Choosing the Correct Lubricant to Meet Changing Regulations - MarineLink.com

Posted - Monday, March 26, 2012 - Benjamin Bryant (taken from March 2012 print edition of MarineNews). -

The proposed 2013 Vessel General Permit prompts vessel managers to review the portfolio of lubricants used on their vessels.

One of the Environmental Protection Agency’s (EPA) changes in the proposed 2013 Vessel General Permit for commercial vessels over 79’ is a requirement to use environmentally acceptable lubricants in certain applications. Given this proposed change, it is a good time for vessel managers to review the portfolio of lubricants used on their vessels to look for gaps in the operational performance of the lubricants, assess vessel compliance with current and proposed regulations, and align lubricant choices with the environmental values of their company and their customers. To conduct the review, the manager should have an understanding of the laws and regulations that influence lubricant choices and only then develop a framework for applying selection criteria to the decision making process.

The Clean Water Act, Oil Spill Pollution, and the Vessel General Permit
Federal regulations for the use of lubricants, whether a grease or an oil, on board vessels operating within the territorial waters of the United States are derived from language contained in the Clean Water Act of 1977 (CWA) which was later amended by the Oil Pollution Act of 1990. Section 311 of the CWA, under the title “Oil and Hazardous Substance Liability”, prohibits the discharge of oil into the waters of the United States in quantities that may be harmful. For the purpose of the act, oil is specifically defined as “oil of any kind” and the phrase “quantities that may be harmful” is defined by regulation. Also, found in section 311 of the CWA is the authority for the U.S. Coast Guard to assess fines for oil spills and to implement oil pollution control measures. Section 311 of the CWA thus prohibits the discharge of lubricants into the environment regardless of the type of base oil used (whether mineral, ester, or synthetic and whether it is environmentally acceptable or not) and directs the U.S. Coast Guard to assess fines for the discharge of oil into the environment and to conduct oil spill prevention, response, and mitigation activities. Thus, choosing a lubricant based on whether or not a fine will be assessed, or how much of a fine will be assessed, should not be a primary consideration when selecting a lubricant because the U.S. Coast Guard must treat all oils the same.

Complete post at:
http://www.marinelink.com/news/lubricant-choosing343352.aspx