US EPA finally launches Permit

New US laws mean 'biodegradable' lubricants must be used where they come into contact with the sea.

The latest rules appear under the new Vessel General Permit (VGP) from the US Environmental Protection Agency (EPA). VGP requirements relate to discharges during normal operation of non-recreational, non-military vessels of a specific size and include extensive regulation on inspections, monitoring, reporting and record-keeping.

In the content relating to the use of marine lubricants, there is one extremely significant new piece of legislation which states: "All vessels must use an Environmentally Acceptable Lubricant (EAL) in all oil-to-sea interfaces, unless technically infeasible."  The implication is that any areas of a ship which come into direct contact with the sea or are immersed, must use 'biodegradable' lubes.

This rule not only applies to the more obvious propulsion systems, such as stern tubes, rudder and thruster bearings, stabilisers and Azimuth thrusters; but also wire rope and other mechanical equipment that may come into contact with the water at some point during operation.

After an initial five-month delay and detailed consultation which garnered thousands of comments from interested parties, the date of enforcement of the new VGP has now been set for 19th December 2013, leaving vessel owners, operators and crew little time to prepare for the latest regulations. There is also little doubt that the EPA will police the new permits vigorously - recent cases of non-compliance and document falsification cost one marine company more than $10m in fines, according to reports.