What are Environmentally Acceptable Lubricants (EALs) and the key characteristics required to be compliant Vessel General Permit (VGP) 2013?

July 4, 2018

Environmentally Acceptable Lubricants are defined by the United States Environmental Protection Agency (EPA) as lubricants that minimize their likely adverse consequences in the aquatic environment, compared to conventional lubricants and have also been demonstrated to meet standards for these three key characteristics per the EPA 2013 VGP Appendix A:

  • Biodegradable – biodegrading into carbon dioxide and water by ≥ 60% or more within 28 days (according to OECD 301A-F or ASTM D7373 methods)
  • Minimally toxic – causing only a light impact on the aquatic environment (LC50> 100mg/L for lubricants and LC50>1000mg/L)
  • Not bioaccumulative – must have a low propensity to bioaccumulate in organisms

The EPA recognizes four types of EALs:

  • Hydraulic Environmental Triglycerides (HETG)
  • Hydraulic Environmental Polyalkylene Glycols (HEPG)
  • Hydraulic Environmental Synthetic Esters (HEES)
  • Hydraulic Environmental PAO (Polyalphaolefins) and other Synthetic Hydrocarbon Products (HEPR)

If a product meets the above criteria, it is approved by the EPA and self-certified as VGP 2013 compliant. The EPA does not certify or recommend EALs.


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