🔍 Key Concepts

• 33 CFR pollution prevention requirements for oil transfers on vessels, especially older vessels over 100 gross tons • Special provisions for vessels where permanent containment (drip pans/coamings) at the fill fitting is impractical • Differences between equipment requirements (hardware changes) and operational controls (watchstanding, procedures, or special nozzles)

💭 Think About

• Look at what the regulation requires specifically when physical containment is not practical. Does it mandate changing the fitting itself, adding a particular device, or changing how the transfer is supervised? • Ask yourself which options are one-time modifications versus ongoing operational measures, and which style is more consistent with how 33 CFR usually handles exceptions for older existing vessels. • Consider whether the rule is focused on preventing spills at the source or on monitoring and responding if a spill begins. Which of the listed choices best aligns with that intent for this exact exception?

✅ Before You Answer

• Verify in 33 CFR 155 (or related part) what is required for vessels constructed before July 1, 1974 and over 100 GT that cannot practically provide fixed containment at the fill fitting. • Check whether the regulation’s language points to a specific device (like a drip collar or special nozzle) or a specific operating procedure (like a required watch). • Confirm if there is any mention of a deadline date for modification in the relevant section, and whether that date matches option A or is not referenced at all.