🔍 Key Concepts

• 33 CFR Part 155 – Oil or Hazardous Material Pollution Prevention Regulations for Vessels • Oil transfer procedures and required equipment/conditions before starting a transfer • Difference between individual safety measures and a combined "catch-all" requirement

💭 Think About

• Look at 33 CFR language for oil transfers: does it usually require just one safety measure, or that all applicable precautions be in place before transfer begins? • Ask yourself whether any of these options (A, B, or C) would ever be allowed to be missing while still being in full compliance with the regulation. • Consider whether the regulation focuses only on scuppers, only on containment, or on the entire transfer system setup before oil movement starts.

✅ Before You Answer

• Verify in 33 CFR Part 155 whether transfer system isolation (blanking/shutoff of unused parts) is required before transfer. • Check whether discharge containment must be in place before transfer starts, not just during or after a spill. • Confirm if regulations require scuppers/drains in containment to be closed during oil transfers to prevent overboard discharge.