HOW TO LIST A NEW PRODUCT ON THE NATIONAL OIL AND HAZARDOUS POLLUTION SUBPART J PRODUCT SCHEDULE

摘要

In light of the recently updated U.S. Coast Guard Regulation for Vessel Response Plans, which include requirements for vessel dispersant response capabilities and with the recent expansion of many U.S. Coastal Dispersant Preauthorization Zones, it is important that both alternative oil spill chemical countermeasure product manufacturers and oil spill responders have an understanding of the National Oil and Hazardous Substance Pollution, Subpart J Product Schedule (NCP Product Schedule). The NCP Product Schedule lists alternative chemical countermeasures which may be used in oil spills in the United States if authorized by a Federal On-Scene Coordinator with consultation from the Regional Response Team including local Trustees. The product types currently listed on the NCP Product Schedule include dispersants, surface washing agents, bioremediation agents and miscellaneous oil spill control agents. Sorbents are also defined in the NCP Product Schedule, but they may or may not be required to be listed on the NCP Product Schedule depending upon their composition. The unauthorized use of oil spill chemical countermeasure products listed on the NCP Product Schedule on an on water oil spill is a violation of the Clean Water Act. In addition, the use of chemical products that are not listed on the NCP Product Schedule on oil spills on waters of the United States is also a violation of the Clean Water Act. Before a chemical countermeasure product is used during an oil spill in waters of the United States, new products must meet the data requirements stated in Subpart J of the NCP Product Schedule regulation (40 Code of Federal Regulations Part 300.900). The United States Environmental Protection Agency (EPA) maintains and updates the NCP Product Schedule. The EPA reviews the required data packages for new products and regularly updates the NCP Product Schedule and Technical Notebook on the NCP Product Schedule website (www.epa.govlemergencies). This paper and poster will outline the steps to list a new product and provide background information on the NCP Product Schedule.