In the Vessel General Permit (VGP) the US Environmental Protection Agency (EPA) summarises rules and regulations that are intended to minimise the pollution of US territorial waters. This extremely strict legislation was amended and updated on 19.12.2013. The VGP 2013 is the updated version of the Vessel General Permit of 2008.
What is the VGP 2013 about?Category: General
How - and on what - is the oil exactly tested?Category: General
All oils listed on our ENVIRONMENTALLY ACCEPTABLE LUBRICANT (EAL) LIST are tested under standardised conditions using static and dynamic testing methods. We have our own R&D test area at SKF Marine in Hamburg. Dynamic tests can easily take several hundred running hours on the test rig. Our experience has shown that this effort is necessary.
Which ships are affected?Category: General
The VGP 2013 applies to all commercial vessels that are 79 feet and greater in length that enter US coastal waters and inland waterways. The regulations cover all vessels with a keel-laying date after 19.12.2013 or that had been drydocked after 19.12.2013.
What exceptions exist?Category: General
Only recreational vessels are excepted from the VGP 2013, unless they are used for carrying passengers for commercial purposes.
What effect will the VGP 2013 have on SKF Marines customers?Category: General
A central requirement of the VGP 2013 is that environmentally acceptable lubricants (EALs) must be used in all applications where there is an oil-to-sea interface. Such interfaces exist both with our SIMPLEX-COMPACT sterntubes and seals and our SIMPLEX-COMPACT fin stabilizers. In effect, this means that you must convert your vessel correspondingly, unless you already use EALs at these interfaces. Alternatively, you can seal your sterntube using a SIMPLEX-COMPACT Airspace seal – because there is then no requirement to use EALs (see question 13 for further information). A further stipulation of the VGP 2013 is that the sacrificial anode is made of aluminium (if the vessel primarily sails in saltwater) or magnesium (if the vessel primarily sails in freshwater). This may also require conversion work to be carried out. SKF Marine offers aluminium anodes for use primarily in saltwater.
The VGP 2013 furthermore stipulates that the volume of pollutants that enters the sea via bilge water may not exceed 15 ppm (parts per million). This is equivalent to the currently applicable MARPOL 73/78 regulations, compliance with which is a requirement for the installation of bilge water separators aboard a ship. There is consequently no need for action here.
What are EALs? Category: General
EAL is the abbreviation for Environmentally Acceptable Lubricant. These special oil-based lubricants must be used at all oil-to-sea interfaces aboard vessels that sail in US waters. The use of EALs requires special EAL compatible seals to be fitted. Caution: Not every bio-oil is an EAL! The EPA has implemented strict standards concerning this. There is a diverse range of certification programmes that can be used to validate a lubricant as an EAL. It is the responsibility of the lubricant manufacturer to comply with the criteria for an EAL.
We have prepared an overview for you here of the available EALs that we have approved for use with Viton Pod and Viton Bio sealing rings.
What requirements are applicable to SIMPLEX-COMPACT sealing rings for sterntube seals if I use EALs?Category: Simplex Seals
You can use EALs for up to 5 years (a standard docking period) with our SIMPLEX-COMPACT sterntube seals. However, you must then use sealing rings made of the Viton Pod or Viton Bio material mixtures. Viton Bio sealing rings are only available for the SC3 seals. It must also be possible for the seals to be flushed in order to allow the oil to be changed at regular intervals (approximately every three months).
When using Viton Pod together with an EAL the following points must also be observed:
- The water content in the lubricating oil may not exceed 1 percent.
- The operating temperature of the rear sterntube bush may not exceed 55 degrees Celsius and the alarm temperature should be set at 60 degrees Celsius.
- The operating temperature of the forward seal may not exceed 60 degrees Celsius.
What requirements are applicable to SIMPLEX-COMPACT sealing rings for stabilizers if I use EALs?Category: SKF Marine Stabilizers
It is imperative that you use sealing rings made of an FKM at the actual oil-to-sea interface in order to lubricate your stabilizer with an EAL. We furthermore strongly recommend the use of FKM sealing rings in all locations that come into contact with EALs, to ensure that the operational reliability of the system is not negatively affected. For new build projects that are to comply with the VGP requirements, we supply our components already fitted with such seals. Our VGP experts will be pleased to help you identify the optimum combination of FKM sealing rings and EALs for your application.
Which EAL does SKF Marine recommend?Category: General
We do not recommend lubricants as a matter of principle. However, the compatibility of the lubricant with the seal material used must be observed. You will find an overview of those EALs that we have tested and approved for use with the sterntube sealing rings that we supply here.
Am I still allowed to sail in US waters without using EALs until the next scheduled drydocking?Category: General
Changing to EALs is fundamentally not recommended unless the sealing rings are replaced at the same time. SKF Marine can issue you with a “Statement of Technical Infeasibility” (see question 16) that will allow you to continue operating with mineral-based lubricating oils until the vessel’s next scheduled drydocking.
Can the changeover to EALs take place without drydocking?Category: General
No, because the sealing rings must be replaced and all of the lubricants have to be changed.
How is the change from mineral-based oils to EALs performed?Category: Simplex Seals
As a manufacturer of shaft components we are not directly involved in the design and installation of sterntube lubricating oil systems, so we do not have detailed knowledge of the tank installations and pipework routeing. SKF Marine can therefore provide no guidance for the replacement of oils in the sterntube and its associated systems. A complete oil change is necessary to ensure the optimum operation of the sealing rings. If, because of the design of the system, small amounts of residual oil are unavoidable, then please contact your oil manufacturer to obtain details of the miscibility and compatibility of the respective oils.
Must Viton Pod sealing rings in a mineral oil-based system be replaced if an EAL is now to be used in this system?Category: General
Yes. In order to maintain the optimum service life of the sealing rings when using an EAL, it is necessary to replace the rings.
Under what conditions can I continue to permanently lubricate my sterntube using mineral-based oils?Category: Simplex Seals
Our SIMPLEX-COMPACT Airspace seal is recognised as an environmentally friendly product as defined by the VGP 2013, because the oil and water are 100% separated by the system’s air chamber. This seal is therefore not classed as an oil-to-sea interface and the sterntube and seal can consequently continue to be lubricated using mineral-based oils. In many cases it can pay off to retrofit your vessel with a SIMPLEX-COMPACT Airspace seal. We would be pleased to provide you with individual advice on this issue, because such a retrofit installation is not always technically feasible.
Can I continue to lubricate my stabilizer using mineral-based oils?Category: SKF Marine Stabilizers
If you want to sail your vessel in US waters the answer is no. At the latest during your vessel’s next drydocking you will have to convert to using EALs and – where necessary – carry out the corresponding conversion work. Until that time you will require a Statement of Infeasibility (see question "What is a “Statement of Infeasibility”? "), which we will be pleased to issue to you.
What are the costs involved in upgrading or retrofitting to comply with the VGP 2013?Category: Simplex Seals
Due to the different situations prevailing aboard each individual ship, it is only possible to provide information once the situation has been analysed in detail. Depending upon the product and vessel, various solutions are available to make your vessel conform 100% to the VGP 2013 regulations. Discuss which solution is best for you with our VGP experts who are on-hand at all times. We will be pleased to advise you.
Which types of Statement of Infeasibility are there and what do they mean?Category: General
There are two different Statements of Infeasibility: There is a Statement of Technical Infeasibility with unrestricted validity for seals without a flushing option and a Statement of Technical Infeasibility that is valid until the next docking. The Statement of Infeasibility allows us to confirm for you that:
- The conversion to an EAL compatible seal or Viton sealing ring is not possible when the vessel is underway and can only be performed at the vessel’s next drydocking (“Statement of Technical Infeasibility”). This will allow you to operate your vessel in US waters using the existing equipment until the next drydocking. However, conversion is then mandatory.
The Statement of Technical Infeasibility of 5 year operation certifies:
- The system design only permits operation of the installed seal with EALs for a maximum period of 2.5 years (“Statement of Technical Infeasibility of Five Year Operation”). This is normally the case when it is impossible to flush the corresponding chamber within the seal. Such a statement is useful for proving to the EPA that converting the seal would cause a disproportionate investment in time and cost. Further information on this issue can be found in the FAQs of the EPA.
Which oils does SKF Marine recommend for its sterntube seals and bushes and what can I do if the oil that I use is not on this list?Category: Simplex Seal
With all SIMPLEX-COMPACT seals and sterntube bushes you can use the oils stated on the ENVIRONMENTALLY ACCEPTABLE LUBRICANT (EAL) LIST FOR SIMPLEX COMPACT STERNTUBE BUSHES AND SEALS. It is however important that the sealing rings are made of the bio-oil-compatible materials Viton Pod or Viton Bio. If the oil that you would like to use is not on this list then please contact our Service Support department by e-mail at email@example.com or telephone them on +49 40 3011-2233.
How can I get a Statement of Infeasibility?Category: General
Please contact our VGP service by e-mail at firstname.lastname@example.org, stating your IMO number and the name of your ship to enable better identification. We will immediately prepare your “Statement of Infeasibility” and send it to you.
What is hydrolysis and what role does it play?Category: General
Most EALs are lubricating oils that are manufactured on the basis of esters. Esters are made by combining acids with an alcohol, in a process which results in ester and water. If ester comes into contact with water under specific temperature conditions, the chemical reaction can be reversed, creating acids and alcohols once again. This process is called hydrolysis. The acids formed can in turn attack elastomers, i.e. the sealing rings. This is why a maximum water content of 1% is permitted when using EALs with the Viton Pod sealing material. The sealing material Viton Bio – developed by SKF Marine for the SC3 – for use with biologically degradable oils is more resistant. In this case, the threshold value for water content in the lubricating oil is 5% – the same as when using mineral-based oils and conventional sealing rings.
Do you have any further questions?
Please contact our experienced VGP expert team at email@example.com or tel. +49 (0)40 30 11 22 33.