QI by voice is sufficient for regulatory purposes. It is not required to record the name of the person you spoke with and that person does not have to be one of the QIs listed in the VRP/NTVRP as long as they identify themselves as a representative of OBriens.

OBriens will not acknowledge receipt of exercise documentation for an exercise conducted by voice. When conducting the QI Notification Exercises by voice, no other documentation via email or fax is necessary or desirable.

Emergency Procedure Drills

These drills are to be conducted once a quarter. This is the same exercises you are doing for the safety management system. But, once each year, the exercise should include a response to an oil spill on deck. It is also not required or desired that you notify OBriens in advance of conducting either the QI Exercise or Emergency Procedure Drills.

OBriens Response Management Inc.

11

Masters Guide to Compliance In US Waters

2012

AP Exercise The Panama Canal SOPEP gives direction. This is a different exercise. Contacting the Qualified Individual does not meet the requirements of the Panama Canal SOPEP. If you have a Panama Canal SOPEP, you must conduct an Authorized Person Notification Exercise twice each year. Agency Conducted Unannounced Drills The states of Alaska, Washington, Oregon and California may board your vessel and request that you conduct an unannounced drill. These drills are usually in the form of notification exercises. Do not delay, time is of the essence. Immediately notify the QI at + 1 985 781 0804. Tell the QI that you are involved in an unannounced drill and that you have state authorities on board. We must follow special procedures on our side to successfully comply with the unannounced drill requirements. You must tell us this exercise is being required by state authorities. Otherwise, we may mistake it for a normal QI Notification Exercise. This will undoubtedly lead to a failure of the drill and a possible penalty for the ship.

OBriens Response Management Inc.

12

Masters Guide to Compliance In US Waters

2012

TESTS BEFORE ENTERING OR GETTING UNDERWAY IN US WATERS The USCG requires that the following equipment must be tested no more than 12 hours before entering the US Territorial Sea (12 miles) or before each time a vessel gets underway in US waters: 1. Primary and secondary steering gear test procedure includes: a. Visual inspection of the steering gear and its connecting linkage. b. Where applicable, the operation of the following: i. Each remote steering gear control system. ii. Each steering position located on the navigating bridge. iii. The main steering gear from the alternative power supply, if installed. iv. The main steering gear from the alternative power supply, if installed. v. Each remote steering gear control system power failure alarm. vi. Each remote steering gear power unit failure alarm. vii. The full movement of the rudder to the required capabilities of the steering gear. All internal vessel control communications and vessel control alarms. Standby or emergency generator Storage batteries for emergency lighting and power systems in vessel control and propulsion machinery spaces Main propulsion machinery, ahead and astern

2. 3. 4. 5.

No vessel may enter, or be operated on, the Territorial Sea of the United States unless the emergency steering drill described below has been conducted prior to departure and 48 hours prior to entry and logged in the vessel logbook, unless the drill is conducted and logged on a regular basis at least once every three months. This drill must include at a minimum the following: 1. 2. 3. Operation of the main steering gear from within the steering gear compartment Operation of the means of communications between the navigating bridge and the steering compartment Operation of the alternative power supply for the steering gear if the vessel is so equipped

These tests do NOT need to be reported to the USCG or OBriens. The completion of these tests should be recorded in the Ships Log.

OBriens Response Management Inc.

13

Masters Guide to Compliance In US Waters

2012

NOTICE OF ARRIVAL/DEPARTURE Notice of Arrival/Departure must be filed with the USCG and is usually accomplished with the Electronic Notice of Arrival/Departure (eNOA/D). This document must be filed according to USCG requirements or your vessel may be delayed entering port. 1. 2 Your eNOA/D should be sent to the USCG National Vessel Movement Center at the following address: enoad@nvmc.uscg.gov If you would like O'Brien's to receive a copy of your NOA/D, you may forward a copy to us at: noad@obriensrm.com. However, we do NOT require that you send us a copy: a. We only store your NOA/D as a record of your voyage. b. It will NOT be read except when there is an emergency and we need information contained in the NOA/D. c. Do NOT include any requests for assistance from OBriens in the NOA/D.

Do NOT send OBriens reports such as noon reports, position reports, berthing, bunkering, cargo loading/discharging reports, stowage plans, entering EEZ, other (24, 48 or 72) hour notice of arrival, status reports, discharge reports, etc. OBriens will NOT acknowledge receipt of any such reports. Do not list OBriens as your Point of Contact in the NOA/D. This should be a local agent or another person/organization who is arranging the details of your call to the US. OBriens will NOT acknowledge receipt of the NOA/D. Address requests for assistance or information to one of the email address provided above. Do not include any requests for assistance from OBriens in the NOA/D. Additional information regarding the submission of the eNOA/D can be found at the USCG National Vessel Movement Center (NVMC) website: http://www.nvmc.uscg.gov/NVMC/default.aspx

OBriens Response Management Inc.

14

Masters Guide to Compliance In US Waters AVERAGE MOST PROBABLE DISCHARGE (AMPD) COVERAGE

2012

AMPD coverage applies ONLY to TANK vessels when they are transferring cargo. AMPD coverage is NOT required for BUNKERING. Vessels conducting cargo operations at a terminal facility are afforded AMPD coverage through the terminal's AMPD service provider. The only known exception is the offshore mooring at Barbers Point, Hawaii. The response activities in the Gulf of Mexico have caused OSRO equipment to be relocated from time to time: 1. 2 Therefore, we recommend your OSRO be notified of all lightering operations. Please contact your contracted OSRO provider listed below for specific information on AMPD charges and to arrange coverage or submit an electronic coverage request that will be forwarded directly to the appropriate service provider. National Response Corporation (NRC) 3500 Sunrise Highway, Suite T103 Great River, NY 11739, USA Tel: +1 631 224 9141 (24 Hrs) +1 800 899 4672 Fax: +1 631 224 9086 Email: iocdo@nrcc.com

Marine Spill Response Corp. (MSRC) 455 Spring Park Place, Suite 200 Herndon, VA 20170 USA Tel: +1 800 645 7745 (24 Hrs) +1 732 417 0175 Fax: +1 732 417 0097 Email: ampd@msrc.org

We have recently automated our AMPD request process to minimize delays in communication, notification and confirmation of coverage. You or your designated company representative can use our online AMPD coverage request form to submit your request directly to your OSRO service provider. Use the link: https://www.piersystem.com/go/doc/2783/1211855/ AMPD coverage requests in the Delaware Bay will be forwarded to Delaware Bay River Cooperative (DBRC) unless otherwise directed. Contact OBriens at ampd@obriensrm.com if you are not sure if AMPD coverage is necessary or for assistance in arranging coverage.

OBriens Response Management Inc.

15

Masters Guide to Compliance In US Waters

2012

CALIFORNIA INCREASED ON-WATER RESPONSE REQUIREMENTS AND SHORELINE PROTECTION COVERAGE The state of California adopted increased on-water response planning requirements effective October 1, 2009. The state of California also identified specific areas of California that require special shoreline protection when ships are transiting both in and out of port. Coverage can be arranged by your local agent, your office or by contacting your OSRO directly. Weve updated our website to process requests for coverage to minimize delays in communication, notification and confirmation of coverage. Select the following web link: https://www.piersystem.com/go/doc/2783/1211855/ 1. The OSRO must be notified at least 24 hours in advance so that the required resources can be arraigned. There may be significant costs associated with coverage.

Plan holders are required to obtain additional OSRO coverage as follows:

2. 3. 4.

Vessels that call Port Hueneme Vessels transiting the southbound traffic lane in the Santa Barbara Channel Vessels that transit the area south of the San Mateo Bridge while en route to Redwood City in southern San Francisco Bay

There are no requirements for shoreline protection for the ports of Sacramento and Stockton. Increased response planning requirements are already met by the existing contracted OSRO service providers for all other areas in California. Questions regarding coverage should be addressed to: casp@obriensrm.com.

OBriens Response Management Inc.

16

Masters Guide to Compliance In US Waters TANK VESSEL OSRO Port LA/LB None MSRC San Francisco All Others 24 Hour Notification Required

2012

LA/LB None NRC San Francisco All Others 24 Hour Notification

NONTANK VESSEL OSRO Port LA/LB San Francisco MSRC & NRC San Diego Humboldt Bay All Others LA/LB None MSRC San Francisco All Others 24 Hour Notification 24 Hour Notification None Required

LA/LB None NRC San Francisco All Others OBriens Response Management Inc. 24 Hour Notification 17

Masters Guide to Compliance In US Waters CALIFORNIA EMISSION REDUCTION REGULATIONS

2012

California Air Resources Board The State of California Air Resources Board (CARB) has been active in their efforts to implement regulations to reduce air emissions in California. The latest amendments became effective December 1, 2011. More information is available in our Regulatory Update and on our website. Applicability a. Any person who owns, operates, charters, rents or leases ocean-going vessels (both US and foreign-flagged) in any of the Regulated California Waters must comply with these regulations b. All ocean-going vessels visiting California Ports c. All ocean-going vessels operating within California Waters d. All ocean-going vessels operating within 24 nm of the California Baseline e. Does not apply when on innocent passage through California Waters or within 24 nm of the California Baseline. Vessel owners/operators are required to use the marine distillate fuels shown in below: Fuel Requirement Phase I Effective Date July 1, 20091 Fuel

Marine gas oil (DMA) at or below 1.5% sulfur; or Marine diesel oil (DMB) at or below 0.5% sulfur Marine gas oil (DMA) at or below 1.0% sulfur; or Marine diesel oil (DMB) at or 0.5% sulfur Marine gas oil (DMA) or Marine diesel oil (DMB) at or below 0.1% sulfur

August 1, 20122

Phase I

July 1, 20143

1. No change from the existing requirements. 2. Marine gas oil sulfur limit reduced from 1.5% to 1%. No change in marine diesel oil limit. 3. Implementation delayed from 2012 to 2014.

OBriens Response Management Inc.

18

Masters Guide to Compliance In US Waters BALLAST WATER MANAGEMENT AND REPORTING

2012

The USCG requires each vessel to maintain a ballast water management plan that has been developed specifically for the vessel that will allow those responsible for the plan's implementation to understand and follow the vessel's ballast water management strategy. Ballast Water Reporting: 1. At least 24 hours before arrival at the port or place of destination, or before departing the port or place of departure if voyage is less than 24 hours, submit the Ballast Water Reporting Form to the National Ballast Information Clearinghouse (NBIC) by one of the following methods: a. Online via the following web link: http://invasions.si.edu/cgi/bwform, b. via e-mail at the following address nbic@ballastreport.org, or c. If necessary, you can fax to +1 301 261 431 The ballast water management plan is not required to be approved by any authority.

2.

Additional information regarding this topic can be found at the National Ballast Information Clearinghouse (NBIC) website: http://invasions.si.edu/nbic/ Do NOT send ballast water management reports to OBriens. We will not acknowledge receipt of any such reports. EPA NPDES VESSEL GENERAL PERMIT (VGP) COMPLIANCE Applicable vessels have been authorized to discharge in accordance with the VGP since February 6, 2009 and must have a Compliance Program/Policies in place to ensure compliance with the VGP requirements that include the implementation, monitoring and documentation of best management practices for the 26 discharges covered by the permit that are applicable for each It is recommended that you contact your vessels owner/operator for further guidance regarding the company policy implemented to meet compliance with the VGP requirements.

OBriens Response Management Inc.

19

Masters Guide to Compliance In US Waters

2012

Notices of Intent (NOI) The purpose of the NOI is for the vessel owner/operator to certify a vessel has implemented sufficient policies to ensure compliance with the VGP inspection, monitoring and documentation requirements. 1. 2. Only vessels that operate/call US waters (0-3 miles) are required to comply with the VGP and submit a NOI. Vessels that did not submit a NOI prior to September 19, 2009 and meet the criteria to do so must submit an NOI at least 30 days prior to operating in US waters (0-3 miles).

The NOI confirmation documentation includes a CERTIFICATE OF COVERAGE and official copy of the COMPLETED NOI FORM, both autogenerated by the EPA. Copies of these two documents must be maintained on board the vessel and made available upon request for inspection. The EPA and USCG have entered into an agreement to commence VGP compliance verification and enforcement effective March 13, 2011. It has been incorporated into a routine part of a Port State Control Exam.

OBriens Response Management Inc.

20

Masters Guide to Compliance In US Waters SUGGESTIONS / COMMENTS / CLARIFICATIONS Contact Vessel Services This document is intended to be a helpful guide for Masters. Please help us make it more useful for you. If you should have any questions, comments or concerns please contact us at: inquiry@obriensrm.com or via the following website http://www.obriensrm.com/go/doc/2783/1104031 24-Hour Emergency Assistance: +1 985 781 0804 www.obriensrm.com

2012

OBriens Response Management Inc.

21