Discharge of Oil - Vegetable Oil?

[mkollerjr]

Loren,

I thought I remember a recent post regarding your local USCG saying they would still bust you for accidental vegetable oil discharge. I've been reviewing the CFR's (Code of Federal Regulations) in preparation of some exams coming up. You should refer them to 33 CFR (which the USCG is responsible for) Subchapter O, which defines oil as:

"Oil means petroleum in any form including crude oil, fuel oil, sludge, oil refuse, and refined products. Oil does not include animal or vegetable based oil..."

Unless I am missing some other definitions somewhere.

Mark

 

[toddster]

Vegetable oils fail the marine toxicity tests just as badly as petroleum based oil. It's because the way the tests are set up, the oil droplets stick to the mouthparts of the invertebrates and suffocate them, aside from any chemical toxicity. Dead is dead. It's like sticking their heads in teeny tiny plastic bags... Even at concentrations as low as 5 ppm. I think it's because the little beggars actively seek out the droplets and try to eat them.

 

[mkollerjr]

I'm sure you're right. But I'm going by what the rule says. Vegetable oil is not considered oil for the purposes of discharge of oil regulations. I'll be darned if I'm going to get slapped with a $10k fine for not reporting an accidental olive oil spill down my galley sink making a spaghetti dinner.

Do you know if the test you mention is referenced anywhere else, making it official?

 

[toddster]

I could find the specific regulations in my project files somewhere. It's not a rule about discharge, it's a rule about what sorts of lubricants are allowed on ships. It's a functional specification, (which would otherwise be good) so it doesn't call out vegetable or mineral. Anything that meets the specs is OK. The problem is, some knucklehead - or more likely, a committee - cut and pasted bits and pieces from various different, irrelevant, and incompatible EPA and OECD specifications, then multiplied the pass level by 10X (hey, more gotta be better, right?) without checking to see whether that's even physically possible. (It isn't.)