While leaks play a major role in water pollution, unplanned discharges are also a serious problem. Under the EPA’s 2013 Vessel General Permit (VGP), all ships larger than 79 feet must use Environmentally Acceptable Lubricants in oil-to-sea interfaces when in the three Nautical Mile limit and in the Great Lakes unless technically infeasible. These regulations include vessel discharges such as oil, waste, water, and runoff. The permit also requires any above water line hull cleaning or deck wash downs resulting in discharge to be conducted with ‘minimally toxic, phosphate-free and biodegradable’ cleaners and detergents.
The 2013 VGP remains in effect until the 2018 Vessel Incident Discharge Act takes its place likely in the 2022-23 timeframe.
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.
Barges, cargo ships, container ships, commercial fishing vessels, cruise ships, emergency response vessels, mobile offshore drilling units, oil tankers, petroleum tankers, ROVs and more are regulated by the 2013 VGP.
If a product meets the following criteria, it is considered technically feasible:
One or more OEM has approved EALs for use
- EALs are available for pre-lubricated products
- EALs are available in Vessel’s ports of call
- Next dry dock has occurred
