It leaked in the locker
On this page11
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.