What is the 2013 VGP?

The Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels (VGP) is a US licence which works alongside the Clean Water Act. It serves to protect the US Coastline and inland waters by regulating discharge from vessels entering these areas.

The first VGP was issued in December 2008; however as of December 19th 2013, a second more demanding version has become effective. It is important that all vessel operators are familiar with this document as the consequences of failing to follow the regulations include fines and imprisonment. One of the most significant updates between the two versions of the VGP was the requirement of vessel operators to use Environmentally Acceptable Lubricants (EALs) in all oil-to-sea interfaces.

What is an environmentally acceptable lubricant (EAL)?

In simple terms, all EALs have been formulated to ensure that their impact on the environment is significantly reduced when compared to that of a traditional lubricant. The VGP states that lubricants must meet stringent testing specifications against three main criterion in order to be classified as an EAL; these are biodegradability, eco-toxicity and bioaccumulation.

Biodegradability

With regards to the VGP, this is a measure of how quickly a lubricant would break down in to its harmless constituents if released into the sea. In the instance of accidental discharge, a biodegradable lubricant will not remain in the environment for long periods of time which limits the damage caused.

Lubricant manufacturers must ensure that all EALs are tested to and pass internationally standardised biodegradability tests. Ideally these tests should be performed by an external accredited laboratory to ensure compliance.

Eco-toxicity

This is a measure of how poisonous a lubricant would be if released into the sea. As described by the VGP, minimally toxic lubricants have little to no impact on marine life.

Lubricant manufacturers must ensure that all EALs are tested to and pass internationally standardised eco-toxicity tests. Ideally these tests should be performed by an external accredited laboratory to ensure compliance.

Bioaccumulation

Even low eco-toxicity chemicals can be dangerous when consumed by animals; this is due to a process called bio-accumulation. When a bio-accumulative chemical is eaten, it will begin to build up in living tissues and cannot be excreted. At the bottom of the food chain this does not generally cause a problem, since the chemical has low eco-toxicity. However, as the chemical moves up the food chain, it increases in concentration to dangerous levels and can cause significant damage.

Lubricant manufacturers must ensure that all EALs are tested to and pass internationally standardised bio-accumulation tests. Ideally these tests should be performed by an external accredited laboratory to ensure compliance.

All components MUST be tested

The VGP is the one of the most stringent environmental regulations for lubricants ever issued and is driving forward the requirement for new cleaner lubricant technologies. Not only does the VGP state that all EALs must be tested to the standards described above, but all components and additives must pass these standards too. This ensures that when the EAL biodegrades, the components are also safe for the environment.

Vessel operators should review the “How do you prove that you are using an EAL?” section for further clarification on EAL requirements.

Who does the VGP apply to?

Vessels which are subject to the requirements of the VGP and therefore are required to use Environmentally Acceptable Lubricants are:

• All commercial vessels which are 79 feet (24.08 metres) or greater in length
• Vessels operating in a capacity as a means of transportation.
• Vessels that have discharges incidental to their normal operations.
• Vessels which enter within three nautical miles of US coastlines and inland waters.

Vessel types which could match the criteria

Commercial fishing vessels, cruise ships, ferries, barges, mobile offshore drilling units, oil tankers, petroleum tankers, bulk carriers, cargo ships, container ships, other cargo freighters, refrigerant ships, research vessels, emergency response vessels, ROV Survey Vessels.

Vessel types which are not subject to the VGP requirements

Recreational vessels and Armed Forces vessels.

N.B. Certain states in the USA have additional / modified regulations, it is advisable to check States’ Certifications in order to ensure your compliance, however they do not generally effect lubrication.

What is the impact of the VGP on lubricant usage?

Effective 19th December 2013, all vessels which are subject to the requirements of the VGP are required to use Environmentally Acceptable Lubricants in all oil-to-sea interfaces, including:

• Wire Ropes
• ROV Umbilicals
• Mechanical Equipment Subject to Immersion
• Controllable Pitch Propellers
• Thruster Hydraulic Fluids
• Paddle Wheel Propulsions
• Stern Tubes
• Thruster Bearings
• Stabilisers
• Rudder Bearings
• Azimuth Thrusters
• Propulsion Pods

When must the switch to EALS be completed?

All vessels must switch to EALs for all oil-to-sea interfaces during their next dry dock.

How is compliance checked and enforced?

Prior to February 2011, the roll of the US Coast Guard (USCG) was primarily educational. However a Memorandum of Understanding was signed with the US Environment Protection Agency (EPA), which facilitates the USCG in reporting VGP non-conformances to the EPA.

• The USCG will check for compliance with the VGP during routine inspections of US-flagged vessels and during Port State Control exams of non-US vessels.
• Evidence of non-compliance may lead to more detailed examinations.
• Detected deficiencies will be reported to the EPA for enforcement.
• The EPA is directly responsible for legal action, which may include administrative orders, administrative penalties or judicial action.
• First-time violations may lead to $10,000 fines (per violation) or imprisonment for up to two years.
• Further violations may lead to $20,000 fines (per violation) or imprisonment for up to four years.
• Falsification of documentation can lead to more severe punishment.

Please review section “1.4 Permit Compliance” of the VGP for more details.

What documentation is required?

In order to comply with the VGP, a number of documents must be completed, many of which make reference to lubricants; these include:

• The Notice of Intent (NoI) – Section D refers to Discharge. If lubricants are used on your vessel in oil-to-sea interfaces, it must be marked in this section.
• VGP Annual Report -Question 5 refers directly to Environmentally Acceptable Lubricants and requests information on lubricants used.
• If EALs have not been used, an explanation is required.
• Under certain circumstances, a non-conformance can be excused for certain reasons. This might be that it is technically infeasible or that the vessel has not dry docked since 19th December 2013.

What records do you need to keep?

Section 4.2 of the VGP states that vessels must keep records onboard that include the Technical Data Sheets for all EALs used in Oil-to-Sea interfaces in order to prove compliance with the permit.

How do you prove that you are using an EAL?

It is the responsibility of the lubricant manufacturer to ensure that VGP compliant lubricants meet the definition of an Environmentally Acceptable Lubricant (EAL). An EAL must meet stringent biodegradability, eco-toxicity and bioaccumulation standards. A lubricant manufacturer’s statement of “meets the requirements of the VGP” is not sufficient evidence that the lubricant meets the strict definition of an EAL. If this is the case, operators are urged to seek further clarification to ensure full compliance.

The testing required to prove that a lubricant is Environmentally Acceptable is rigorous and expensive. For that reason, a lubricant which is fully compliant with the guidelines will be clearly marked as being VGP compliant.

• Independent test data for the EAL will be available from the manufacturer, ensure that this includes test data on the components too.
• Technical and Safety Data Sheets are likely to carry a statement which clearly states that the product is VGP and EAL compliant.
• It is likely to state on the product label that the lubricant is VGP and EAL compliant.
• The VGP states that a number of labelling programs are acceptable in determining whether or not a product is an EAL. The standards include European Eco-Label, Nordic Swan, Swedish Standards, Design for the Environment and Blue Angel.

Using a lubricant with all or most of the information provided above should be adequate evidence for inspecting authorities, ensuring that they will be happy with your compliance to the VGP’s EAL requirements.

Does being an EAL reduce the performance in extreme temperatures?

No! BIOGEN WIRESHIELD has been tested alongside traditional greases as well as EALs and is equivalent to or outperforms them all.

Does BIOGEN WIRESHIELD perform in extreme temperatures?

Yes! The drop point for BIOGEN WIRESHIELD is greater than 250 Centigrade thanks to a unique high temperature base fluid, it is therefore perfectly suited for use in wire rope applications where heave compensation devices utilised. In these situation, temperatures of up to 120 Centigrade are not uncommon, which are well within the limits of BIOGEN WIRESHIELD.

At the other end of the scale, BIOGEN WIRESHIELD will continue to perform down to -30 Centigrade, making it suitable for use in Arctic conditions.

Since BIOGEN WIRESHIELD is biodegradable, will relubrication be more frequesnt?

Not necessarily.

Relubrication is application specific and should be monitored as with all other lubricants.

Is BIOGEN WIRESHIELD compatible with other lubricants?

Best practice in all cases is to remove previous lubricant however testing does not show any negative interactions.

What is the shelf life of BIOGEN WIRESHIELD?

It is a common misconception that biodegradable lubricants have a lower shelf life than traditional greases and oils. BIOGEN WIRESHIELD has a shelf life of three years, the same as all other ROCOL wire rope lubricants.