Bio Lubes or Environmentally Acceptable Lubricants (EALs) for Marine Vessels
August 5, 2014
There is no doubt that the Marine Industry is having its share in polluting the waters. The 2010 Etkin study states that through operational discharges including stern tube leakage from commercial shipping globally, it is estimated that between 37 and 61 million liters of marine lubricant products / oil was added into the marine port waters on an annual basis.
Certainly every one of us agrees that this is a huge threat to our environment. But how do greases and marine lubricant products get into the water? To name a few, through Stern Tubes, Thruster bearings, Stabilizers, Rudder bearings, Azimuth thrusters, Propulsion Pod Lubrication, Wire Ropes, Mechanical equipment like dredges, gabs …
That is why the US Environmental Protection Agency (EPA) makes use of the Vessel General Permit (VGP) to regulate and control discharges to water made by vessels in US waters as part of their normal operation. The 2013 revised VGP is introducing EALs (Environmentally Acceptable Lubricants) in all applications that have potential for an “oil to sea” interface, unless technically infeasible.
The new rules are covering territories within 3 miles of the US coast for all states including the Great Lakes. And it includes Puerto Rico, Guam, American Samoa, the Virgin Islands, the Commonwealth of the Northern Mariana Island and the Pacific Islands. The vessels in scope are 24 meters and greater in length, including auxiliary crafts like lifeboats onboard the same. When it comes to the vessels in scope, there are only a few exceptions like vessels of the US Armed Forces.
Does this mean that most of our customers calling US waters must be compliant with EPA and lubricate their equipment with EALs?
The answer is yes, except it is technically in-feasible. But what doe in-feasible mean?
- No EAL Products are approved for use in a given application that meet manufacturer (OEM) specification for that equipment
- Products which come pre lubricated (e.g. wire ropes) and have no available alternatives manufactured with EALs
- Products meeting a OEM specifications are not available within any port in which the vessel calls
- Change over and use of EAL must wait until vessel’s next scheduled dry docking
- The US Coast Guard will carry out checks of vessel compliance. So how do you prove that you are compliant?
- Keep Material Safety Data Sheet on board
- Document whether EALs are registered under a labelling program
If a vessel is unable to use EAL because of technically infeasible, the owner / operator must:
- Explain why they cannot do so in their vessel recordkeeping documentation
- Note the use of a non-environmentally acceptable lubricant to EPA in vessels Annual Report
Probably the biggest challenge for the customers is to where can they purchase EALs and if they can buy from any brand any EAL? There are more than 100 OEMs for equipment and seals that are in scope for the VGP
- EAL products currently available do not necessarily comply with VGP requirements, meaning that reformulation of these EAL products may be required
- It is likely that reformulated EAL products will have to be submitted for OEM approval. This is a time consuming process
- Currently there are several EAL products available which claim to be VGP compliant, but are missing the OEM approval. This is specially valid for Seals like Sterntube or hydraulic equipment
So the question remains how ship owners / operators can choose the right EAL for their equipment. Being a managing director to an authorized shell marine lubricants distributor company in the UAE, Mr. Swen Sauerberg stated the following points:
- Don’t believe at 1st glance what you get offered
- You need to check that the product offered is VGP compliant and has the OEM approval
- If you don’t see the OEM approval, you can actually damage for instance important seals like your stern tube or hydraulic cylinders
- Consult the company that you really trust. Someone who understands the US requirements and the products available in the market with OEM approval
- And the other thing is availability. EALs are still not in every port available. You need to understand where you need the product ( ports ) and check with your supplier on beforehand about availability
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