Legislation and Environmentally Acceptable Lubricants (EALs) The marine industry is one of the most heavily regulated industries and was amongst the first to adopt widely implemented international safety and environmental standards. It is principally regulated by the International Maritime Organization (IMO), which is responsible for the protection of the marine environment and has, over many years, adopted a wide range of measures to prevent and control pollution caused by ships. One of the main goals of IMO is to mitigate the effects of any damage that may occur as a result of maritime operations and accidental spills, leaks and discharges.
In 2008, the EPA issued the first version of the Vessel General Permit (VGP). The VGP was amended by the EPA in 2013 to require all vessels to use EALs, rather than mineral oils, in all oil-to-sea interfaces unless technically infeasible.
Environmentally Acceptable Lubricants are defined by the EPA as offering these three characteristics. First, they must be “biodegradable”
- biodegrading into carbon dioxide and water by ≥ 60% or more within 28 days (according to OECD 301B or ASTM D7373 methods). Next, they must be “minimally toxic,” causing only a light impact on the aquatic environment (LC50> 100mg/L for lubricants and LC50>1000mg/L). Lastly, they are “not bioaccumulative,” and must have a low propensity to bioaccumulate in organisms.
Reporting Under “The Sheen Rule” The Clean Water Act of 1972 mentions discharges of oils should not exhibit any visible ‘sheen’ on the water’s surface otherwise it is considered a pollutant (according to CFR 40 Part 435 A). This has led to a common misperception that the United States Coast Guard approves oils based on the oil not leaving a sheen. Under the legal authority of the Clean Water Act (CWA), the Discharge of Oil regulation, more commonly known as the “sheen rule,” provides the framework for determining whether an oil spill or discharge to inland and coastal waters and/or their adjoining shorelines should be
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reported to the National Response Center. Specifically, the regulation requires the person in charge of a facility or vessel responsible for discharging oil that may be “harmful to the public health or welfare” to report the spill to the federal government. The regulation also establishes the criteria for determining whether an oil spill needs to be reported.
The criteria are: • Discharges that cause a sheen or discoloration on the surface of a body of water;
• Discharges that violate applicable water quality standards; and
• Discharges that cause a sludge or emulsion to be deposited beneath the surface of the water or on adjoining shorelines.
Environmentally Acceptable Lubricants (EALs) offer a full range of performance levels while minimizing (but not eliminating) the risk of triggering the reporting requirements of the “sheen rule”. It’s important to note that correctly formulated EALs provide higher
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