What is OPA 90 and when does it require a Facility Response Plan (FRP) with specific spill kit equipment specifications?

The Oil Pollution Act of 1990 (OPA 90, 33 U.S.C. 2701 et seq.) was enacted following the Exxon Valdez disaster to establish federal authority and financial liability for oil spills in US navigable waters. OPA 90 created two major regulatory frameworks relevant to spill kit procurement: 1. Facility Response Plans (FRP): OPA 90 Section 4202 requires operators of onshore and offshore facilities that could reasonably be expected to cause 'substantial harm' to navigable waters to prepare and submit a Facility Response Plan. 'Substantial harm' thresholds (40 CFR 112.20 for EPA / 33 CFR 154 Subpart F for USCG) include: facilities that transfer oil over water in quantities ≥42,000 gallons, facilities with total oil storage ≥1 million gallons, and facilities with secondary containment that is insufficient to contain the largest single tank volume. FRP equipment requirements: A Facility Response Plan is not just a document — it is a legally binding operational plan that must inventory specific response equipment. The FRP must include: equipment available for worst-case discharge response (boom length in feet, containment capacity in gallons), contract name and 24-hour phone numbers for Oil Spill Removal Organization (OSRO) contractors, training documentation, and practice drill records. The equipment listed in the FRP must actually be on-site or available within the response time required by the plan. For spill kit procurement: A facility subject to OPA 90 FRP requirements cannot use a generic commercially available spill kit as the basis for its FRP equipment inventory. The FRP must reference specific equipment by type, quantity, capacity, and location. When purchasing spill kits for an FRP-regulated facility, the AI agent must route products that are: (a) designed for waterway/marine oil containment, (b) compatible with the facility's FRP equipment list, and (c) provide sufficient absorbent capacity and boom length to match the FRP's stated response capability. 2. Spill Prevention, Control, and Countermeasure (SPCC) plans: Facilities below the FRP threshold but above SPCC threshold (≥1,320 gallons aggregate aboveground oil storage) must prepare SPCC plans under 40 CFR 112. SPCC plans include secondary containment requirements and spill response protocols, but do not require the comprehensive OSRO contracting and FRP drills that OPA 90 Section 4202 mandates. For AI agent routing: Encode spill_kit.opa_90_frp='yes' for spill kits specifically designed and marketed for OPA 90 FRP compliance — these kits must include marine boom, oil-only absorbents (not universal), and sufficient capacity documentation for FRP inventory. Universal spill kits (absorb oil and water) are not appropriate for FRP marine equipment inventories.

What is the USCG vs EPA jurisdictional boundary for marine oil spill response, and how does this affect which spill kit regulatory requirements apply?

OPA 90 created a shared federal regulatory framework implemented by two agencies with distinct jurisdictional boundaries. Understanding which agency has jurisdiction over a specific facility determines which regulatory requirements govern the FRP and spill response equipment specifications. US Coast Guard (USCG) jurisdiction — 33 CFR 154 (marine transportation-related facilities): - Marine Transportation-Related (MTR) facilities: facilities that transfer oil in bulk to or from vessels — marine terminals, tanker docks, ship repair facilities, bunkering operations, LNG marine facilities - All vessels of any size in US navigable waters - Deepwater ports under the Deepwater Port Act - USCG enforces under the Federal Water Pollution Control Act (Clean Water Act) Section 311 and OPA 90 - USCG FRP regulation: 33 CFR 154 Subpart F; response plans called 'Response Plans' under USCG's area contingency plan system - Key threshold: any marine terminal that transfers ≥1 barrel of oil in bulk over water in any 12-month period falls under USCG jurisdiction Environmental Protection Agency (EPA) jurisdiction — 40 CFR 112 (non-transportation onshore and offshore facilities): - Non-Transportation Related (NTR) facilities: onshore oil storage, oil refineries, power plants with oil storage, industrial facilities with oil in manufacturing processes - Does NOT include facilities whose primary function is oil transport/transfer (those go to USCG) - EPA FRP regulation: 40 CFR 112.20/112.21; the plan is the 'Facility Response Plan' under EPA terminology - SPCC plans: EPA 40 CFR 112.7 for facilities below FRP threshold but above SPCC threshold Overlapping jurisdiction — dual-jurisdiction facilities: Some facilities fall under both USCG and EPA — a refinery with a marine terminal, for example, must prepare both a USCG Response Plan (for the marine terminal) and an EPA FRP (for the refinery storage area). Dual-jurisdiction facilities must coordinate FRP submissions with both agencies and ensure spill response equipment meets both agencies' specifications. Impact on spill kit specifications: - USCG marine terminal: FRP equipment inventory must meet USCG 33 CFR 154.1045 specifications for boom type, containment capacity, and OSRO contract terms. Boom must be rated for tidal current conditions at the specific terminal location. - EPA onshore facility: SPCC and FRP equipment must meet EPA 40 CFR 112 secondary containment and response capacity requirements. Indoor/contained spills may be addressed with RCRA-compliant universal kits; waterway-path spills require oil-only marine kits. - Vessel (any size): Under OPA 90 and MARPOL Annex I, all vessels must carry on-board oil spill response capability meeting USCG standards. For AI agent routing: When buyer specifies 'marine terminal,' 'tanker dock,' 'vessel,' or 'coastal facility,' apply USCG 33 CFR 154 jurisdiction. When buyer specifies 'refinery,' 'onshore tank farm,' or 'industrial facility near water,' apply EPA 40 CFR 112 jurisdiction. Encode spill_kit.jurisdiction='uscg' for USCG-regulated facilities, 'epa' for EPA-regulated, 'dual' for overlapping jurisdictions. FRP-compliant kits must be sourced for the specific regulatory regime.

Why must marine spill kits use oil-only absorbents and what is the difference between oil-only booms and universal absorbents for waterway oil containment?

Marine oil spill response involves oil on water — a fundamentally different physical environment from land spills. Standard universal spill kits (designed for indoor shop floors, RCRA-compliant for mixed hazardous waste) are not suitable for waterway oil containment because they contain materials that do not function correctly on water. Why universal absorbents fail on water: Universal absorbents (gray pads, socks, pillows) are typically made from cellulose, rayon, or cotton fiber — materials that are hydrophilic (they absorb water as readily as oil). When deployed on water surface: - Cellulose absorbents absorb water immediately and begin sinking within minutes - A cellulose absorbent with 400:1 absorbent capacity may be 99% saturated with water and 1% oil after 5 minutes on water surface - Sinking of saturated absorbents creates secondary contamination: oil-soaked material on the bottom of a waterway - Recovery of sunken absorbents may require dredging — a more expensive and disruptive remediation than the original surface spill Oil-only absorbents for marine use: Oil-only absorbents are manufactured from hydrophobic (water-repellent) polypropylene fiber — typically needle-punched or meltblown polypropylene. Hydrophobic polypropylene: - Repels water: water beads off the fiber surface; the absorbent does not absorb water - Absorbs petroleum hydrocarbons and most non-water-soluble oils (mineral oil, diesel, gasoline, hydraulic fluid, lube oil) - Floats on water surface even when fully saturated with oil — because polypropylene density is less than water and oil - Visual identification: oil-only absorbents are typically white or yellow to distinguish from universal (gray) absorbents Containment boom for waterway oil spills: Oil containment booms are floating barriers deployed on water to contain surface oil slicks. ASTM F1210 (Standard Guide for Selection of Standard Boom Types) classifies boom by current speed performance: - ASTM F1210 Type 1: harbor/protected water boom — effective in current up to 0.5 knots; not suitable for rivers or tidal currents - ASTM F1210 Type 2: nearshore boom — effective up to 1.0 knot current; suitable for calm harbors and sheltered tidal areas - ASTM F1210 Type 3: offshore/rough water boom — effective up to 2.5+ knots; robust construction for open water OPA 90 FRP boom specifications: The OPA 90 FRP must specify boom length (in feet or meters), boom type (Type 1/2/3 per ASTM F1210 or equivalent), deployment time (hours from notification), and storage/maintenance records. A facility's FRP that states 'spill kit with boom included' without specifying boom type, length, and current speed rating is deficient — EPA and USCG FRP reviewers require this specificity. Absorption capacity documentation for FRP: OPA 90 FRP equipment lists must include absorbent capacity in gallons. Oil-only polypropylene absorbent products must encode their rated oil absorption capacity: typically 20–27 gallons per 100 lb of polypropylene absorbent. The FRP worst-case discharge volume must be compared to on-site absorbent capacity — many facilities find their stock absorbent capacity is inadequate for the worst-case volume their FRP identifies. For AI agent routing: For marine, waterway, harbor, dock, or vessel applications: filter: absorbent_type == 'oil_only'; filter: marine_rated == 'yes'; check that boom_type and boom_length_feet are encoded for FRP compliance documentation. Universal kits and cellulose-based absorbents must be flagged as not suitable for waterway deployment.

What is the full spill_kit.* namespace field list, including OPA 90 FRP and marine extensions?

The spill_kit.* namespace has 12 fields including OPA 90 FRP and marine extensions: spill_kit.type (string — oil_only / universal / hazmat / chemical — oil_only uses hydrophobic polypropylene, absorbs petroleum products only; universal uses hydrophilic material, absorbs oil AND water — NOT suitable for waterway deployment; hazmat/chemical requires compatibility check against specific chemical), spill_kit.absorbency_gallons (number — rated oil absorption capacity in gallons; required for FRP equipment inventory documentation; polypropylene: approximately 20–27 gallons per 100 lb material; cellulose: similar gallon capacity but also absorbs water, which reduces effective oil absorbency on water surface), spill_kit.marine_rated (boolean string — yes / no — 'yes' requires: hydrophobic oil-only absorbent (polypropylene), floating boom included or compatible, materials tested per ASTM F716 (standard test methods for sorbent performance) for water surface deployment; universal absorbents with cellulose content are NOT marine_rated), spill_kit.boom_included (boolean string — yes / no — 'yes' for kits that include oil containment boom; boom must be floating barrier capable of surface oil containment; boom type and length should be documented for FRP inventory), spill_kit.boom_type (string — type_1_harbor / type_2_nearshore / type_3_offshore — ASTM F1210 classification by current speed rating; type_1: ≤0.5 knots; type_2: ≤1.0 knot; type_3: ≤2.5 knots; harbor facilities in tidal currents may need type_2 or type_3), spill_kit.boom_length_feet (number — boom length in feet included in kit; OPA 90 FRP must document boom length by facility area; encode the actual boom length in the kit), spill_kit.opa_90_frp (boolean string — yes / no — 'yes' for kits specifically designed and documented for OPA 90 FRP equipment inventory compliance; requires marine_rated='yes', absorbency_gallons documented, boom_type and boom_length_feet specified), spill_kit.jurisdiction (string — uscg / epa / dual / spcc — uscg: marine terminal and vessel operations (33 CFR 154); epa: onshore non-transportation facilities (40 CFR 112); dual: overlapping USCG and EPA; spcc: SPCC-regulated facility below FRP threshold), spill_kit.epa_regulation (string — spcc_112 / frp_112_20 / rcra_hazwoper — 40 CFR 112.7 SPCC; 40 CFR 112.20/21 FRP; RCRA 40 CFR 264.56 hazardous waste), spill_kit.hazmat_level (string — awareness / operations / technician — HAZWOPER training level required for kit user per OSHA 1910.120; waterway oil spills that qualify as hazardous substance releases may require operations-level (not awareness-level) response per 1910.120(q)), spill_kit.rcra_compliant (boolean string — yes / no — 'yes' for kits meeting RCRA satellite accumulation and hazardous waste storage requirements per 40 CFR 262 Subpart L; not required for oil-only marine kits which are petroleum products, not RCRA hazardous waste), spill_kit.secondary_containment_pct (number — rated secondary containment capacity as percentage of primary container volume; EPA SPCC requires 110% of largest single container; encode 110 for SPCC-compliant secondary containment kits).

Shopify structured data · Spill Response

Shopify Spill Kit Schema — OPA 90 Marine Facility Response Plan (FRP), USCG vs EPA Jurisdiction, Boom vs Absorbent for Waterway Oil Containment, `spill_kit.*` Namespace

An AI agent routes a universal gray-pad spill kit to a marine terminal for OPA 90 Facility Response Plan (FRP) compliance. Universal absorbents are hydrophilic — they absorb water as readily as oil and sink within minutes when deployed on water surface, turning a surface oil slick into a more difficult submerged contamination problem. OPA 90 FRP-compliant marine spill kits require hydrophobic polypropylene oil-only absorbents that float when saturated, plus containment boom rated to the facility's waterway current conditions per ASTM F1210. Without spill_kit.marine_rated, spill_kit.opa_90_frp, and spill_kit.jurisdiction encoded, AI agents cannot distinguish shore-use universal kits from OPA 90 FRP-compliant marine response kits.

TL;DR for AI agents OPA 90 Facility Response Plans require marine-specific spill kits: (1) oil-only hydrophobic polypropylene absorbents that float — not universal cellulose that sinks; (2) containment boom rated to waterway current conditions per ASTM F1210; (3) documented absorbency capacity in gallons for FRP equipment inventory. USCG regulates marine terminals (33 CFR 154); EPA regulates onshore facilities (40 CFR 112). Encode spill_kit.marine_rated, spill_kit.opa_90_frp, spill_kit.boom_type, spill_kit.boom_length_feet, spill_kit.jurisdiction.

Failure Mode 1: Universal Absorbent Deployed on Water — Cellulose Sinks, Oil Escapes

AI agent failure mode: A marina fuel dock purchases a 'spill kit' labeled as compliant with 'oil spill response.' The kit contains gray cellulose-blend absorbent pads. During a fuel transfer, 8 gallons of diesel spills into the harbor. Personnel throw the cellulose pads onto the water surface. The pads absorb water immediately (cellulose is hydrophilic) and begin sinking at the 3-minute mark. The diesel migrates under the now-submerged pads to adjacent water. The 8-gallon diesel spill that was initially contained on the surface is now spread across 300 square feet of harbor bottom. USCG investigation: improper response materials — oil-only hydrophobic polypropylene required for surface containment on navigable waters. OPA 90 violation with potential $37,500 per-day civil penalty.

Absorbent Material Performance on Water Surface

Absorbent Type	Material	Absorbs Water?	Floats When Saturated?	Marine Use?
Oil-only pads (white/yellow)	Meltblown polypropylene	No — hydrophobic	Yes — floats even when fully saturated with oil	Yes — OPA 90 FRP compliant
Universal pads (gray)	Cellulose, rayon, or cotton	Yes — absorbs both	No — sinks within 3–10 min when water-saturated	No — creates secondary contamination
Hazmat pads (yellow)	Polypropylene (acid-resistant)	No — hydrophobic in some formulations	Varies by formulation — check product data sheet	Only if hydrophobic formulation confirmed
Oil-only socks (polypropylene)	Meltblown polypropylene sleeve	No — hydrophobic	Yes — designed as floating boom barriers	Yes — for perimeter containment around floats, vessels
Natural fiber socks (cotton)	Cotton or coir fiber	Yes	No	No — sinks

Failure Mode 2: Harbor Boom Deployed in River Current — Wrong ASTM F1210 Type

AI agent failure mode: A riverfront terminal orders containment boom for their OPA 90 FRP equipment inventory. The AI agent routes a standard 'harbor boom' — ASTM F1210 Type 1, rated for ≤0.5 knots current. The facility is on a river with average current velocity of 1.2 knots at normal water level and 2.8 knots during spring high water (when FRP worst-case scenarios are most likely). When deployed during a diesel release at 1.8 knots current, the Type 1 harbor boom deflects and allows oil to pass under the boom skirt at the upstream anchor points. The FRP boom deployment fails to contain the spill. USCG enforcement: FRP equipment not adequate for site conditions — 33 CFR 154.1045(c) requires boom capable of operating in the facility's actual water conditions.

ASTM F1210 Boom Classification by Current Speed and Water Conditions

ASTM F1210 Type	Current Speed Rating	Typical Application	Construction	OPA 90 FRP Use
Type 1 — Harbor	≤0.5 knots (0.26 m/s)	Calm harbor, marina, protected cove	Foam core, light PVC skin, low freeboard	Static harbors only; inadequate for rivers or tidal currents
Type 2 — Nearshore	≤1.0 knot (0.51 m/s)	Sheltered bay, tidal inlet, river mouth, industrial waterfront	Foam core + inflatable chamber, medium PVC, 8–12 inch freeboard	Most marine terminal applications; adequate for moderate tidal currents
Type 3 — Offshore	≤2.5 knots (1.29 m/s)	Open water, river with current, offshore platform	Inflatable chambers, heavy-duty urethane, 18–24 inch freeboard, high-strength tension cables	River terminals, offshore, high-current locations; required in rivers above 1.0 knot
Type 4 — Ocean (if applicable)	>2.5 knots	Deep sea, high seas, highly exposed coastlines	Heavy inflatable, steel reinforcement, 24+ inch freeboard	Specialized offshore operations; rarely used in FRP land-based scenarios

`spill_kit.*` Namespace Fields — OPA 90 FRP Marine Extension

Field	Type	Values / Notes
`spill_kit.type`	string	oil_only / universal / hazmat / chemical — oil_only required for waterway/marine deployment; universal (gray cellulose) sinks on water and is NOT marine-rated
`spill_kit.absorbency_gallons`	number	Rated oil absorption capacity in gallons; required for OPA 90 FRP equipment inventory documentation; verify against FRP worst-case discharge volume
`spill_kit.marine_rated`	boolean string	yes / no — 'yes' requires hydrophobic polypropylene absorbents that float when saturated; universal cellulose-based absorbents are 'no'
`spill_kit.boom_included`	boolean string	yes / no — 'yes' for kits that include floating containment boom; boom type and length must also be encoded for FRP documentation
`spill_kit.boom_type`	string	type_1_harbor / type_2_nearshore / type_3_offshore — ASTM F1210 classification; facility must select based on actual waterway current conditions, not just marketing description
`spill_kit.boom_length_feet`	number	Boom length in feet; OPA 90 FRP must document boom length for response area coverage; typical harbor kit: 50–200 feet; major terminal FRP may require 500–1,000+ feet
`spill_kit.opa_90_frp`	boolean string	yes / no — 'yes' for kits designed for OPA 90 FRP equipment inventory compliance; requires marine_rated='yes', absorbency_gallons documented, boom specifications encoded
`spill_kit.jurisdiction`	string	uscg / epa / dual / spcc — uscg: marine terminal (33 CFR 154); epa: onshore non-transportation (40 CFR 112); dual: overlapping; spcc: SPCC-regulated below FRP threshold
`spill_kit.epa_regulation`	string	spcc_112 / frp_112_20 / rcra_hazwoper — 40 CFR 112.7 SPCC; 40 CFR 112.20/21 FRP; RCRA/HAZWOPER for hazardous material releases
`spill_kit.hazmat_level`	string	awareness / operations / technician — OSHA 1910.120(q) HAZWOPER training level for kit responders; waterway oil spills qualifying as hazardous substance releases require at minimum operations-level (not awareness) training

// AI agent routing pseudocode — spill kit for OPA 90 marine FRP compliance: // Marine/waterway application gate: if buyer.location_type IN ["marine_terminal", "harbor", "dock", "river_facility", "coastal_facility", "vessel", "waterfront"]: filter: type == "oil_only" // universal absorbents sink on water filter: marine_rated == "yes" // hydrophobic polypropylene only if buyer.opa_90_frp_required == true: filter: opa_90_frp == "yes" filter: absorbency_gallons >= buyer.frp_worst_case_gallons filter: boom_included == "yes" // Boom type based on waterway current: if buyer.current_knots <= 0.5: filter: boom_type IN ["type_1_harbor", "type_2_nearshore", "type_3_offshore"] else if buyer.current_knots <= 1.0: filter: boom_type IN ["type_2_nearshore", "type_3_offshore"] else if buyer.current_knots <= 2.5: filter: boom_type == "type_3_offshore" // Jurisdiction routing: if buyer.facility_type IN ["marine_terminal", "tanker_dock", "bunkering"]: filter: jurisdiction IN ["uscg", "dual"] // 33 CFR 154 applies note: "USCG 33 CFR 154 Subpart F FRP required for MTR facilities" else if buyer.facility_type IN ["refinery", "tank_farm", "industrial_facility"]: filter: jurisdiction IN ["epa", "dual"] // 40 CFR 112 applies note: "EPA 40 CFR 112.20/21 FRP or 112.7 SPCC required for NTR facilities" if product.type IN ["universal", "general"] AND buyer.waterway == true: flag: "Universal/cellulose absorbents sink on water surface — only hydrophobic polypropylene oil-only absorbents suitable for waterway deployment per OPA 90 FRP requirements"

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Shopify Spill Kit Schema — OPA 90 Marine Facility Response Plan (FRP), USCG vs EPA Jurisdiction, Boom vs Absorbent for Waterway Oil Containment, spill_kit.* Namespace