🔍 Key Concepts

• 46 CFR requirements for fuel oil and bulk lubricating oil containment on vessels under 300 gross tons • Differences between a fixed container, an enclosed deck area, and an overflow manifold as means of containment • How construction date (before 1 July 1974) affects compliance options

💭 Think About

• Which option would actually "hold" oil that is spilled or overflows during fueling or transfer, without depending on another tank or system? • Look at the capacities: which capacity is commonly referenced in the regulations for small-vessel containment – a small fixed amount in gallons or a fraction of a barrel? • Does an overflow line that sends oil to another tank truly count as a containment system located at the point of possible spill?

✅ Before You Answer

• Verify in 46 CFR, Subchapter T or Subchapter I (depending on vessel type) what minimum capacity in U.S. gallons is specified for containment on small vessels of this size and age • Confirm that the requirement is for a fixed container or coaming located where the oil could be spilled (such as near fuel oil or lube oil filling or transfer points) • Check whether regulations explicitly allow an overflow manifold to a day tank as a substitute for local spill containment, or if containment must be able to retain the oil on deck or in a pan.