| Lesson Learned No. 1 |
Exercises |
| What happened? |
The exercises carried out before the event did not include the participation of state and municipal institutions, nor did they foresee the use of resources exclusively from the government or a situation of national significance with an unknown polluter. Exercises in Brasil focus on at-sea response, and not at shoreline clean-up. |
| Why did it happen? |
No scenarios for triggering the PNC were envisaged in these circumstances. |
| What was the consequence? |
Interactions with other federative entities were developed during the emergency phase. There was no prior preparation for managing the response to a spill of national significance with unknown polluter. |
| Suggestions for the future |
To practice complex scenarios in simulated exercises, including the involvement of other entities (at local and state levels) and considering the possibility of the polluter not being identified. To exercise scenarios which focus on shoreline clean-up, instead of at-sea response only. |
| Lesson Learned No. 2 |
Incident Command System - ICS |
| What happened? |
The PNC Manual´s and the ICS´s forms were not used entirely. Data collection tools were generated throughout, and not prior, to the emergency. |
| Why did it happen? |
Many participants were not familiar with the tools. There was an overlap between the ICS and the PNC forms. There was no previous development of tools (such as applications) for data collection and standardization. |
| What was the consequence? |
Problems in the command flow, doubts about roles and how to fill out the forms. Application development during the emergency phase generated positive, but late results. |
| Suggestions for the future |
To perform harmonization and simplification between the templates and forms contained in the PNC Manual and those provided in the ICS. To provide training in ICS, especially considering the roles of each section and the responsibility to fill out forms. To refine the tools created in this incident, so that they are ready for future events. |
| Lesson Learned No. 3 |
Legal framework |
| What happened? |
There was no provision for tools/resources/structure to respond to an incident of this magnitude exclusively by the government. |
| Why did it happen? |
Decree No. 8,127/2013 and its Manual did not provide guidelines for unusual incidents, such as the one experienced. |
| What was the consequence? |
It was necessary to create flows and tools during the emergency phase, which impacted the agility of the response. |
| Suggestions for the future |
To establish a Working Group, to be coordinated by the MMA, as National Authority of the PNC, and with the participation of the Brazilian Navy, Ibama, ANP, ICMBio and SEDEC, to revise Decree No. 8,127/2013, Decree 10.950/2022, the PNC Manual and Resolution n. 398/2008 (CONAMA 2008). |
| Lesson Learned No. 4 |
Interinstitutional articulation |
| What happened? |
Difficulties in establishing articulations between GAA, entities that participated in the PNC Support Committee and local governments. |
| Why did it happen? |
Institutions that participated in the Support Committee did not engage in responding to the incident. There was no tool for previous interaction between the Federal, State and Municipal levels. |
| What was the consequence? |
Delay in response to specific demands, uncoordinated actions between Union and states. |
| Suggestions for the future |
To establish, on the part of the National Authority, mechanisms for engaging the institutions that were in the Support Committee (or another group to be created), as well as state agencies, to improve the articulation, integration and interaction necessary to respond to an incident. To promote the implementation of the Area Plans. |
| Lesson Learned No. 5 |
Disclosure |
| What happened? |
The information dissemination channels were not established immediately. There was no planning to reach all audiences, especially local communities. |
| Why did it happen? |
Unpredictability of the incident escalation. Absence of prior communication plan. |
| What was the consequence? |
It took time to provide regular information to the public at the first weeks of the emergency. Some local communities were not reached by official communication. |
| Suggestions for the future |
To review the communication strategy, considering the need for agility and objectivity in the dissemination of information to the press and to the society. To provide training in conflict management and communications strategy for the GAA staff. |
| Lesson Learned No. 6 |
PNC activation |
| What happened? |
Absence of transparency regarding the activation of the PNC. Absence of objective criteria for its activation. |
| Why did it happen? |
The plan was activated by a document classified as confidential. Inability to predict the evolution of the incident. PNC Manual provides subjective criteria for triggering the plan. The PNC manual was not published, so it was not easily accessible to the public. |
| What was the consequence? |
Public authorities, society and the press questioned the activation of the plan and the correct moment to activate it. |
| Suggestions for the future |
To refine the criteria for triggering the PNC, to facilitate decision making. To formally trigger the PNC with a Ministerial Ordinance or superior document, to legitimize and support the acts and demands of GAA, as well as to inform the public that there is an emergency ongoing. To publish the PNC Manual, aiming to provide transparency of the planned actions to be implemented during an incident, to society and to the control agencies. |
| Lesson Learned No. 7 |
Resources |
| What happened? |
GAA institutions did not have specific resources to respond to an incident of this magnitude. There were no agile mechanisms for hiring and purchasing materials in an emergency. The Government is not refunded when the polluter is unknown. Government formally requested services and equipment from oil companies. |
| Why did it happen? |
There is no legal provision. |
| What was the consequence? |
Public institutions spent their own resources for emergency response, impacting other actions under their responsibility. The hiring and purchasing process takes time in the public service, delaying the delivery of equipment. There is no compensation for the government. Oil companies that acted at the government´s request were not reimbursed yet. |
| Suggestions for the future |
To assess the need to create a national fund (public or private) to compensate damages caused by oil spill pollution incidents and to provide financial resources to the response. To proceed with the internalization of international conventions dealing with liability (CLC 1992, Funds Convention, Bunker Convention). To detail the reimbursement process. |
| Lesson Learned No. 8 |
Local teams |
| What happened? |
Cleaning was performed by local teams. However, the techniques were not adequate in some cases. |
| Why did it happen? |
Lack of preparation of local teams to respond to oil spills. |
| What was the consequence? |
Larger volume of contaminated waste, safety problems, secondary impacts of the response. |
| Suggestions for the future |
Increase emergency response actions by training local teams to shoreline clean-up, in coordination with the National Secretariat for Civil Defence and State Agencies. |
| Lesson Learned No. 9 |
Volunteers |
| What happened? |
High engagement of volunteers, whether from the community or from experts, however, in a disorganized manner. |
| Why did it happen? |
Absence of established procedure for the management of volunteers of various types. |
| What was the consequence? |
Available workforce and knowledge could have been better used. |
| Suggestions for the future |
To register possible volunteers for beach cleaning. To create a standardized national register of voluntary companies and specialists, including international ones. To establish formal agreements with relevant partners. |
| Lesson Learned No. 10 |
Control Institutions |
| What happened? |
Control and judicial interference in the emergency management. Absence of a specific group dedicated to answering such requests in the GAA. |
| Why did it happen? |
Lack of proactive disclosure of ongoing actions. Lack of interaction with the control institutions. |
| What was the consequence? |
Overload on technical teams to respond to demands. Need to carry out ineffective field actions to meet legal demands. |
| Suggestions for the future |
To include in the organizational ICS chart, a unit dedicated to answering to the control units, preferably a multi-institutional one. To publicize GAA’s actions from the first moment. |
| Lesson Learned No. 11 |
Feedback |
| What happened? |
Federal government was not prepared to get feedback after oil pollution incidents. |
| Why did it happen? |
The tool was not mentioned in the legal framework. |
| What was the consequence? |
Specific form was generated by GAA during the emergency. |
| Suggestions for the future |
To include the use of a feedback tool in the PNC Manual. |
| Lesson Learned No. 12 |
Inventory |
| What happened? |
No information on the quantities of materials and resources available to be requested by the Federal Government. |
| Why did it happen? |
Absence of national inventory of emergency response equipment. |
| What was the consequence? |
Administrative requests could have been better programmed, speeding up the response. |
| Suggestions for the future |
To have an inventory database of emergency plans, area plans and available resources. |
| Lesson Learned No. 13 |
Waste Management |
| What happened? |
Difficulty identifying locations for final waste disposal. Absence of prior protocol for identifying temporary locations. |
| Why did it happen? |
Lack of knowledge about places to receive oily residues in large quantities. |
| What was the consequence? |
Final recipients were identified during the emergency, which delayed waste disposal. Waste was disposed of in inappropriate places, causing social and environmental impacts. Sending materials to cement companies proved to be an environmentally appropriate alternative. |
| Suggestions for the future |
To develop a protocol to promote the prior identification of temporary and final disposal sites. Such protocol should be shared with the competent entities (states, through the State Environment Agency and municipalities). |
| Lesson Learned No. 14 |
Scientific Community/Tecnhical advisors |
| What happened? |
In the early stages, the scientific community was not engaged with GAA in the emergency response. Researchers acted isolated and without knowledge of the context. Excellent experience with ITOPF advisors |
| Why did it happen? |
There was no previous procedure for interaction with the academy. |
| What was the consequence? |
Creation of Working Groups by GAA organized the participation of the scientific community. |
| Suggestions for the future |
To create a previous channel of interaction with the scientific community, to assist in PNC situations. To encourage scientific research on topics of interest to the PNC. |
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