Vessel sanitation is inspected unannounced and scored in public, which makes the paperwork a commercial matter as well as a regulatory one. A chemistry does not pass an inspection; a programme does. This page maps onsite hypochlorous acid into the framework a vessel actually works to, and is explicit about what changed in 2025.
About claims on this page
EcoloxTech generators produce a hypochlorous acid solution on site. They are regulated by the EPA as devices, are not registered disinfectants, and we make no efficacy claims for them or for the solution they produce. The only EcoloxTech product with disinfection claims is HOCl-AS200 (EPA Reg. No. 101112-1), used according to its label. Research cited here describes published studies of hypochlorous acid and electrolysed water under their own test conditions; it is not a claim for any product.
The rules changed in 2025
The CDC Vessel Sanitation Program’s 2025 Environmental Public Health Standards replaced the 2018 Operations Manual. A great deal of supplier material still quotes the 2018 manual, including set points and sampling frequencies that have since moved. Work from the current Standards, and check any figure you were given against them before it goes into a procedure.
What changed in 2025
The CDC Vessel Sanitation Program replaced the 2018 Operations Manual with the 2025 Environmental Public Health Standards. This was a rewrite, not a reissue, and the practical consequence is that a good deal of circulating guidance — supplier sheets, internal procedures written years ago, training decks — now quotes a superseded document.
Three changes shape day-to-day work:
- Continuous water monitoring. Electronic data loggers must record halogen levels for at least 16 hours in each 24-hour period — a plant-monitoring duty rather than a spot-check.
- A tighter Legionella regime. Quarterly sampling for spa pools, whirlpool spas and heated jetted tubs, extendable to six-monthly after 24 months of negative results, with jetted tubs drained daily.
- Completeness of surveillance records. Every field of the AGE surveillance log completed, including zero and not-applicable entries.
The first practical task for most operators is an audit of their own documents against the current Standards, looking for figures and frequencies inherited from the old manual. That is unglamorous and it is where findings come from.
AGE surveillance, and the two thresholds
Acute gastroenteritis surveillance is the backbone of the regime. Cases among passengers and crew are logged and reported on a fixed schedule.
| Stage | What happens |
|---|---|
| Case definition | Three or more loose stools in a 24-hour period, or vomiting plus another symptom — diarrhoea, myalgia, headache, abdominal cramps or fever |
| 24-hour report | Submitted when the vessel is 36 to 24 hours from a US port |
| 4-hour update | Submitted when four or more hours out, if cases have increased but remain below 2% |
| 2% or more of passengers or crew | VSP provides support and technical assistance |
| 3% or more of passengers or crew | Classified as an outbreak; investigation and response follow |
Two operational points follow. The log has to be complete and contemporaneous, including nil returns, because an incomplete log is a finding in its own right regardless of how few cases there were. And the thresholds are the reason sanitation supply has to be sized for the escalated state: the decisions that keep a voyage below 3% are made in hours, not days.
Water systems
Potable water, recreational water facilities and their monitoring sit with the technical department under the ship’s water-management plan and the current Standards. We do not print halogen set points here, for two reasons: they belong to the Standards edition in force, and a figure lifted from a supplier page into a shipboard procedure is exactly the error an inspection finds. Get them from the Standards and from your water-management plan.
What belongs in the sanitation programme’s records is the boundary: which systems are plant-managed, who owns each one, and how a housekeeping or galley task that draws on that water is verified.
Chemical control aboard
- Approved chemicals list naming the generated solution, any registered products and every detergent, with the area each is used in.
- SDSs available where products are used — including brine or acid inputs to the generator, which are the hazardous part of an onsite system.
- Secondary containers labelled with contents; closed, opaque containers for stored solution; white HDPE for any secondary container of HOCl-AS200, per its label.
- Segregation of incompatibles — acids and ammonia away from chlorine chemistry, with stowage that holds in a seaway.
- Change control on generator set points, authorised and recorded, so a night-shift adjustment does not become the new normal.
The records an inspector will ask for
- Cleaning and sanitation procedures by area, with set point, method, contact time and frequency.
- Strength and pH logs for the outlets serving those areas, with a defined target range.
- AGE surveillance log, complete and current, including nil entries.
- Outbreak escalation procedure, and evidence it has been exercised.
- Vomiting-incident procedure and incident records.
- Isolation cabin protocol and terminal cleaning records.
- Training records by name and date, including at crew change.
- Maintenance records for the generator, softener and filters.
- Product documentation: generator manual, SDSs, HOCl-AS200 label where used.
- Water-management plan and its monitoring records, held by the responsible department.
The HOCl Compliance Pack has printable versions of several of these, written for shoreside use but adaptable aboard.
Inspection day
Expect an unannounced arrival and a route that follows the risk: galley and buffet, then water systems and RWFs, then public areas, toilets and accommodation, with the AGE log and the surveillance records reviewed alongside. Expect an inspector to pick one task and follow it through — the procedure, the solution at the outlet, the log for the past week, the training record of the crew member on duty, and one corrective action with its outcome.
The preparation that helps is not a scramble. It is having the documents current against the 2025 Standards, the logs honest, the test kits where the work is, and crew who can describe what they do without reciting a script. Inspectors are experienced at spotting the difference.
What you can say
Under FIFRA a claim made “by labelling or otherwise” — on a website, a spec sheet or a customer handout — can make a product an unregistered pesticide, and the EPA’s acceptance letter of 10 December 2025 requires that website claims for HOCl-AS200 not differ substantially from its accepted label. Describe the generator by what it produces — free available chlorine, pH, output rate — and reserve organism claims for the registered product used per label. Staying compliant with HOCl has a table of acceptable and unacceptable phrasing.
Vessels outside VSP
VSP applies to vessels on international voyages calling at US ports. Ships operating elsewhere work to their flag state and port states, and to applicable EU and WHO ship-sanitation guidance, which cover similar ground in different language. Operators running mixed itineraries generally find it simpler to hold one standard across the fleet — usually the most demanding one — than to maintain two sets of procedures for crews who rotate between hulls.
Auditing your own documents against the 2025 Standards
The highest-value compliance task available to most operators right now costs nothing but time: read your own procedures against the Standards in force and find what is inherited.
| Where to look | What to look for |
|---|---|
| Cleaning and sanitation procedures | Set points, contact times and frequencies traceable to the 2018 manual or to a supplier sheet of that era |
| Water-management plan | Monitoring arrangements written before the continuous-logging expectation, and RWF sampling frequencies predating the 2025 Legionella regime |
| AGE surveillance forms | Fields that allow blanks where completeness is now expected, including nil and not-applicable entries |
| Training material | Decks and handouts quoting the superseded manual by name |
| Supplier documentation | Spec sheets and claim language that reference guidance no longer in force |
| Fleet consistency | Sister ships running different versions of the same procedure after independent updates |
Do it once, properly, across a class rather than a hull, and record the review itself — being able to show an inspector a dated document review against the current Standards is worth more than any individual correction it produced.
Frequently asked questions
Are we still allowed to use our 2018-based procedures?
Your procedures must reflect the Standards in force. Audit them against the 2025 Standards and update anything inherited — figures, frequencies and record formats.
Does a generator help our inspection score?
Not by existing. What helps is a programme that is executed consistently and documented honestly, which is easier when solution is available everywhere at a controlled strength.
Who owns water-system compliance?
The technical department, under the water-management plan. Keep that boundary explicit in your documents so nothing falls between departments.
What if cases rise mid-voyage?
Follow the reporting schedule and escalate the cleaning protocol. The thresholds are 2% for VSP support and 3% for outbreak classification, applied to passengers or crew.
Do we need a registered disinfectant aboard?
Wherever a protocol, flag state or medical procedure specifies one, yes.