The new USA Vessel General Permit will come into effect on 19th December 2013 and will remain in force for five years. This legislation applies to ALL commercial vessels calling at a US port, not just newbuildings as had been indicated in earlier drafts.
All vessels must use Environmentally Acceptable Lubricants (EALs) on all oil to sea interfaces unless technically infeasible. The EAL must be approved according to one of the following standards: Blue Angel, European Ecolabel, Nordic Swan, Swedish Standards SS155434 and 1555470, OSPAR and EPA’s DfE. With regard to whether a vessel can wait until the next drydocking prior to changing from mineral oils to EALs, we have received advice that if a drydocking is necessary to substitute the oils then a vessel may operate in US waters until its next drydocking to change out to an EAL. This is because the use of the EAL would be technically infeasible until the next drydocking. However, owners should be aware that there is still no final ruling on this – anyone concerned should check the latest situation. A helpful link can be found here.
We have investigated whether our Airspace seal counts as an oil to sea interface. This seal has been approved by the ABS (American Bureau of Shipping) as a non-pollution seal due to the fact that there is no oil to sea interface provided that the seal system is not damaged in some way. However, since it is not possible to rule out circumstances in which there could be a leakage EALs must be used on this type of seal as well.
The problem with bio oils in general is that they are often aggressive towards the types of sealing ring material used on all lip type sealing systems today. We have, however, tested a number of bio oils which have proved to be much less aggressive towards our sealing ring material Viton Pod. These bio oils are approved for a five year docking cycle when using the Airspace seal and a two and a half year docking cycle when using standard seals. The bio oils which are currently approved by us are in alphabetical order:
Statoil Sternaway Bio 100
` Terresolve EnviroLogic 3068
Terresolve EnviroLogic 3100
Total Lubmarine Bioneptan 100
Vickers ECOSURE SMX 68
Vickers ECOSURE SMX 100
However to date none of these oils have been approved to one of the required EAL standards. This situation is dynamic, and we recommend that vessel operators check with their lubricant supplier prior to changing the sterntube lube oil. We also recommend that ship operators check with us at the same time to obtain the latest list of recommended bio oils.
Please note also the new requirements regarding anodes: all vessels calling at US ports must cease using zinc anodes and switch to aluminium or magnesium. If they continue to use zinc anodes, the vessel must document why the change has not been made. There are currently no aluminium anodes available for Simplex seals but a new design is in development. We will keep you posted of developments.