Onsite Hypochlorous Acid Generation in Cruise Operations. Logistics, cost, the evidence, and the 2025 VSP Standards. Nine pages. September 2026, revision 2.
Written for cruise operators, fleet technical managers and public health officers. It treats the cruise case as a logistics problem first — a vessel is a closed system that cannot take a delivery — and works through the evidence, the numbers and the trade-offs from there.
What is inside
| Section | What it covers |
|---|---|
| 1. The operational problem | Why a ship is the hardest version of this: no mid-ocean delivery, budgeted weight and volume, hazardous-goods rules, a corrosive and continuously occupied environment, lumpy demand. |
| 2. What a generator is | The device position, what it produces, and the two failure modes onsite generation removes — running out, and mis-diluting. |
| 3. The research on HOCl | Microbac Laboratories virucidal hard-surface testing against murine norovirus MNV-G at 50 ppm, one minute, at pH 5 and pH 8, with the conditions and the limits stated. |
| 4. Where documented claims come from | HOCl-AS200, EPA Reg. No. 101112-1, with the accepted label facts and the full 21-organism list. |
| 5. Food contact | What FCN 1811 actually covers, and why 60 ppm and 200 ppm come from two different authorities. |
| 6. The 2025 VSP Standards | The supersession of the 2018 Operations Manual, the surveillance thresholds, and the changes that catch operators out. |
| 7. The cost model | The Norwegian Cruise Line reference figures, scaled per berth, with three caveats on the page. |
| 8. What it does not fix | The spare-parts supply chain, the feed water prerequisite, the Legionella position, and why it is not a substitute for a VSP programme. |
| 9. Questions to ask any supplier | Eight questions, including ones to ask us. Several are ones our competitors will struggle with. |
What this paper claims, and what it does not
The cover of the paper carries this in full. In short: an EcoloxTech system is a device that produces a hypochlorous acid solution on site, it is regulated by the EPA as a device, and we make no efficacy claims for it or for the solution it produces. Laboratory and published findings are reported as findings about hypochlorous acid under the conditions stated, attributed to the laboratory that produced them. Documented disinfection claims come from HOCl-AS200 (EPA Reg. No. 101112-1) used according to its label. Cost figures are our own data, labelled as such. We do not claim that our equipment prevents outbreaks.
About revision 2
This edition supersedes the April 2026 white paper. The earlier version attributed efficacy claims to our generators, described FCN 1811 as an FDA clearance, characterised the research library as norovirus evidence, and quoted a section of the VSP Standards we have not been able to verify in the primary text. Those statements have been removed or corrected. If you hold a copy of the April 2026 edition, please replace it with this one.
Related reading
The deployment behind the cost model is written up as the Norwegian Cruise Line case study. The sector programme is at cruise and marine, with companion pages on pathogens and compliance and audits. The underlying economics are at ROI and savings, and the laboratory reports referenced in section 3 are in the research library.