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What goes wrong

It leaked in the locker

On this page11
The locker leak becomes a pumped discharge. That is the chain to break.

The container moved all season

A locker is a tumbler. A closure that seals on a bench works loose over weeks of motion, and nobody opens the locker to check.

The liner failed before the cap did

An oil against the wrong liner migrates slowly. The cap is still tight and there is a film under the container, which is the commonest version of this failure.

It went through a freeze and a thaw

Winter layup, an unheated shed, and a container that contracted and expanded. Both the bottle and the closure move, and they do not move together.

The bottle rolled

A round bottle in a cockpit or on a side deck. It goes under a seat, over the side, or under a foot, and the F style and oval sections exist because of it.

It ended up in the bilge

Which is the step that turns a contained mess into a discharge. The bilge pump goes over the side and the sheen standard has no de minimis.

The spill was small and still over the line

A discharge that causes "a film or sheen upon... the surface of the water" is a discharge in quantities that may be harmful. Small is not a defense because no quantity is named.

Nobody chocked it

Which is not a packaging failure and is the cheapest fix available: a tray, a chock and a stowage position above the bilge. The container is half the system and the stowage is the other half.

The decant spilled on the dock

A yard moving oil from a gallon into a working bottle, over water. "Adjoining shorelines" is in the clause, so a dock spill is reached too.

The cap was cross-threaded in the wind

On a hull, kneeling, with wax on both hands. A closure that is forgiving to re-seat is worth more here than one that seals marginally better when seated perfectly.

Test it as a season, not as a fill

Filled, sealed, on its side, shaken daily, through a freeze, for six months, then opened by somebody with cold hands. That is the duty cycle and every failure above appears in it.

References

40 CFR 110.3, discharge of oil in such quantities as "may be harmful" under section 311(b)(4) of the Clean Water Act. Such discharges are those that "(a) Violate applicable water quality standards" or "(b) Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines". law.cornell.edu
The Davis Pack Supply catalog, measured 18 October 2026. The marine shelf is 880 rows: 354 containers and 526 closures. 50 mL to 3,785 mL with a median of 237; 101 containers over a pint, 45 over a quart, 13 over a gallon and none over five gallons. 166 HDPE, 117 PET, 71 PP, and no glass or metal at all. 163 jars, 159 bottles, 19 tubs and pails, 12 jugs, 1 tube. 136 white, 83 natural, 54 clear, 39 black, 20 amber. Closures: 368 continuous thread, 39 child resistant, 26 dome lids, 26 spouted, 18 flip top, 11 liners and sealing discs, 10 round tubs, 7 specialty, 7 buttress, 6 phenolic, 2 trigger sprayers.
Written from 40 CFR 110.3 and 33 CFR 155.450, and from the catalog as it stood on 18 October 2026. The Vessel General Permit, the Vessel Incidental Discharge Act and in-water hull cleaning rules are named and not summarized; state and local rules on boat washing and marina discharge vary by water body. Whether a specific product may be used in the water is a question about that product and that water.