The Vessel General Permit in a nutshell

On 19 December 2013, the revised Vessel General Permit (VGP) issued by the US Environmental Protection Agency (EPA) came into force. This means that the VGP mandates the use of Environmentally Acceptable Lubricants (EALs) in all oil-to-water interfaces (e.g. stern tube seals, thruster seals) on all merchant vessels of 79 feet or longer that are sailing in US coastal and inland waters – unless technically infeasible. Read this blog to find out what this means for ship owners.

Owning a vessel of less than 79 feet and operating in US waters? Then you have to meet the requirements of the Small Vessel General Permit. Read our blog about the sVGP to find out what the consequences are.

EAL

According to the VGP, a regular seal has an oil-to-sea interface and EPA indicates that every oil-to-sea interface has to use an EAL. These lubricants are biodegradable, non-bio accumulative, and minimally toxic. They must be approved by labelling programs like Blue Angel, European Ecolabel, Nordic Swan, Swedish Standards SS 155434 and 155470, OSPAR and EPA’s DfE. Not every bio-oil is an EAL. Always check with the oil supplier if the intended lubricant is in compliance with VGP requirements.

NBR or FKM?

If you want to sail with an EAL,you have to check the compatibility of the EAL with the rubber compound of the seal. In most occasions, FKM compound will be used together with EAL, but no EAL is the same and that is why there is no guarantee that our seals are compatible with every EAL. We keep a list of tested EAL with Lagersmit rubber compounds. The most up-to-date list of EAL’s can be found at www.lagersmit.com/eal.

When you miss a certain oil on our EAL list, the oil-supplier can file a request with our Technology & Processes department (Mr. Pepijn Swarte – Pepijn.Swarte@lagersmit.com). If the oil was tested, but not approved, we advise to use another approved oil. In that case it’s better to contact your oil-supplier to get the best advise on which oil to use.

More info? One of our research engineers wrote a blog about the compatibility of several EALs with Lagersmit’s lip seals.

Technical infeasible & Technical infeasibility statement

The VGP indicates that the specified vessels should use EALs unless this is deemed technical infeasible. This means that no EAL alternative is available for the given application or that the right EAL is not available at the next port of call. In addition to that, it is also allowed to sail on with mineral oil, if the oil cannot be replaced without going into dry dock. This rule applies with our seals. However, the oil still has to be changed at the first possible opportunity when going to dry dock. Seals cannot be changed while afloat, because the stern tube and seal have to be drained and cleaned, and the rubber lip seals have to be changed. If this procedure is not used, the possibility of EAL and mineral oils mixing up exists. This may severely damage the lip seals.

If you want to sail based on the above, a letter of technical infeasibility is needed, and this document has to be present at the vessel at all times so that it can be shown to the authorities.

Alternative seal design instead of EAL

Instead of using an EAL, it’s also possible to use an alternative seal design. These seal designs are often air/vacuum/void space seal types that collects any leakage in/to a drain tank. EPA does not issue pre-approvals for these alternative seal designs, but recommends to have a third party verification by a classification society that the seal design is unlikely to leak during normal operation, and therefore, will no longer function like an oil-to-sea interface. Examples of alternative seal designs are the Supreme Ventus® and Supreme Athmos® air-type seals.

“A typical air seal or void space seal functions by having at least two independent sealing systems: one on the side of the seal facing oil, and one on the side of the seal facing

water. An air chamber or void space in between these two seals collects water before it is pumped for further reuse or treatment. These seal designs, when properly maintained and sufficiently emptied, may completely eliminate oil drips or leakage into surrounding waters since the leakage is captured in the void space and then drained internally and captured by the vessel.” – EPA

How we can help you

Whether you want a letter of technical infeasibility or more information about our – by DNV GL approved to be in line with VGP- sealing solutions Supreme Ventus and Supreme Athmos, we can help you.

Get in contact with our seal experts!

About the authors

Oscar Stienstra

Oscar studied mechanical engineering and logistics, supplemented with various QC & SHEQ related training courses. He is working for Lagersmit since 2000. The first 8 years as a planner and then as SHEQ Coordinator. He’s responsible for all SHEQ activities including all Class related issues.

Ashley van der Vlies

Ashley studied Communications at the Inholland University of Applied Sciences. After graduating in 2006, she has been working in various branches. She started at Lagersmit as an Online Marketeer early 2015. She is mainly responsible for generating leads through the online channels (website, social media, online advertising) and also for providing the content for these channels.

Read more about VGP & EAL!