Vessel General Permit – VGP

Environmentally Acceptable Lubricants (EALs) – Mandated by U.S. Environmental Protection Agency (EPA)

• The EPA implemented the Vessels General Permit (VGP) which entered into force in December 2013.
• The VGP applies to all vessels above 79ft trading on U.S. ports and mandates such to use Environmentally Acceptable Lubricants (EAL) in all oil-to-sea interfaces, unless technically unfeasible, which covers applications / equipment such as stern tubes, rudder & thruster bearings, controllable pitch propellers, thrusters, stabilizers, wireropes and other equipment subject to water interface / immersion
• DNV states: “However, any ship components that can potentially cause the leakage of lubricants into the sea are in principle to be considered according to the VGP”

The legislation has denied ‘technically unfeasible’ being valid under certain situations such as:

• An EAL not being available or approved by the manufacturer for use in certain equipment
• Pre-lubricated equipment (e.g. wire ropes) have no available alternatives manufactured with EALs
• EAL lubricants meeting manufacturers’ specications not being available at the ports in which the vessel operates
• Use of an EAL must wait until the vessel’s next dry-docking prior to being able to conduct a change-over

EAL compliance declaration is issued by the lubricant producer through 3rd party accreditation in accordance with national / regional Labeling Programs which have been approved by the EPA.

OSPAR Convention

• Introduced 1992 and short for “Oslo Paris convention”
• Premise for participating governments local legislation -> All offshore oil & gas operation in North Atlantic
• HOCNF format (Short for the harmonized certificate for chemicals needed to be acceptable for Operators to use) is the strictest bio-regulation globally and applies to the Oil & Gas/Onshore industry in the region.
• The Contracting Parties comprise fifteen governments which ensure enforcement
• LanoPro products and its components have been evaluated by independent laboratories in Norway in accordance with the OSPAR Harmonised Offshore Chemical Notification Format (HOCNF). Third party compliance comfirmation has been issued by Add Novatech AS in Norway, confirming the product is an EAL according to the Vessels General Permit regulation, according to EPA`s definition.
• OSPAR is one of the EPA approved labeling programs for EALs.