TEC- 0986 ClassNK

ClassNKClassNK issues technical information TEC-0986 regarding the use of Environmentally Acceptable Lubricants.

On 18 October 2013, ClassNK issued Technical Information No. 0968 on the subject of "Final 2013 Vessel General Permit issued by U.S. Environmental Protection Agency" (hereinafter referred to as "2013 VGP"). Since the issuance of Technical Information No. 0968, many inquiries, particularly about the use of Environmentally Acceptable Lubricants (hereinafter referred to as "EAL"), have been received. Therefore, more detailed explanations about the use of EALs are given in the table below.

ClassNK is now issuing a "Statement of Fact" (hereinafter referred to as "SOF") as part of its new "EAL Usage Assessment Service" to verify that a ship is in full compliance with the 2013 VGP requirements.

SOFs can be issued for the following cases:
  1. An air seal system is being used;
  2. An EAL is being used for lubrication on a newly built ship;
  3. An existing ship switches from a conventional lubricant to an EAL; and,
  4. The use of an EAL is technically infeasible.
Remarkable points regarding the use of EAL

The requirements for the use of EAL in the 2013 VGP

All vessels subject to the 2013 VGP must use an EAL in all oil to sea interfaces, unless technically infeasible. (2013 VGP Part 2.2.9)

What is an EAL?

"Environmentally acceptable lubricants (EAL)" means lubricants that are "biodegradable", "minimally-toxic" and are "not bioaccumulative" as defined in Appendix A of the 2013 VGP.

Kinds of oils that qualify as an EAL

Some environmental labelling programs designed to indicate environmentally-friendly products have been established. Standards for environmentally-friendly products are specified by third party organizations. For the purposes of the 2013 VGP, products satisfying the U.S. Environmental Protection Agency's definition of an "EAL" include those labelled by the following programs: Blue Angel, European Ecolabel, Nordic Swan, the Swedish Standards SS 155434 and 155470, Convention for the Protection of the Marine Environ- ment of the North-East Atlantic (OSPAR) requirements, and the EPA's Design for the Environment (DfE).

Products without any labelling still may be considered EALs under the 2013 VGP as long as they are, based upon the results of analysis conducted by the EAL's producer, deemed to be "biodegradable", "minimally- toxic" and "not bioaccumulative" in accordance with Appendix A of the 2013 VGP.

"Environmental Labelling Program"

According to JISQ 14024 and ISO 14024, environmental labelling programs are multi criteria based, third party certified programs. Such programs create a standard under which products can be assessed against set criteria and compared with others within the same category, awarding labels to those which are environmentally preferable throughout their life cycle.

"Oil to sea interfaces"

According to Part 2.2.9 of the 2013 VGP, "oil to sea interfaces" include items such as the following: lubrication discharges from paddle wheel propulsion, stern tubes, thruster bearings, stabilizers, rudder bearings, azimuth thrusters, propulsion pod lubrication, and wire ropes and mechanical equipment subject to immersion, etc

For more information please read the TEC- 0986 issued by ClassNK

You can also ready the following related article by clicking below:

Final 2013 Vessel General Permit issued by US Environmental Protection Agency