Dispersant regulation can vary widely between countries, and this is reflected in how products are approved for use. Some regulators maintain national lists of approved dispersants, others recognise approvals from external authorities, and some reference products via their National Oil Spill Contingency Plan (NOSCP). In some cases, no formal list exists at all.
This article outlines the main approval models used globally, their advantages and limitations, and explains why understanding approvals is crucial for effective oil spill preparedness.
Why do countries hold pre-approved lists
Pre‑approved dispersant lists allow regulators to confirm in advance that products meet defined standards for effectiveness, toxicity and, where required biodegradability. Having this assurance in place accelerates the decision-making process during an incident which is of particular importance with dispersant use which often only has a limited window of opportunity for effective application.
In this context, pre-approval refers to a product that have been assessed and is acceptable in principle for use within a country’s waters. It does not refer to situations where an operator has been authorised to spray dispersant under certain scenarios without first consulting the regulator.
Inclusion on an approved list does not imply a preference for dispersant use. It simply means that, where a Net Environmental Benefit Analysis (NEBA) supports it, the product has met the regulators baseline performance criteria and can be considered for use.
How countries approve dispersants
Many countries that consider dispersant application for use have established approval processes to ensure that any products applied during a response meet their pre-established criteria. Because there are no international agreements on how countries should do this, countries have adopted a variety of different approaches:
National approval lists with defined testing
Some countries operate their own approval process that requires the manufacturer to submit test data on toxicity, effectiveness, biodegradability and physical characteristics. Approved lists are often published online and typically include an expiry date, after which re-approval is required. Countries following this approach include UK, USA, Brazil, France and Australia.
A key advantage of this approach is control. Regulators can specify:
- Test protocols and performance thresholds
- Oils and species representative of local conditions
- Operational constraints such as viscosity storage conditions.
From a technical perspective, this is considered good practice. However, it does introduce risk. If a manufacturer withdraws support for a product, or does not re-apply for re-approval, that dispersant can fall off the list regardless of existing and usable stockpiles.
This risk became clear in 2022 when ChampionX (now SLB) announced the discontinuation of COREXIT products and withdrew regulatory support. As a result, COREXIT fell off many approval lists, significantly reducing global dispersant availability despite large remaining stockpiles.
These regimes also place a substantial administrative burden on regulators to maintain the list, review submissions and keep lists up to date.
Basing approvals on other countries lists
To reduce administrative burden, some countries base dispersant approvals on established external testing regimes. A good example is the ROPME Sea Area, where the eight member states permit dispersants that appear on at least two of the following lists: the UK, US or Cedre (France).
This ensures approved dispersants have passed a formal, transparent testing regime and that lists remain current.
However, this approach is not without drawbacks. If one of the reference authorities removes a product, that change can cascade automatically into countries that rely on its approval, potentially making a dispersant unavailable even where substantial in‑country, regional or global stockpiles exist. Some jurisdictions address this by allowing exemptions for specific products.
Another limitation is that the adopted tests are not tailored to local environmental conditions or species. While acceptable for many regimes, this reduces the ability to align approval criteria with local ecological sensitivities.
Fixed lists embedded in an NOSCP
In some countries, permitted dispersants are listed directly in their National Oil Spill Contingency Plans (NOSCP). This creates a fixed, easily understood list that remains under national control and avoids the need for a separate testing programme.
The main drawback is that these lists can be difficult to keep current, particularly as NOSCPs are often only reviewed periodically. Products that are no longer available may remain listed after being superseded, while newly available products may not be included.
There is also a risk that products on the list may not have been subject to a robust or transparent testing regime meaning their effectiveness or toxicity profile may not meet modern standards.
However, when the list is well considered and based upon analysis of publicly available testing data, this approach can provide IMTs and responders with a clear and unambiguous understanding of what is permitted.
What testing is done for a dispersant to be approved?
Where countries manage their own approval lists, manufacturers are often required to submit test data to show that a product is safe, effective and within toxicity limits. These requirements typically cover:
- Effectiveness
- Ecotoxicology
- Biodegradability
- Physical properties
These tests give regulators the confidence that approved dispersants meet defined performance and toxicity criteria. However, approval does not imply that dispersants are always the right choice. It simply means that, if NEBA indicates a net benefit, the product has met the regulators’ predefined criteria for use. For more information about Net Environmental Benefit Analysis (NEBA), read the article.
Why dispersant approvals matter for planning
Dispersants are a key component of oil spill preparedness and, where NEBA supports their use, can significantly reduce environmental impact. For that reason, large global stockpiles are maintained so they can be accessed and deployed at short notice when needed. Understanding which dispersants can be used in areas of risk is imperative for well-informed oil spill preparedness.
The Global Dispersant Stockpile (GDS), held by OSRL on behalf of industry comprises 5,000m3 spit across three dispersant types – Corexit 9500A, Slickgone NS and Finasol OSR 52. However, unless all three of these dispersants are approved in a given jurisdiction, the total volume of dispersant available for use may be significantly reduced.
This has practical implications in a large-scale incident, where access to the full stockpile may be necessary. For operators, understanding which dispersants can be used in their region is therefore a fundamental element of preparedness.
The OSRL approvals database
To support more informed preparedness planning, OSRL has developed a global Dispersant Approvals Database that brings together country‑specific approval information for the dispersants held in OSRL’s stockpiles. This is written about in more detail in the article “Introducing OSRLs Dispersant Approval Database”.
Closing thoughts
Understanding how dispersants are approved, and the implications of this on response capability, is essential for effective oil spill response planning. Approval processes shape which products can be used and how much dispersant may be available in a largescale incident.
