### United States Environmental Protection Agency Office of Wastewater Management Washington, DC 20460

EPA 800

‐ R

‐ 11

‐ 002 November 2011 

# Environmentally Acceptable LubricantsExhaust Gas Scrubber Washwater Effluent Contents

ii CONTENTS

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1 I NTRODUCTION .................................................................................................................... 1 1.1 Marketing and Labeling .......................................................................................... 3

2 T YPES OF E NVIRONMENTALLY A CCEPTABLE L UBRICANTS .................................................. 4 2.1 Vegetable Oils ......................................................................................................... 4 2.2 Synthetic Esters ....................................................................................................... 4 2.3 Polyalkylene Glycols .............................................................................................. 5 2.4 Water ....................................................................................................................... 5

3 C ONSIDERATIONS FOR EAL S IN THE A QUATIC E NVIRONMENT ............................................ 6 3.1 Thickening Agents .................................................................................................. 6 3.2 Advantages and Disadvantages of Vegetable-based EALs .................................... 6 3.3 Advantages and Disadvantages of Synthetic Ester-based EALs ............................ 7 3.4 Advantages and Disadvantages of Po lyalkylene Glycol-Based EALs ................... 8 3.5 Availability and Cost of EALs ................................................................................ 8

4 D EFINING “E NVIRONMENTALLY A CCEPTABLE ” ................................................................. 10 4.1 Biodegradability .................................................................................................... 10 4.2 Aquatic Toxicity ................................................................................................... 11 4.3 Bioaccumulation ................................................................................................... 13 4.4 Summary of Environmentally Accepta ble Lubricant Characteristics .................. 14

5 E NVIRONMENTALLY A CCEPTABLE L UBRICANT L ABELING P ROGRAM ............................... 16 5.1 National Labeling Programs ................................................................................. 16 5.1.1 Blue Angel ................................................................................................ 16 5.1.2 Swedish Standard ...................................................................................... 16 5.2 International Labeling Programs........................................................................... 17 5.2.1 Nordic Swan.............................................................................................. 17 5.2.2 European Eco-label ................................................................................... 17 5.2.3 OSPAR ...................................................................................................... 19 5.3 Summary of Environmentally Acceptabl e Lubricant Labeling Programs ............ 19

6 C ONCLUSION ...................................................................................................................... 21

7 R EFERENCES ................................................................................................................... 7-22Environmentally Acceptable Lubricants

iii LIST OF TABLES

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1 Cost of EALs................................................................................................................. .......9 2 Internationally Standardized Test Me thods for Measuring Biodegradability ....................11 3 Summary of Differential Biodegradati on Rates by Lubricant Base Oils ..........................11 4 OECD Aquatic Toxicity Tests ...........................................................................................12 5 Summary of Comparative T oxicity of Base Oils ...............................................................12 6 Summary of Bioaccumulation Po tential by Base Oil Types .............................................14 7 Comparative Environmental Behavior of Lubricants by Base Oil Type ...........................15 8 Comparison of EAL Labeling Programs ...........................................................................20

LIST OF FIGURES

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1 Annual Oil Inputs into th e Marine Environment .................................................................2

The EPA contacts for this document are Ryan Albert (202) 564-0763 an d Brian Rappoli (202) 566-1548.Environmentally Acceptable Lubri cants Section 1 - Introduction

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## SECTION 1
INTRODUCTION

The purpose of this document is to describe the range of environmentally preferable lubricants that may be used as a best mana gement practice (BMP) by operators of vessels covered under the Vessel General Permit for Discha rges Incidental to the Normal Operation of Vessels (VGP) 1 . Within this document, the term environmentally acceptable lubricant (EAL) is used to describe those lubri cants that have been demonstr ated to meet standards for biodegradability, toxicity and bioaccumulation potential that minimize their likely adverse consequences in the aquatic environment, comp ared to conventional l ubricants. In contrast, lubricants that may be expected to have desirable environmenta l qualities, but have not been demonstrated to meet these standards, are refe rred to as environmentally friendly lubricants (EFLs) or biolubricants.

Lubricants lost from a vessel enter the aquati c environment, where serious damage to the aquatic ecosystem can occur. Consequently, ther e has been an emphasis on encouraging the use of EALs on vessels to protect the environment (Carter, 2009). Although their use is increasing, EALs comprise only a small percenta ge of the total lubricant market.

The significance of lubricant discharges (not a ccidental spills) to th e aquatic ecosystem is substantial. The majority of ocean going ships op erate with oil-lubricat ed stern tubes and use lubricating oils in a large nu mber of applications in on-d eck and underwater (submerged) machinery. Oil leakage from stern tubes, once considered a part of normal “operational consumption” of oil, has become an issue of concern and is now considered as oil pollution. Stern tube leakage is a significant source of lubr icant oil inputs to the aquatic environment. A 2001 study commissioned by the European Commission DG Joint Research Centre revealed that routine unauthorized operational discharges of oi l from ships in the Me diterranean Sea created more pollution than accidental spills (Pavlakis et al., 2001). Stern tube l eakage was identified as a major source of these discharges.

An analysis of data on oil consumption pe rformed by a lubricant supplier indicated a range of average daily stern tube lubricant consumption rates fo r different vessels (Etkin, 2010). The average rate across vessel t ypes was 2.6 liters per day, but range d from less than 1 liter per day to 20 liters per day. Because it is comm on practice to use the lubricant supplied for the vessel’s main engines as the stern tube lubrican t to minimize the number of lubricants held on board, the amount which is used in stern tubes and released to the sea is not recorded.

Engine oil formulations have the correct char acteristics (e.g., viscosity) to fulfill the role of lubricants specifically formulated for stern tubes. However, engine oil additives, which can be up to 30% of the formulation, are strongly alkaline (to neutralize the acids formed during fuel combustion). Consequently, due to the nature of engine oil additives, this practice greatly increases the toxic effects of stern tube discharges.

1 The 2008 VGP encourages vessel owners and operators to use environmentally prefer able lubricants whenever possible.Environmentally Acceptable Lubri cants Section 1 - Introduction

2 In addition to spills and stern t ube leakage, there are “operati onal inputs” of lubricant oils that occur due to continuous low- level discharges and leakages that occur during normal vessel operations in port. The sources of operational di scharges include deck machinery and in-water (submerged) machinery. There are a number of syst ems situated below the waterline that must be lubricated. The main systems to consider are the stern tube bearing, thruster gearboxes, and horizontal stabilizers. All of th ese have pressurized lubricatin g oil systems that maintain a pressure higher than the surrounding sea. This en sures that no significant amount of seawater can enter the oil system, where it w ould compromise the unit’s reliab ility. However, any leakage of lubricant oil flows into the sea.

A 2010 study estimated the marine inputs of lubricant oils within the 4,708 ports and harbors of the world through stern tube leakage and operational di scharges from marine shipping (Etkin, 2010). The study results indicate that commercial vessels make over 1.7 million port visits each year and leak 4.6 to 28.6 million liters of lubricating oil from st ern tubes. In addition, 32.3 million liters of oil is introduced to marine waters from other operational discharges and leaks. In total, operational discharges (incl uding stern tube leakage) input 36.9 to 61 million liters of lubricating oil into marine port waters annually – the equivalent of about one and a half Exxon Valdez-sized spills. Assumi ng that the higher estimate of stern tube leakage is representative of the inputs that may occur in port as well as in transit, the total estimated input of lubricating oil from leakage and operational discharges represents nearly 61 million liters annually worldwide. Leaks of lubricating oil repr esent 10 percent of the total oil inputs into marine waters, as estimated in the 2003 NRC Oil in the Sea study (see Figure 1). The total annual estimated response and damage costs for these leaks and operational discharges are estimated to be about $322 million worldwide. Total estimated costs for the U.S. are estimated to be $31 million annually (Etkin, 2010).

Based on Etkin, 2010 and NRC, 2003

Figure 1. Annual Oil Inputs into the Marine Environment

The following sections of this document desc ribe the main types of EALs in current production; considerations for EALs in th e aquatic environmen t; the standards for biodegradability, toxicity and bioaccumulation po tential of EALs; the potential advantages and disadvantages of using EALs on board co mmercial vessels; and labeling programs.Environmentally Acceptable Lubri cants Section 1 - Introduction

3 1.1 M ARKETING AND L ABELING
Although EALs have been in commercial produ ction for years, they comprise a small portion of the total lubricant market and are stil l regarded as niche products (Habereder et al., 2008). The market for EALs continues to expand, pa rticularly in Europe, where the use of such lubricants is being encouraged through a combin ation of tax breaks, pur chasing subsidies, and national and international labeli ng programs based on well-defined criteria. Many lubricants are advertised as being environmentally preferable ; however, currently there are no regulatory standards for EALs, and no internationally a ccepted term by which they are defined. To distinguish lubricants which have been shown to be both biodegradable and non-toxic according to acceptable test methods from those lubri cants that are simply marketed as being “environmental” (or similar term inology), in their 1999 Lubricants and Hydraulic Fluids Manual, the US Army Corps of Engineer s recommended use of the term “environmentally acceptable” (a term commonly used by American Society for Testing and Materials (ASTM) committees) to address environmental lubricants. Bioaccumulation potential was not addressed within this definition of EALs.

While numerous terms are presently used to advertise lubricants as having desirable environmental properties, there is growing consensus to use the term “environmentally acceptable” to denote a lubricant that is biodegradab le, exhibits low toxicity to aquatic organisms and has a low potential for bioaccumulation. Alth ough many tests for these qualities exist, there is also harmonization underway within the lubricant manufac turing community regarding the most appropriate standard testing methods fo r these and other qualities determined to be important for an EAL, such as the proportion of renewable (recyclable) materials used in manufacturing. An environmentally acceptable lubr icant should still perform well in comparison to the conventional lubricant it replaces. This harmonization is being driven by national and international labeling programs, particularly in European nations where the testing procedures and criteria have been codifi ed (Habereder et al., 2008 a nd IENICA, 2004). These labeling requirements, while not regulated by law, have helped to clarif y the difference between EAL and EFL products in the marketplace.

Because the majority of a lubri cant is composed of the base oil, the base oil used in an EAL must be biodegradable. The three most common categories of biodegradable base oils are: 1) vegetable oils, 2) synthetic es ters, and 3) polyalkylene glycols. Due to the low toxicities of these three types of base oils, aq uatic toxicity exhibited by lubri cants formulated from them is typically a consequence of the performance enhancing additives or thickening agents (found in greases) used in the formulation, which can vary widely.Environmentally Acceptable Lubri cants Section 2- Types of Envi ronmentally Acceptable Lubricants

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## SECTION 2
TYPES OF ENVIRONMENTALLY ACCEPTABLE LUBRICANTS

Environmentally acceptable lubricants are comm only classified according to the type of base oil used in their formulation. In general, lubricants consist of approximately 75 to 90 percent base oil. Greases contai n approximately 10 percent thicke ning agent, which is usually a soap (Gow, 2009), in addition to the base oil. Th e remaining fraction of a lubricant formulation consists of performance enhancing additives. A lubricant formulation can include hundreds of additives, which address performance issues sp ecific to their applic ation and performance shortcomings of the base oil. Additives are co mmonly used to address oxidative aging, corrosion, high pressure, low or high temperature condi tions, phase transition, shear, foaming, and hydrolysis (particularly for vege table and synthetic ester-based oils) (Habereder et al., 2008).

The number of additives that are compatible with vegetable oils, synthetic esters, or polyalkylene glycols is small relative to the number of additives that are compatible with conventional (mineral) base oils. However, this is changing as a result of increased emphasis on EAL development. Additive manufac turers are working more closel y with the lubricant industry to design additives that are suitable for improving the performance of EALs that are more environmentally benign (Aluyor et al. 2009). For some of the more stringent labeling programs (see Section 5), additives used in EAL must be both ashless (i.e., containing no metals other than Ca, Na, K, Mg) and non-toxic (H aberader et al. 2009). Among th e soaps, calcium-based soaps are considered less toxic co mpared to other types (e.g

. , lithum-based), and soaps in general are considered less toxic than gr aphite thickeners (Gow, 2009).

2.1 V EGETABLE O ILS
The main components of vegetable oils are tr iglycerides (natural esters), the precise chemical nature of which is dependent on both the plant species and strain from which the oil is obtained (Haberader et al., 2008 and Nelson, 2000). Outside the U. S., rapeseed is the most commonly used crop for creating vegetable oil lu bricants (Cuevas, 2005 and Habereder et al., 2008). In the U.S., the most commonly used crops for producing vegetabl e oil lubricants are canola, soybeans, and sunflowers (Nelson, 2000).

Largely because of performance issues relate d to low thermo-oxida tive stability and poor cold flow behavior, pure vegetabl e oil-based lubricants comprise a relatively small fraction of the biolubricant market, although recent research deve lopments have shown promise for overcoming these shortcomings (Erhan et al., 2006 and Kabir et al., 2008). Another reason is that vegetable oil-based lubricants are much le ss available than synthetic este rs (Bremmer and Plonsker, 2008). To date, their most common commercial applic ations include hydraulic fluid and wire rope
grease.

2.2 S YNTHETIC E STERS
Lubricants based on synthetic esters have b een in production longer than any other class of biolubricant and were first used for jet engine lubric ation in the 1950s. Synt hetic esters can be prepared by the esterification of biobased materials (i.e., some combination of modified animal fat and vegetable oil). Because synthetic esters can be specifically tailored for their intendedEnvironmentally Acceptable Lubri cants Section 2- Types of Envi ronmentally Acceptable Lubricants

5 application, they have many performance advantag es over pure vegetable oils, and are used as the base oil in lubricants for many vessel applications, including hydraulic oil, stern tube oil, thruster oil, gear lubricant, and grease (ACE , 1999 and Habereder et al., 2008). Synthetic estersbased EALs are developed and marketed by se veral major oil companies including British Petroleum, Chevron, Exxon/Mobil and Gulf, and ar e currently the most widely commercially available class of EAL.

2.3 P OLYALKYLENE G LYCOLS
Polyalkylene glycols (PAG) are synthetic lu bricant base oils, typically made by the polymerization of ethylene or propylene oxide (Brown, 1997). Depending on the precursor, they can be soluble in either oil (propylene oxide) or water (et hylene oxide) (Greaves, 2008 and Habereder et al., 2008). Although th ey are made from petroleum-based materials, PAGs can be highly biodegradable, particularly the water soluble PAGs (Greav es, 2008; Sada et al., 2008; and Sada et al., 2009).

2.4 W ATER
At least one company has developed a complete ly seawater-lubricated stern tube system that uses non-metallic bearings in place of metal bearings. This system is currently in place in over 500 commercial vessels, includi ng several Carnival Corporation cruise ships (Carter, 2009).Environmentally Acceptable Lubricants Section 3- Considerations for EALs in the Aquatic Environment

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## SECTION 3 CONSIDERATIONS FOR EALS IN THE AQUATIC
ENVIRONMENT

A number of factors must be considered when selecting lubricants for use in the aquatic environment. Vessels require a variety of lubrican ts for different applicat ions and on-ship storage can be limited. Consequently, the most useful lu bricants are those that can perform well in a variety of applications (Rana, 2001). Additionally, lubricants must be widely available; in the case of some larger ocean going vessels, compatib le lubricants must be available at ports around the globe (Blanken, 2006).

Marine environments are characterized by hi gh humidity conditions, and seawater ingress can pose serious lubrication problems in sealed compartments, such as stern tubes and hydraulic systems (Rana, 2001). Stern tube seals are highly susceptible to leakage, both from normal operations, including vibrations a nd misalignment, and from contac t with nets or fishing lines (Sada et al., 2008 and Carter, 2009). The constant presence of seaw ater increases the potential for corrosion, requiring thicker greases to repe l water and corrosion inhibitors to minimize corrosion following seawater ingress. In addition, lubricants subject to frequent contact with water have a greater likeli hood of undergoing some degree of biodegradation (ACE, 1999).

3.1 T HICKENING A GENTS
Stiffer greases (i.e., National Lubricating Greas e Institute grade 3 or higher) are typically used in marine applications as they repel wate r more effectively. Lithium-based thickeners are the most commonly used thickening agents, as they are considered to have the best all-purpose formulation. Although they comprise a much sm aller fraction of the grease market, calciumbased thickeners do perform well under cool, wet conditions, and are used in formulations for some marine applications (e .g., propeller housing and water pumps). Anhydrous calcium-based greases are becoming increasingly common in Eu rope, where there is a greater emphasis on adoption of EALs, because of their relatively low toxicity and better performance at higher temperatures (Gow, 2009).

3.2 A DVANTAGES AND D ISADVANTAGES OF V EGETABLE
- BASED EAL S

In addition to their environm ental benefits (i.e., high biodegradability and low aquatic toxicity), vegetable oils possess several advantageous performance qualities compared to mineral oils. They have a higher viscosity index (m eaning they do not thin as readily at high temperatures) and they have a higher lubricit y, or ability to reduce friction (Nelson, 2000; IENICA, 2004). Vegetable oil-base d lubricants also have a hi gh flash point, meaning they combust at higher temperatures than conventiona l mineral oils. They perform well at extreme pressures, and do not react with pain ts, seals, and varnishes (ACE, 1999).

Vegetable oils possess several major perf ormance drawbacks, however, which have limited their use in the formulation of EALs. The primary limitations are (1) poor performance at both low and high temperatures a nd (2) oxidative instabil ity (Erhan et al., 2006 and Habereder et al., 2008). Vegetable oils thicken more than minera l oils at low temperatur es and are subject toEnvironmentally Acceptable Lubricants Section 3- Considerations for EALs in the Aquatic Environment

7 increased oxidation at high temperatures, resulti ng in the need for more frequent oil changes. These shortcomings can be addressed with the us e of selected additives for a formulation or through the selective breeding and us e of high-oleic oils (i.e., oils that contain more oleic acid, a monounsaturated fat, and less pol yunsaturated fats) that are less susceptible to oxidative instability. The use of selected additives can increase production costs and may decrease the overall environmental acceptab ility of the product (Nelson, 2000; Bremmer and Plonsker, 2008). In addition, vegetable oils remove mineral oil de posits, resulting in the need for more frequent oil filter service.

Vegetable oil lubricants are more expensive th an comparable mineral oil lubricants, as a function of both higher base oil costs, as well as higher costs for the base oil-compatible additives (ACE, 1999). Although Mill er (2008) stated that vege table oil lubricants cost approximately double that of mineral base oi ls, more recent inform ation obtained through personal communication with a major lubricant supplier suggests that the current cost premium for these biolubricants may be only 20% more. Changing from a mineral to a vegetable oil lubricant is relatively simple, as vegetable oils and mineral oils are compatible and vegetable oil lubricants will perform properly if some mine ral oil residue remains. Because the overall formulations are less toxic, disposal costs are ge nerally lower; however, this may not always be the case, as fewer disposal stations are able to accept spent biobased lubricants (ACE, 1999; Nelson, 2000; and Bremmer and Plonsker, 2008).

3.3 A DVANTAGES AND D ISADVANTAGES OF S YNTHETIC E STER

- BASED EAL S
Synthetic esters perform well across a wide range of temper atures, have a high viscosity index, possess high lubricity, provide corrosion pr otection, and have high oxidative stability (ACE, 1999 and Habereder et al., 2008). Because th ey contain biobased material, many synthetic esters satisfy testing requirements for biodegrad ability and aquatic toxicity, although they tend to be less readily biodegradable th an pure vegetable oil-based lu bricants (WISE Solutions, 2006). Synthetic ester-based lubricants can be more or less toxic than vegetable oil-based lubricants, depending on the aquatic toxicity of the additi ves used in the formulation. The only notable performance issue with synthetic esters is that th ey are incompatible with some paints, finishes, and seal materials (ACE, 1999).

Synthetic esters are generally the most expe nsive class of EAL (Mil ler, 2008). Synthetic ester-based biolubricants cost ap proximately 2-3 times that for comparable conventional mineral oil-based lubricants. As the availability of s ynthetic ester-based EALs increases, this cost differential is expected to decline.

The relatively higher cost of synthetic es ters is somewhat m itigated by their high oxidative stability, which results in longer lubricant life. This is particularly applicable to areas of the vessel that require more frequent lubricant changes (e.g., engine oil, hydraulic fluid, stern tube-thruster fluid). Synt hetic esters are compatible with mi neral oil, which reduces changeover costs, but similar to vegetable oi ls in that their effectiveness at removing mineral oil deposits can cause filters to clog during the period initia lly following lubricant changeover (ACE, 1999). Disposal costs are similar to those for vegetable oil-based lubricants.Environmentally Acceptable Lubricants Section 3- Considerations for EALs in the Aquatic Environment

8 3.4 A DVANTAGES AND D ISADVANTAGES OF P OLYALKYLENE G LYCOL -B ASED EAL S
Lubricants consisting of polyalkylene glyc ols (PAGs) have the best overall low- and high-temperature viscosity performance among all of the classes of biol ubricants. For marine applications, water soluble PAG EALs are attractive because, in addition to their high biodegradability, they retain th eir performance characteristics fo llowing water influx better than other EALs; as a result, PAG EALs have received consideration as a stern tube lubricant (Sada et al., 2008; Sada et al., 2009). The water solubility of ethylene oxide-derived PAGs can improve performance relative to other l ubricants by maintaining viscosit y following some fraction of water influx (up to 20% in some laboratory tests), which can be of great importance for stern tube lubrication (Sada et al., 2008; Carter, 2009). PAGs also perf orm well in terms of lubricity, viscosity index, and corrosion protection. The relativ ely high viscosity and l ubricity of PAGs has resulted in the recent development of PAG-ba sed thruster lubricants (Sada et al., 2009).

Disadvantages associated with PAGs are that they are incompatible with mineral oils, as well as most paints, varnishes, and seals (A CE, 1999; Sura et al., 2008). Because of this incompatibility, they have the highest changeove r costs of any class of EAL (Sada et al., 2008). Additionally, water soluble PAGs may demonstrate increased toxi city to aquatic organisms by directly entering the water column and sediment s rather than remaining on the water column surface as a sheen (Habereder et al., 2008).

3.5 A VAILABILITY AND C OST OF EAL S
At the present, the global availability of EALs for different mari ne applications is growing. One manufacturer of marine EALs, Ca strol Bio Range, provided data demonstrating that stern tube and thruster lubr icant, hydraulic fluids, gear lubr icants and grease were available in the following global regions and countries (P earce et al., 2010; Ca strol Marine, 2011):

 Americas: USA;

 Northern Europe: Belgium, Denmark, Finland, France, Germany, Netherlands, Norway, Sweden, UK;

 Mediterranean: Italy, Spain, Turkey, UAE; and

 Asia-Pacific: China, Japan, Hong Kong, Singapore, Korea.

Market cost data for EALs are unavailable, b ecause manufacturers consider such data to be proprietary marking information. The purchas e prices of EALs are guarded closely by the manufacturers, and EPA has generally been unable to obtain publicly available cost information from EAL manufacturers. Operating costs for sh ip-owners and charterers using environmentally preferable lubricants are exp ected to increase modestly re lative to conventional products, although there can be efficiency gains from longer life (e.g., reduced corrosive properties, enhance water contamination performance). Howe ver, the benefit of using environmentally preferable lubricants can be considerable in terms of reduced environmental impacts.

Some indication of the cost of EALs relative to conventional lubricants was provided by a major lubricant vendor and is tabulated in Ta ble 1. Some specialized lubricants may have higher costs.Environmentally Acceptable Lubricants Section 3- Considerations for EALs in the Aquatic Environment

9 Table 1. Cost of EALs

Lubricant Base Oil Ratio of EAL cost to Conventional Mineral Oil Lubricant Cost Mineral Oil 1 Vegetable Oils 1.2 Synthetic Esters 2 to 3 Polyalkylene Glycols 2 to 3

An informal survey of websites for th e boating supply distributors West Marine, Jamestown Distributors, Aerospace Lubricants, In c. and Aqua Lube, demonstrates that semisynthetic ester and full synthetic ester engine o il, gear oil, and greases are the most commonly available biolubricants for recreational vesse l owners. The costs of full synthetic ester formulations (primarily two cycl e and four stroke engine oils) range from 1.4-1.8 times the costs of comparable conventional (miner al oil) formulations. These di stributor website s do not provide information as to whether any of the syntheti c ester-based biolubricants meet certification standards that would classify th em as EAL. For commercial vessels , relative pricing information for Gulf Oil marine lubricants reveals that costs for biolubricants advertis ed (synthetic gear oil, compressor oil, and coolant oil, the three synthe tic lubricants), ranged from approximately 1.3- 2.5 times (coolant oil) to 3.5-4.3 times (gear oil and compressor oil) the cost for comparable mineral oil products (Gulf Marine, 2010). It may be reasonable to assume that the cost premium for EALs is similar to these price ratios.

Many countries, primarily in Europe, encour age the manufacture and consumption of EALs. Examples are through tax exemptions on environmentally acceptable base oils, taxes on mineral oils, subsidies to consumers to cove r the price difference between conventional and EALs, or preferential purchasing programs that re quire a percentage of ce rtain classes of product to be made from renewable resources (Hab ereder et al., 2008; IENICA, 2004; and WISE Solutions, 2006).Environmentally Acceptable Lubricants Secti on 4 - Defining “Envir onmentally Acceptable”

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## SECTION 4
DEFINING “ENVIRONMENTALLY ACCEPTABLE”

Lubricants may be labeled using a variet y of terms to signify that they are environmentally friendly. Although EFLs are most likely to be tested for biodegradability, aquatic toxicity and bioaccumulation potential, th ere are numerous other methods, which vary in their sensitivity.

4.1 B IODEGRADABILITY
Biodegradability is a measure of the breakdown of a chemical (or a chemical mixture) by micro-organisms. Primary biodegradation is the loss of one or more active groups in a chemical compound that renders the compound inactive with regard to a partic ular function (Betton, 2009). Primary biodegradation may result in the c onversion of a toxic compound into a less toxic or non-toxic compound. Ultimate biodegradation, also referred to as mineralization, is the process whereby a chemical compound is converted to carbon dioxide, water, and mineral salts (Betton, 2009).

In addition to primary and ultimate biodegrad ation, biodegradation is also defined by two other operational properties: inherent biodegradability and ready biodegradability. A compound is considered inherently biodegradable so long as it shows evidence of biod egradation in any test for biodegradability. Readily biodegradable is an operational de finition that some fraction of a compound is ultimately biodegradable within a speci fic timeframe, as specified by a test method.

Common test methods, such as those deve loped by the Organization for Economic Cooperation and Development (OECD), the Coor dinating European Council (CEC), and the American Society for Testing and Materials (AST M), for determining lubricant biodegradability are OECD 301B (the Modified Strum test ), ASTM D-5864, and CEC L-33-A-934. Both OECD 301B and ASTM D-5864 measure ready biodegradabil ity, defined as the conversion of 60% of the material to CO 2 within a ten day window following the onset of biodegradation, which must occur within 28 days of test initiation (Willing, 2001). In contrast, the CEC method tests the overall biodegradability of hydr ocarbon compounds and requires 80 % or greater bi odegradability as measured by the infrared absorbance of extractable lipophilic compounds (CEC, 1997 and WISE Solutions, 2006). Unlike the OECD a nd ASTM methods, the CEC method does not distinguish between primary and ultimate biodegr adability, and is considered to be a less stringent test (Blanken, 2006).

Table 2 lists some of the internationally standardized test methods that measure biodegradability.Environmentally Acceptable Lubricants Secti on 4 - Defining “Envir onmentally Acceptable”

11 Table 2. Internationally Standardized Test Methods for Measuring Biodegradability

Test Type Test Name Measured Parameter a Pass Level b Method
Ready Biodegradability (A substance is considered to be inherently biodegradable using any of these tests if it shows

> 20% biodegradability within the test duration) DDAT DOC > 70% OECD 301A Strum test CO 2 > 60% OECD 301B MITI test DOC > 70% OECD 301C Closed bottle test BOD/COD > 60% OECD 301D MOST DOC > 70% OECD 301E Sapromat BOD/COD > 60% OECD 301F Strum test CO 2 > 60% ASTM D-5864 Shake flask test CO 2 > 60% EPA 560/6-82-003 BODIS test BOD/COD > 60% ISO 10708
Hydrocarbon degradability CEC test Infrared Spectrum > 80% CEC L-33-A-934

Screening tests (semi-official) CO 2 headspace test CO 2 > 60% ISO 14593 Source: modified from Willing, 2001 a. DOC – dissolved organic carbon; CO 2 – carbon dioxide; BOD – biochemical oxy gen demand; COD – chemical oxygen demand b. Ready biodegradability is de fined as complete mineralizati on of a compound into water, carbon dioxide, and mineral salts according to a specific test criterion. Pass levels indicate the percentage of complete mineralization (or ultimate biodegradat ion) as indicated by the “Measured Parameter” that must occur for a product to be classified as readily biodegradable.

Table 3 summarizes biodegradati on rates for different lubricant base oils. Ester-based oils have a much greater inherent biodegradation rate due to the presence of carboxylic acid groups that bacteria can readily util ize (Mudge, 2010). These compounds are also more water soluble than compounds that do not c ontain polar functional groups, th e absence of which can reduce their bioaccumulation potential.

Table 3. Summary of Differential Biodegra dation Rates by Lubricant Base Oils

Lubricant base oil Base oil source Biodegradation Mineral oil Petroleum Persistent / Inherently Polyalkylene glycols (PAG) Petroleum - synthesized hydrocarbon Readily Synthetic Ester Synthesized from biological sources Readily Vegetable Oils Naturally occurring vegetable oils Readily Source: Mudge, 2010

4.2 A QUATIC T OXICITY
In addition to possessing a certain percentage of readily biodegradable material, an EAL must also demonstrate low toxici ty to aquatic organisms. Test methods to demonstrate toxicity include the OECD tests series 201-4, and 209-212; and corresponding USEPA environmental effect test guidelines from EPA 560/6-82-002. The most common aquatic toxicity tests for assessing EALs are the 72-hour growth test for algae (OECD 201), the 48-hour acute toxicity test for daphnia (OECD 202), and the 96 -hour toxicity test for fish (OECD 203). Analogous USEPA tests are sections EG-8, EG- 1, and EG-9 of EPA 560/6-82-002 for algae, daphnia, and fish, respectively. A listing of all of the OECD aquatic toxicity test s is included in Table 4.Environmentally Acceptable Lubricants Secti on 4 - Defining “Envir onmentally Acceptable”

12 Table 4. OECD Aquatic Toxicity Tests

Test Title, with Species Test Number Growth Inhibition Test, Alga OECD 201 Acute Immobilization Test, Daphnia sp. OECD 202 Acute Toxicity Test, Fish OECD 203 Prolonged Toxicity Test: 14-Day Study, Fish OECD 204 Respiration Inhibition Test, Bacteria OECD 209 Early-Life Stage Toxicity Test, Fish OECD 210 Reproduction Test, Daphnia magna OECD 211 Short-term Toxicity Test on Embryo and Sac-fry Stages, Fish OECD 212

In general, the vegetable oil and synthetic es ter base oils have a low toxicity towards marine organisms with the LC 50 for fish toxicity reported as being ~10,000 ppm for fatty acid esters and glycerol esters (see Table 5) (v an Broekhuizen, 2003). Water soluble PAGs may demonstrate increased toxicity to aquatic orga nisms by directly entering the water column and sediments rather than remaining on the water column surface as a sheen (Habereder et al. 2008).

Table 5. Summary of Comparativ e Toxicity of Base Oils

Lubricant base oil Base oil source Toxicity Mineral oil Petroleum High Polyalkylene glycols (PAG) Petroleum - synthesized hydrocarbon Low a Synthetic Ester Synthesized from biological sources Low Vegetable Oils Naturally occurring vegetable oils Low Source: Mudge, 2010 a. Solubility may increase the toxicity of some PAGs

As with many oily chemicals, the toxicity in some tests is not measureable as the LC 50 exceeds the water solubility of the compound (Mudge, 2010). In such cases, it is possible to induce physical effects such as smothering but this is not a chemical toxic effect. Some methodologies use the water-accommodated fraction, the part of the oil that disperse or dissolves in water, although this is not a true reflecti on of the entire oil behavior in the marine environment.

The petroleum-based oils have a greater to xicity to biota in the marine food chain compared to the other base oil sources (Mudge , 2010). This is relate d to the more rapid breakdown of petroleum-based oils once in the sea, which ultimately affects the potential for bioaccumulation. The toxicity of petroleum-based o ils is also dependent upon additives used in formulations and metabolites produced in biodegradation.

The use of additives is dependent on the choice of base oil and the intended function of the lubricant (Mudge, 2010). However, several of the more toxic compounds in formulations are also the ones with poor degradab ility. The overall product toxicity may be significantly reduced by switching to a biologically-sourc ed base oil used in conjunction with low toxicity additives.Environmentally Acceptable Lubricants Secti on 4 - Defining “Envir onmentally Acceptable”

13 4.3 B IOACCUMULATION
The propensity of a substance to bioaccumulate is another prop erty of a lubricant that is often considered in the qualif ication of a product as an EAL (Mudge, 2010). Bioaccumulation is the build-up of chemicals within the tissues of an organism over time. The longer the organism is exposed to a chemical and the longer the organi sm lives, the greater th e accumulation of the chemical in the tissues (Mudge, 2010). If the ch emical has a slow degr adation rate or low depuration rate within an organism, concentrat ions of that chemical may build-up in the organism’s tissues and may eventually lead to adverse biological effects. It is, therefore, desirable to use compounds in fo rmulations that do not bioaccumul ate. It may not be possible to phase out all bioaccumulating compounds, but it is feasible to use chemicals that have a lower bioaccumulation potential, either through not bein g taken up as readily or by degrading more quickly both in the environment and in the organism.

The bioaccumulation potential of a compound is di rectly related to its water solubility; chemicals that are not water sol uble tend to move into fatty tissu es rather than to staying in water. These lipophilic chemicals include most of the compounds used in the manufacture of the base oil in lubricants. The water solubility of a compound is relate d to the type of atoms in the molecule; compounds comprised solely of car bon and hydrogen tend to have the lowest solubility in water. Compounds of this type in cludes alkanes, which form almost 90% of the current base oil in conventiona l lubricant formulations. The in clusion of one or more oxygen atoms in a molecule will, in general, increase the water solubility and reduce bioaccumulation. Compounds with oxygen also tend to degrade more quickly in the environment or be excreted faster from organisms.

Many naturally-derived base oi ls used in lubricants are formulated around carboxylic acids, which increase water solubility and degrada tion; therefore, their bioaccumulation potential is reduced in comparison to alkane-based oils.

It has been assumed for some time that larger molecules are not bioaccumulated as they are unable to physically pass through the membranes of cells and be incor porated into the living cells (Arnot et al., 2010). Theref ore, when designing lubricant fo rmulations, the molecular size of the components of the base oil are considered as they will direc tly affect the rate of uptake. There has been several criteria pr oposed over the past few years to describe the point at which chemicals are no longer taken up in the body and bioaccumulated (Arnot et al., 2010). In an evaluation of data for esters, ther e was a strong link between the log K ow (the logarithm of the partitioning coefficient of a substance in n-octano l and water) and the log BCF (a measure of the bioconcentration from water into aquatic organisms), while th e other factors had less welldefined relationships. The selec tion criteria chosen by the Ca nadian Government and United Nations Environment Program (UNEP) (Canada, 2000 and UNEP, 2001) and the U.S. Environmental Protection Agency (U SEPA, 1999) led to cut-off log K ow values of ~5. There is no single criterion to adequate ly describe the BCF; one study proposes a holistic approach integrating several factors, incl uding measured uptake and elimina tion rates (Arnot et al., 2010).

Certain labeling programs, most notably the European Eco-la bel (see Section 5), require demonstration that a product is not bioaccumulative. This can be accomplished in a number of ways for organic compounds, such as measuring log K ow , or BCF. The two most common testEnvironmentally Acceptable Lubricants Secti on 4 - Defining “Envir onmentally Acceptable”

14 methods for establishing bioaccumulation potenti al are OECD 117 and 107. For these tests, the test substance is added to a mixture of octanol and water and its dissolution in each phase is detected using gas chromatography or an infr a red detector. The bi oaccumulation of the substance is measured by establishing its partition coefficient (expressed as log K ow ) in octanol and water. Substances that have a tendency to bioaccumulate will prefer entially dissolve in the octanol rather than the water, and octanol mimics the fatty tissue in an organism. Therefore, the greater the log K ow , the greater the likelihood that the substance will bioaccumulate.

Partition coefficients for th e marine environment are normally measured on a log scale between 0-6. Substances with log K ow <3 are deemed not to bioaccumulate and those with log K ow >3 are deemed to be bioaccumulating.

Seawater may increase the like lihood of uptake by organisms in comparison to freshwater due to “salting out” of lipophilic substances. Therefor e, although freshwater is used in these test methods, as long as conservative acceptance limits ar e set, they can be used as an indicator of bioaccumulation potential in the marine environm ent. The use of these test methods as an indicator of a substance’s bi oaccumulation potential can negate the need to carry out in vivo or in vitro fish or mussel testing.

In summary, the level to which a component of the product is bioaccumulated in an organism is dependent on the environmental an d biological half-lives of the compounds (some will degrade before being incorporated into an or ganism and some will be metabolized within the organism), as well as the lipophilic nature of the compounds (as measured by water solubility). Any component that has low water solubility may potentially bioaccumulate in an organism. In the case of lubricants, fatty acid-containing co mponents have reduced bioaccumulation potential due to greater water solubility and higher biodegrad ation rates. This is on e distinct advantage in using esters over the other carbon and hydr ogen alone base oil types (see Table 6).

Table 6. Summary of Bioaccumulation Potential by Base Oil Types

Lubricant base oil Base oil source Potential for Bioaccumulation Mineral oil Petroleum Yes Polyalkylene glycols (PAG) Petroleum - synthesized hydrocarbon No Synthetic Ester Synthesized from biological sources No Vegetable Oils Naturally occurring vegetable oils No Source: Mudge, 2010

4.4 S UMMARY OF E NVIRONMENTALLY A CCEPTABLE L UBRICANT C HARACTERISTICS
A summary of the major factors regarding biodegradation, toxicity and bioaccumulation potential, for each of the base oil types is shown in Table 7 . In this table, the three major criteria are presented for each base oil and color-coded to indicate the environmental outcome. The biodegradability of a lubri cant reflects that of the lubricant’s ba se oil, while the degree of aquatic toxicity is typically a conseque nce of the performance enhancing additives (or thickening agents) within the formulation. The base oils that degrad e quickly are considered more preferable than those that do not rapidly degrade, although there might be a trade-o ff with regard to the depletion of oxygen during compound metabolism. The com pounds that do not bioaccumulate and areEnvironmentally Acceptable Lubricants Secti on 4 - Defining “Envir onmentally Acceptable”

15 relatively less toxic are consider ed more preferable than thos e that bioaccumulate and have higher toxicities.

Table 7. Comparative Environmental Behavi or of Lubricants by Base Oil Type

Lubricant base oil Base oil source Biodegradation Potential for Bioaccumulation Toxicity

Mineral oil Petroleum Persistent / Inherently Yes High
Polyalkylene glycols (PAG) Petroleum - synthesized hydrocarbon Readily No Low a
Synthetic Ester Synthesized from biological sources Readily No Low
Vegetable Oils Naturally occurring vegetable oils Readily No Low

Source: Mudge, 2010 a. Solubility may increase the toxicity of some PAGs

Currently, a majority of lubricant base oils (mineral oils) have the lowest biodegradation rate, a high potential for bioaccu mulation, and a measurable toxici ty towards marine organisms. In contrast, the base oils deri ved from oleochemicals (vegetab le oils and synthetic esters) degrade faster, have a smaller residual, do not bioaccumulate appreciably and have a lower toxicity to marine organisms. PAG-based lubric ants are also generally biodegradable and do not bioaccumulate; however, some PAGs may be more t oxic due to their solubility in water. On the basis of this simple comparison, lower environmen tal impacts will arise if a greater proportion of base oils are manufactured from biologically-sourced materials.Environmentally Acceptable Lubrican ts Section 5 - Environmentally Acceptable Lubricant Labeling Program

16 

## SECTION 5
ENVIRONMENTALLY ACCEPTABLE LUBRICANT LABELING
PROGRAM

To minimize confusion in the marketplace a nd to increase public awareness and create sensitivity for environmentally preferable produc ts, national and internat ional labeling programs have been developed, primarily in Europe (H abereder et al., 2008). These labeling programs have defined and established methods to measure the properties of a lubri cant that would qualify it as being environmentally acceptable. The la beling programs can aid the purchasing decisions of a vessel operator by helping to remove uncer tainty. The principal national and international labeling certification programs for biolubr icants and EALs are presented below.

5.1 N ATIONAL L ABELING P ROGRAMS

5.1.1 Blue Angel

The first national labeling scheme for lubr icants was the German Blue Angel label, developed in 1988. Criteria have been develope d for several classes of lubricants, including hydraulic fluids, lubricating oils , and greases. In order to qua lify for certifica tion, a lubricant must possess the following characteristics: biodegr adability; low toxicity to aquatic organisms; non-bioaccumulative; and no dangerous components (such as carcinogens or toxic substances as defined by Germany’s Ordinance on Hazardous Subs tances). A product must also pass technical performance characteristics appropriate for its us e. Biodegradability can be demonstrated using OECD tests 301B-301F to measure ultimate bi odegradability or CEC L-33-A-934 to measure primary biodegradability. Blue Angel’s requirement for ultimate biodegradability is the primary difference between the Blue Angel labeling certification program and other national and international certification programs. Aquatic toxi city is determined according to OECD 201-203.

Products receiving the Blue Angel certificati on must also pass a series of technical performance requirements that depend on the cl ass of lubricant. Unlik e some of the other labeling programs, the Blue Angel certification do es not have any requirements for renewability; consequently, lubricants comprised completely of petroleum-sourced components can receive Blue Angel certification. Neverthe less, Blue Angel certification is considered rather stringent, and the proportion of lubricants receiving this cer tification remains low, w ith the majority being hydraulic fluids (Habereder et al., 2008). A comple te list of all lubricants that carry the Blue Angel certification can be found at http://www.blauer-e ngel.de/en/products_brands/ search_products/search_for_products.php.

5.1.2 Swedish Standard

Another national labeling scheme for lubricants is the Swedish Standard, which includes standards for hydraulic fluids (SS 155434) and greases (SS 155470). Eval uation of a lubricant under the Swedish Standard involves testing for bi odegradability and aquatic toxicity, as well as sensitizing properties of a lubri cant formulation and its components (Habereder et al., 2008). The Swedish Standard evaluates biodegradability using ISO test methods (e.g., ISO 9439), and has varying requirements, depending upon class, fo r renewable resources content (SP 2010). TheEnvironmentally Acceptable Lubrican ts Section 5 - Environmentally Acceptable Lubricant Labeling Program

17 Swedish Standard is unique because it was con ceived and developed as a collaborative project between government and industry. This program ha s more listed lubricant products, particularly hydraulic fluids, than any other natio nal labeling program (IENICA, 2004).

5.2 I NTERNATIONAL L ABELING P ROGRAMS

5.2.1 Nordic Swan

The first international labeling program for EALs was the Nordic Swan program, encompassing Norway, Sweden, Finland, Iceland, and Denmark. This program was initially introduced for hydraulic oil, two-stroke oil, gr ease, and transmission and gear oil (IENICA, 2004). The Nordic Swan certification addresses biodegradability, aquatic toxicity (OECD 201 and 202), technical performance, and renewability. The renewability requirements are the highest of all the labeling programs (e.g., at least 65% renewable content for hydraulic fluid, transmission fluid, gear oil, or grease, and at least 50% for two- stroke oil). Consequently, very few lubricants bear the Nordic Swan label (Habereder et al., 2008).

5.2.2 European Eco-label

The European Union has adopted a single European Eco-label. The Eco-label is considered to be the first major advancement towards creating a single international standard, and is becoming the most generally accepted label. The Eco-label for lubricants was established in 2005, and includes hydraulic fluids, greases, and to tal loss lubricants, such as two-stroke oils. This labeling scheme consists of seven criteria encompassing biodegradab ility, aquatic toxicity, bioaccumulation, and the presence of certain classe s of toxic substances (Habereder et al., 2008). A complete list of all lubri cants that carry the European Eco-Label can be found at http://www.eco-label.com/default.htm.

The ecological criteria for Eco-label lubrican ts aim at promoting products that have a reduced impact on the water and soil during their use and contain a large fraction of biologicallybased material. Since this is the most widely accepted labeling program, the requirements for this labeling scheme are described in detail below.

5.2.2.1 Dangerous Materials

Before a lubricant can be considered for the Eco-label, it is determined that neither the formulation nor any of the main components are on th e list of R-phrases (risk phrases) pertaining to environmental and human health hazards according to the European Union Dangerous Preparations Directive (IENICA, 2004). These include qualities such as explosiveness, flammability, carcinogenic potential, volatility, po tential to cause birth defects, etc.

5.2.2.2 Toxicity

Aquatic toxicity can be evaluated either for the complete formulation and main compounds (those compounds comprising at least 5% of the formulation) or for each constituent substance. Greases must be evaluated for each constituent substance unless it can be shown that the thickening agent is at least inherently bi odegradable (see below). All formulations and components must pass both OECD 201 and 202 fo r acute toxicity testing, and OECD 210 or 211 for chronic toxicity testing. If evaluated for the formulation and main constituents, the LC 50 (i.e.,Environmentally Acceptable Lubrican ts Section 5 - Environmentally Acceptable Lubricant Labeling Program

18 concentration of a compound or mixture that will kill half of the sample population of a specific test-organism in a specified peri od) of hydraulic fluids must be at least 100 mg/L and the LC 50 of greases, two-stroke oils, and all other total loss lubricants must be at least 1000 mg/L (European Commission, 2009). If the evaluati on is based on each constituent substance, then constituents that comprise less than 20% of hydraulic fluids can have an LC 50 of 10-100 mg/L or have a no observed effect concentration (NOE C) of 1-10 mg/L; constituents th at comprise less than 5% of hydraulic fluids can have an LC 50 of 1-10 mg/L or have a NOEC of 0.1-1 mg/L; and constituents that comprise less than 1% of hydraulic fluids can have an LC 50 of less than 1 mg/L or have a NOEC of 0-0.1 mg/L. For greases, two-stroke oils, and other total loss lubr icants, the respective percentages are 25%, 1%, and 0.1% (European Commission, 2009).

5.2.2.3 Biodegradability and Bioaccumulation

Ninety percent or more of the total hydrau lic oil formulation (75% for greases or twostroke oils) must be ultimately biodegradable, as determined according to any of OECD tests 301 A-F, or equivalent. Less than 5% of the hydraulic oil formulation (20% for greases or two-stroke oils) must be inherently biodegr adable. Inherent biodegr adability can be defi ned as at least 20%, but less than 60% or 70% biodegrad able (depending on the test), fo r any of OECD 301 A-F, or it can be defined as greater than 70% biodegradatio n in the OECD 302C test (or equivalent), or greater than 60% biodegradation in the ISO 14593 test (European Commission, 2009).

In addition to being biodegradable, a lubr icant must not have the potential to be bioaccumulative. A lubricant is considered not potentially bioaccumulative if one of the following conditions is met: it has a molar mass gr eater than 800 g/mol or a molecular diameter greater than 1.5 nm; it has a log K ow less than 3 or greater than 7; or it has a measured BCF less than 100 L/Kg (European Commission, 2004). Log K ow , which can be assessed using OECD 107, 117, or 123, or calculated, can be used to dem onstrate bioaccumulation potential for organic compounds only. For all other compounds, BCF must be measured using the flow-through fish test given by OECD 305 (European Commission, 2004).

5.2.2.4 Restricted Substances

Lubricant formulations must not include certain specific substances, including halogenated organic compounds, n itrite compounds, metals or metallic compounds (with the possible exception of sodium-, potassium-, ma gnesium-, lithium-, aluminum-,and calcium-based soaps) (European Commission, 2004).

5.2.2.5 Renewable Content

At least 50% of hydraulic oils and two-stroke oils, and at least 45% of greases, must consist of renewable materials, with renewabl e defined as vegetable oils or animal fats (European Commission, 2004). Given that 70-90% of a lubricant or l ubricant grease is the formulation’s base oil, this re quirement effectively excludes mi neral oil lubricants from Ecolabel certification.

5.2.2.6 Other

The final criteria for the Eco- label are for technical performa nce, which are specific to the lubricant class in question.Environmentally Acceptable Lubrican ts Section 5 - Environmentally Acceptable Lubricant Labeling Program

19 5.2.3 OSPAR

The offshore oil and gas industr y is highly regulated, partic ularly in the North Sea, compared to other marine industries (Pearce et al, 2010). Considerable attention is given to the chemicals used on and discharged from offshore oil facilities. Some of these chemicals, such as well chemicals, are deliberately discharged durin g normal use, similar to the discharge of total loss lubricants by the marine industry.

The Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR Convention) 2 is the current legal instrument guiding international cooperation on the protection of the marine environment of the No rth-East Atlantic. Work under the Convention is managed by the OSPAR Commissi on, which is made up by representatives of 15 contracting Governments and the European Commission (represents the European Union).

The standards for environmental complian ce, which are defined within the OSPAR Harmonized Mandatory Control Scheme (HMCS) re gulations, require compone nt level testing of chemicals released to the marine environment for biodegradation, bioaccumulation, and toxicity. These standards, which apply to the North Sea, are being adopted by most other oil and gas regulators around the world (includi ng Australia, Canada, India, Indonesia and New Zealand) as they are considered to be the most appropriate for measuring th e overall impact of a substance – not just its persistence (Pear ce et al., 2010). Although these regulations do not cover the shipping industry, they may be considered the most appr opriate standards for m easuring the impact of released chemicals in the marine environment.

The OSPAR standards measure environmental performance of chemicals in terms of persistence (biodegradation in seawater over a 28-day period, by OECD 306), bioaccumulation (evaluation by measuring K ow using OECD 117 or 107) and marine toxicity to four North Sea species (algae, copepods, sediment reworkers an d bottom-dwelling fish). Testing is carried out on each component, and must be conducted by an approved third-party laboratory. The OSPAR protocols for methods for the test ing of chemicals used in the o ffshore oil industry are available online (OSPAR, 2006). The mechanisms set out in the HMCS to ensure and actively promote the continued shift towards the use of less hazar dous substances (or preferably non-hazardous substances) are described in the OSPAR Deci sion 2000/2 on a Harmoni sed Mandatory Control System for the Use and Reduction of the Di scharge of Offshore Chemicals (OSPAR, 2000).

5.3 S UMMARY OF E NVIRONMENTALLY A CCEPTABLE L UBRICANT L ABELING P ROGRAMS
A summary of the major EAL labeling program s discussed in this section (including biodegradation, toxicity, bioaccumulation potential and other criteria) is provided in Table 8.

2 www.ospar.orgEnvironmentally Acceptable Lubrican ts Section 5 - Environmentally Acceptable Lubricant Labeling Program

20 Table 8. Comparison of EAL Labeling Programs

EAL Labeling Program Biodegradability Aquatic Toxicity Bioaccumulation Other Criteria

Blue Angel (Germany) OECD 301B-F (ultimatebiodeg.) or CEC L-33-A934 (primary biodeg.) OECD 201-203 OECD 305 A-E or K ow Dangerous materials; Technical performance Swedish Standard ISO 9439 NA None Renewable content; Sensitizing properties Nordic Swan NA OECD 201-202 None Renewable content; Technical performance European Eco-label OECD 301 A-F (ultimate biodeg.), OECD 302C or ISO 14593 OECD 201 and 202 (acute) & OECD 210 or 211 (chronic) OECD 107, 117 or 123 (K ow for organic compounds) or OECD 305 Dangerous materials; Restricted substances; Renewable content; Technical performance OSPAR OECD 306 (degradation under marine conditions) Marine toxicity to 4 species OECD 117or 107 (K ow )

NA - Not availableEnvironmentally Acceptable Lubr icants Section 6 - Conclusion

21 

## SECTION 6
CONCLUSION

Because much of the lubricant lost from a vesse l directly enters the aquatic environment, there is a greater focus on encouraging the im plementation of EALs on vessels (see 2008 VGP, page 24) (Carter, 2009). For all applications where lubricants are likely to enter the water, EAL formulations using vegetable oils , biodegradable synthetic esters or biodegradable polyalkylene glycols as oil bases instead of mineral oils can offer significantly reduced environmental impacts across all applications. Although th eir use is increasing, EALs con tinue to comprise only a small percentage of the total lubricant market.

Among types of EALs used in vessels, hydrau lic fluids are the most prevalent. Along with chain saw oil, more hydraulic fluids carry the Blue Angel and European Eco-label than any other class of lubricant. A major reason for the success of environmentally acceptable hydraulic fluid is that some of the performance issues a ssociated with EALs in open systems (particularly those formulated with vegetable oil derived base oils), such as oxidation, temperature sensitivity, and biodegradation following exposure to water, are less problematic in this closed system (ACE, 1999).

Stern tube leakage is a significant source of lubricant oil inputs to the aquatic environment; therefore, the benefit of replacing mineral-oil-based stern tube lubricants with EALs is expected to be consider able. Because of the inevitability of leaks, stern tube lubricants are also subject to water influx and increased bi odegradability associated with water contact. While still a niche market, environmentally accep table stern tube lubricants formulated from PAGs have shown to perform as well as a conven tional stern tube lubricant, with the additional benefit of maintained viscosity foll owing water influx (Sada et al., 2009).Environmentally Acceptable Lu bricants List of Figures



## SECTION 7
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