Implementation of the United States Environmental Protection Agencys 2013 Vessel General Permit demonstrated that the marine industry was not prepared for such regulation. There are still vessels operating in U.S. waters today, four years after the introduction of the legislation, that are claiming exemptions due to technical constraints. Lubricants are only a small part of the permit, but one that regulators view as effective and sustainable.

The regulation affects the discharge of 27 effluent streams in vessels longer than 79 feet, as well as commercial and non-recreational vessels under this length, that operate within U.S. coastal waters and the Great Lakes. These streams include bilge water, ballast water and condensate discharges, among others. Considering that EALs are mentioned in only one paragraph in the main text of the regulation and a combined half-page in Appendix A of the 194-page document, it seems likely there are details we have missed that could put operators out of compliance.

Vessel operators need to practice due diligence in selecting environmentally acceptable lubricants for on-deck auxiliary systems and applications without a direct oil-to-water interface. If the industry is seen to be irresponsible by doing less than or barely what is required to comply with the set limits, regulators will step in and set stricter ones. These will cause operational issues that will often stem from the fact that the regulator does not fully understand the way the industry operates, or from the limitations in control measures and technical solutions.

One could argue that the use of EALs as a regulatory requirement was made compulsory in the U.S. and not in Europe due to the fact that environmental awareness is higher east of the pond. For example, offshore operators have worked together with regulators since the 1970s to demonstrate that they take their role in the protection of the environment seriously. This can be further argued by the fact that lakers-vessels operating exclusively in the Great Lakes-were virtually excluded from the requirements of the VGP, partly because measures had previously been imposed on these closed waters.

The VGP was a real game changer when it came to EALs. It caused a great headache for marine operators due to the increased complexity in lubricant sourcing and cost, and to lubricant formulators who had to supply products to a demanding market while overcoming practical problems such as global availability of raw materials and compatibility with current equipment, particularly seals and elastomers.

The hurried original equipment manufacturer approach to VGP compliance mainly focused on practical issues such as compatibility of equipment seals with the proposed lubricants. Performance was not considered an immediate priority, though the regulatory requirements drove the lubricants market to formulate products based on natural and synthetic ester feedstocks, which offer improved performance in terms of lubricity, operating temperature and viscosity. Today, OEMs are taking a closer look at the performance of the products, and there is a trend to develop a tiered approach to EALs with specific equipment manufacturer approvals.

The effect of the VGP on the marine lubricants auxiliary market has been significant, and has brought solutions that in the past were reserved for so-called problematic vessel designs, such as leaky stern tubes, or sensitive waterways, such as rivers, lakes or closely regulated seas. Smaller players in the lubricants market that focused on auxiliary equipment and identified the need for lubes that could meet these demands were early to capitalize on the regulation, and major players were quick to follow. Most companies supplying lubricants to the marine industry today offer a range of hydraulic and gear oils, a stern tube oil and one or two greases for on-deck applications that comply with limits set by the VGP.

However, the five or six VGP-compliant products that lubricant manufacturers or marketers typically offer are a drop in the ocean compared to the extensive product range for the total marine auxiliaries market. Clearly there is a need for such an array of products, and indeed more specialized ones. But in the case of EALs, operators have to make do with what is available.

Most EALs required to comply with biodegradability, toxicity and bioaccumulation parameters set by the 2013 VGP are limited to equipment at the oil-to-water interface. But there are more applications where lubricants will ultimately affect a vessels effluent streams than those strictly defined as having an oil-to-water interface. An example is the condensate from vane or screw compressors, where oil is carried over into the vapor phase. Engine room compressor condensate will typically end up in the vessels bilge water, which needs to be treated before discharge. Treatment systems such as membranes will be clogged up by hydrocarbons and quickly lose efficiency, worsening the headache of ship operators striving to remain compliant.

Lubricant suppliers will typically offer a range of environmentally acceptable hydraulic fluids and gear oils designed for on-deck applications, such as winches, cranes or hatch covers. Nevertheless, there is a series of other auxiliary equipment where the use of lubricants compliant with the VGP is often neglected. Such products are hydraulic fluids for auxiliary control systems and air lubricators for operating pneumatic control valves. Specialized lubes, such as radar dome control fluids, are often not considered. Rust preventives and petroleum based corrosion protection films can cause non-compliant, hydrocarbon based products to be mixed with a vessels effluent streams in deck wash-down. As a matter of fact, the VGP makes explicit mention of the use of EALs in all on-deck applications in section 2.2.1 under Effluent Limits and Related Requirements, which deals with deck wash-down and runoff water.

Another source of frequent non-compliance is pre-lubricated replacement parts, such as greased bearings. The above mentioned on-deck applications need bearing replacement on a regular basis. Although some of the major bearing manufacturers will supply bearings with fit-for-purpose grease as factory-fill, the chances of picking up a replacement bearing that contains a VGP-compliant grease in East Africa, for instance, are slim. Operators need to make sure they purge the existing grease with a compliant product. This must be done in accordance with the bearing manufacturers instructions, noting any incompatibility issues between the original and the replacement grease.

Wire ropes often come pre-lubricated from the manufacturer; in particular, the core of the rope needs to be lubricated during the production stage. Under stress, this lubricant will be forced to the surface of the rope, raising compliance issues. The same applies to synthetic ropes and cords, where a lubricant is used in the core to increase service life. The vessel operator needs to ensure that the ropes chosen were pre-lubricated with a suitable product, to avoid costly after-treatment during installation.

Induced air heating or cooling systems installed for the comfort of the crew, but also for the temperature control of the cargo, are another source of oil contamination, either through a possible system failure or through oil carrying over in the vapor phase and subsequent condensate. Heating, ventilation and air conditioning systems will typically use environmentally friendly polyol ester based refrigeration oils that most likely comply with the requirements of the VGP, but this should be confirmed by the supplier. The effect of refrigeration systems could be significant on board large container vessels, on which tens to hundreds of temperature-controlled containers could be carried at any one time.

The 2013 VGP expires Dec. 19, 2018, five years after implementation. The EPA has yet to announce any specific changes, including lubricant requirements, for the third version of the VGP. But decisions from the U.S. Second Circuit Court of Appeals in 2015 on ballast waters and treatment systems have led the way for the upcoming permit. It is predicted that the 2018 VGP will be the most impactful in terms of vessel discharges. In my dictionary, impactful means costly and difficult to implement. Of course, this remains to be seen when the draft version of the regulation is presented either this summer, as initially announced, or later in the year.

One thing is for sure: Environmental groups will continue to put pressure on legislators, and the laws will become stricter for all traffic in the seas.

Andreas Dodos is a chemical engineer with Eldons SA. He has over 15 years of experience in the field of lubricating greases and specialty industrial lubricants. He is a member of a number of professional bodies, has been the chairman of the European REACH Grease Thickener Consortium since 2010 and currently serves on the ELGI board of directors. He can be reached at andreas.dodos@eldons.gr.