IT'S MORE THAN JUST OIL. IT'S LIQUID ENGINEERING.

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  4. VESSEL GENERAL PERMIT

VESSEL GENERAL PERMIT

Rescue vessel at sea
Mandatory use of ‘Environmentally Acceptable Lubricants’ in US waters from December 2013

 

The Environmental Protection Agency (EPA) in the USA has published a new version of the Vessel General Permit (VGP), which has been in force since 19th December 2013. From this date, all ‘vessels’ calling in the ‘waters of the United States’ must:

  • Obtain a Vessel General Permit (VGP)
  • Use Environmentally Acceptable Lubricants in all oil-to-sea interfaces, unless technically infeasible

A VGP is required for MODUs (Mobile Offshore Drilling Units) such as semi-submersible drilling rigs and drill ships.

WHY THE CHANGE?

The EPA’s recognition of the impact that lubricant discharges (not accidental spills) have on the marine ecosystem has motivated the change. The 2013 VGP mandates the use of EALs for all applications where lubricants are likely to enter the sea, not mineral oils, as EALs can offer a significantly reduced environmental impact across all applications.

For any additional information please consult your local Castrol representative.

1. http://www.epa.gov/npdes/pubs/vgp_permit2013.pdf
2. If products do not have one of the labels above, they will be classified as environmentally acceptable if meeting the criteria set by EPA for biodegradation, bioaccumulation, and toxicity:

  • To be classified as “biodegradable” a lubricant must contain at least 75% (w/w) of a constituent substance or constituent substances (only stated substances present above 0.10% shall be assessed) that each demonstrate either the removal of at least 70% of dissolved organic carbon, production of at least 60% of the theoretical carbon dioxide, or consumption of at least 60% of the theoretical oxygen demand within 28 days. Acceptable test methods to demonstrate biodegradability include: Organization for Economic Co-operation and Development (OECD) Test Guidelines 301 A-F, 306 (marine), and 310, ASTM 5864, ASTM D-7373, OCSPP Harmonized Guideline 835.3110, and International Organization for Standardization 14593:1999. For lubricant formulations, the 10% (w/w) of the formulation that need not meet the above biodegradability requirements, up to 5% (w/w) may be non-biodegradable (but not bioaccumulative) while the remainder must be inherently biodegradable. For grease formulations, the 25% (w/w) of the formulation that need not meet the above biodegradability requirement, the constituent substances may be either inherently biodegradable or non-biodegradable, but may not be bioaccumulative. Acceptable test methods to demonstrate inherent biodegradability include: OECD Test Guidelines 302C (>70% biodegradation after 28 days) or OECD Test Guidelines 301 A-F (>20% but <60% biodegradation after 28 days).
  • “Not bioaccumulative” means the lubricant’s partition coefficient in the marine environment is log KOW <3 or >7 using test methods OECD 117 and 107 or its molecular mass > 800 Daltons.
  • “Minimally-toxic” means a substance must pass either acute (short term) or chronic (long term) toxicity tests. Acute tests must be carried out on 3 trophic levels and chronic on 2. Both marine and freshwater test methods are valid. Products can be assessed by either testing the fully formulated product and its main components or by testing each of the components in the formulation for their toxicity.

3. As measured in OECD 306 product level testing
4. Using OSPAR criteria for assessing bioaccumulation potential
5. As measured in ISO 10253 / ISO 14669