Fathom Spotlight: A Slippery Start For The New Year

by Fathom
Monday December 23, 2013

The 19th December 2013 marked the advent of a new set of regulations and standards entering into force for ships sailing in US waters.

This week, Fathom explores what the new United States Vessel General Permit (VGP) requirements mean for ship owners and operators sailing in US waters, where it is estimated that some 10%-20% of world tonnage is traded.

The VGP and its rules around marine effluents has spurred innovation within the maritime industry, particularly around oil-based products, such as machinery lubricants. Therefore, in this week's spotlight we pay special attention to the lubricants market and the expansion of Environmentally Acceptable Lubricants (EALs) that minimise or completely remove the requirement for oil-based lubricants for machinery and vessel operations.

What Does the 2013 US VGP Enforce?

The US VGP regulates 27 specific discharge categories, including – but not limited to – bilge water, ballast water, hull fouling, deck washdown and washwater.

The first VGP enforcements were issued in 2008 by the US Environmental Protection Agency (EPA) and came into force at the start of 2009. On March 28, 2013, EPA re-issued the VGP for another five years and that re-issued VGP has now superseded the 2008 US VGP.

The VGP rules apply to all non-recreational vessels that are 79ft (24.079m) or greater in length that operate within a three-mile territorial sea of the US.

To view the final 2013 US VGP official documentation please click here.

Back in April 2013, Fathom reviewed the 2013 US VGP requirements and identified the most significant changes regarding the aforementioned effluent limitations and rules. This spotlight can be viewed here.

The VGP and the Lubricants Market

Possibly the most far-reaching of these changes relates to the use of environmentally acceptable lubricant oils.

During the course of maritime operations, lubricants will leach into the sea. According to a study conducted in 2010 by Professor Dagmar Etkin, commercial vessels leak between 4.6 - 28.6 million litres of lubricating oils from stern tubes alone. In essence this means that every year, the equivalent of several Deepwater Horizon spills are leaked into the ocean from in-harbour stern tube leaks alone.

Recognising that not all lubricants can be prevented from leaking into the ocean during ship operations, the 2013 US VGP requires that all oil-to-sea interfaces must use EALs, where technically feasible.

EALs are defined by the EPA as lubricants that are "biodegradable", "minimally toxic" and "not bioaccumulative".

According to the EPA, four major types of lubricants meet all the necessary required criteria to be approved as an EAL. These are:

  • Vegetable Oils (such as canola or soy oil based);
  • Synthetic Esters (esters derived from bio-based sources);
  • Polyalkykene Glycols (can be either water soluble or water insoluble);
  • Water (referring to water lubricated and cooled stern tubes).

The 2013 US VGP enforces that these 'bio-lubricants' must be used in all applications where the lubricant and the ocean come in to direct contact. This would include areas of the ship such as the controllable pitch propellers, stern tubes, rudder and thruster bearings, stabilisers, Azimuth thrusters, propulsion pod lubrication and wire rope and mechanical equipment that are subject to immersion.

By 'technically infeasible', the VGP is referring to:

  • pre-lubricated equipment such as some wire rope;
  • when there is no EAL available that meets the manufacturer's lubricant specifications either on the market or at that specific dock;
  • if the process of switching over needs to be performed at the next dry-docking.

When technically infeasible, the use of non-compliance lubricants must be recorded in the vessel's Annual Report and its usage justified.

Furthermore, it is strongly encouraged - but not mandated - that vessels use EALs in all above deck equipment and that new build vessel operators use seawater-based systems for their stern tube lubrication.

The Expansion of the Bio-Lubricants Market

Recognising the environmental problems associated with lubricant leakage and the legislative shift towards EALs, several companies furiously launched into R&D around EAL development and the last few years have seen a monumental shift towards EAL development and launch. 

In August, Vickers Oils confirmed that their Hydrox Bio, Ecosure HSE and Biogrease EP2 ranges of bio-lubricants met the detailed ecological definitions and requirements laid down in the 2013 US VGVessel General Permit (VGP).

Castrol announced in a press release earlier this year that their Castrol's BioStat and BioBar ranges are registered under OSPAR and therefore meet the criteria for being EALs under the VGP. "OSPAR requires testing the individual chemicals in a product in seawater as this is the environment they will ultimately end up in," Susannah Linington, Castrol Marine Environmental Specialist, commented. "Although seawater testing can be harder to pass than freshwater or soil testing, this is the regime we have adopted at Castrol for developing our BioRange of products.  This ensures that we can supply documentary evidence why our products meet the environmental standards laid out in the VGP."

Two specialty lubricants from Klüber Lubrication - Klüberbio EG 2 gear oil for thrusters and Klüberbio RM 2 stern tube oil – have also been recognised for meeting the EAL requirements and will carry the European Ecolabel. "The EU Ecolabel is a label of environmental excellence that is awarded to products and services meeting high environmental standards throughout their life-cycle: from raw material extraction, to production, distribution and disposal," the company stated.

Similarly, ExxonMobil recently announced that they have developed a full range of EALs to support operators with the 2013 US VGP regulations. Each product in the new Mobil SHC Aware family meets or exceeds VGP requirements. This product family includes hydraulic fluids, stern tube lubricants, gear oils and a multi-purpose grease.

Following rigorous independent testing and European Ecolabel certification, Lubmarine announced that its products Bioneptan and Biohydran TMP meet EAL criteria and therefore VGP requirements. These products are largely ester-based, thereby offering higher durability and lower toxicity than mineral lubricants. The biodegradable stern tube lubricants Bioneptan, for example, is claimed to offer increased thermal and oxidation stability, enabling almost four-fifths of the oil to return to its original carbon and water state within 28 days.

Another lubricant that falls under the category of EALs is the Thordon COMPAC seawater lubricated propeller shaft bearing which completely eliminates the risk of oil discharges from the stern tube. Seawater is used as lubrication instead of oil and is taken from the sea, pumped through the bearings and returned back to the sea. There is said to be no risk of damage to an aft seal by fishing nets or ropes as there is no aft seal. This results in lower in-service maintenance costs and the elimination of storage, sampling and disposal of oil from the stern tube.

Since then, the bio-lubricants market diversified to include all areas of the ship from gears and bearing lubrication, windows, and wire ropes as well as stern tube lubrication.

However, there has also been some confusion generated through the marketing of minimally toxic, eco-friendly products, which despite the offering of lower environmental impact, are not actually compliant with the requirements.

One area that was holding back the development of a market standard was the lack of a world-wide consensus as to the definition of an EAL; however, with the 2013 US VGP's clear definition based on previous schemes such as the Blue Angel, the market has now reached a certain level of transparency with regards to what it should be aiming for.

This explains why 2013 has seen a number of press releases announcing the approval of several bio-lubricants as EALs.


As vessels approach their next drydocking period, from an operational standpoint a number of actions need to be taken by an operator:

  • Confirm with lubricant supplier if they offer solutions for oil-to-sea interfaces that meet the VGP's definition of an EAL.
  • Confirm that suitable EALs are available for all applications required by the vessel including wire ropes (and if it is feasible to use them)

This is a great opportunity to carry out a market review either just on EALs or for full lubricant supply. A study by the US EPA found EALs to be on average 38% more expensive than mineral based lubricants but not necessarily more expensive than other synthetic lubricants. As synthetic lubricants tend to have better performance characteristics and longer fluid life, there is an argument that some cost differential may be mitigated by this. However, it is difficult to quantify in hard figures. 

Furthermore, it might be worthwhile considering a switch to EALs for above deck equipment as recommended in the 2013 US VGP and thereby possibly pre-empting future regulations. After all, the 2008 VGP only recommended the use of EALs on all oil-to-sea interfaces which has now become a regulatory requirement, showing that current regulatory encouragements will often become tomorrow's requirements.

Fathom have gone that extra mile to tackle the complex changes to this market with a Lubricant Focus, a revised addition of this publication will be released in May 2014 so keep your eyes out for more information. To view the first edition please click here.