ASTM D8324-21
(Guide)Standard Guide for Selection of Environmentally Acceptable Lubricants for the U.S. Environmental Protection Agency (EPA) Vessel General Permit
Standard Guide for Selection of Environmentally Acceptable Lubricants for the U.S. Environmental Protection Agency (EPA) Vessel General Permit
SIGNIFICANCE AND USE
4.1 The purpose of this guide is to provide information on environmentally acceptable lubricants (EALs) used in marine applications. That information includes EAL types, general properties, and recommended means by which their technical performance can be evaluated. In addition, general information on the major environmental standards and other organizations and permits defining, classifying, and regulating the use of EALs are summarized.
4.2 Another goal of this guide is to provide concise tables that describe the biodegradability, ecotoxicity, and bioaccumulation requirements found in the 2013 EPA Vessel General Permit (VGP) for a lubricant to be defined as an EAL.
4.3 The scope of this guide is to provide information, without specific limits, to aid in the selection of EALs and use in marine applications. It is the intention of the preparers of the guide to provide a base knowledge of information on EALs and their use in marine applications to vessel owners and operators, vessel maintenance engineers, and preparers of marine original equipment manufacturer (OEM) lubricant requirements.
SCOPE
1.1 This guide provides information, without specific limits, to aid in the selection of environmentally acceptable lubricants (EALs) and use in marine applications.
1.2 Units—The values stated in SI units are to be regarded as the standard. No other units of measurement are included in this standard.
1.3 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.
1.4 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
General Information
- Status
- Published
- Publication Date
- 31-Mar-2021
- Technical Committee
- D02 - Petroleum Products, Liquid Fuels, and Lubricants
- Drafting Committee
- D02.12 - Environmental Standards for Lubricants
Relations
- Effective Date
- 01-Apr-2024
- Effective Date
- 01-Mar-2024
- Effective Date
- 01-Mar-2024
- Effective Date
- 15-Jan-2024
- Effective Date
- 15-Jan-2024
- Refers
ASTM D4175-23a - Standard Terminology Relating to Petroleum Products, Liquid Fuels, and Lubricants - Effective Date
- 15-Dec-2023
- Effective Date
- 01-Dec-2023
- Effective Date
- 01-Dec-2023
- Effective Date
- 01-Nov-2023
- Effective Date
- 01-Nov-2023
- Effective Date
- 01-Nov-2023
- Effective Date
- 01-Nov-2023
- Effective Date
- 01-Nov-2023
- Effective Date
- 01-Oct-2023
- Refers
ASTM D4175-23e1 - Standard Terminology Relating to Petroleum Products, Liquid Fuels, and Lubricants - Effective Date
- 01-Jul-2023
Overview
ASTM D8324-21 is the ASTM International standard guide for the selection of environmentally acceptable lubricants (EALs) for marine applications subject to the requirements of the U.S. Environmental Protection Agency (EPA) Vessel General Permit (VGP). This guide provides valuable information on EAL types, their general properties, and avenues for evaluating their technical and environmental performance. It summarizes key environmental regulations and ecolabel programs, and supports marine equipment operators, vessel owners, engineers, and manufacturers in making informed lubricant choices that minimize environmental impact while meeting complex performance needs.
Key Topics
Definition and Classification of EALs:
The standard outlines different classes of EALs based on base stock types and environmental criteria such as biodegradability, toxicity, and bioaccumulation. Hydraulic fluids, greases, and gear oils are among the product types covered. The guide draws on both international and regulatory frameworks, including the 2013 EPA VGP requirements.Environmental Performance Requirements:
ASTM D8324-21 details performance metrics for EAL selection, including:- Biodegradability: The lubricant’s ability to break down naturally.
- Ecotoxicity: The effect on aquatic life, measured through acute testing protocols.
- Bioaccumulation: The tendency for ingredients to accumulate in marine organisms.
Regulatory and Ecolabel Programs:
The guide summarizes U.S. and international legislative requirements and voluntary ecolabeling systems (e.g., EPA VGP, Blue Angel, Nordic Swan, European Ecolabel, OSPAR), which help define compliance criteria for marine lubricants.Evaluation and Testing Methods:
Numerous referenced ASTM, ISO, DIN, and OECO test methods provide the technical basis for verifying the environmental and performance characteristics of lubricants.
Applications
Marine Vessel Lubrication:
ASTM D8324-21 is essential for the marine industry, supporting users in selecting EALs for vessel components at risk for oil-to-sea interface exposure, such as stern tubes, thrusters, propulsion systems, and exposed deck machinery. Lubricants are classified as total loss, partial loss, or accidental loss based on their environmental release potential during use.Regulatory Compliance:
Compliance with the EPA VGP is required for most commercial vessels operating in U.S. waters. The standard assists users in meeting these requirements by clarifying lubricant testing, labeling, and reporting obligations.OEM and Maintenance Specifications:
Marine equipment manufacturers and maintenance professionals rely on ASTM D8324-21 to develop and specify lubricants that balance environmental acceptability, equipment protection, and operational efficiency.Product Development and Procurement:
Lubricant suppliers and buyers can use this guide to understand international compatibility, minimize liability, and select certified products for environmentally sensitive marine operations.
Related Standards
ASTM Methods:
Numerous ASTM test methods are referenced for evaluating lubricants' physical and chemical properties, including but not limited to:- D445 (Kinematic Viscosity)
- D5864 (Aerobic Aquatic Biodegradation)
- D892 (Foaming Characteristics)
- D2266 (Wear Preventive Characteristics)
- D1401 (Water Separability)
- D4175 (Terminology Relating to Petroleum Products)
ISO and DIN Standards:
International standards, such as ISO 15380 (categories of hydraulic fluids), ISO 6743-4 (classification of lubricants), and various DIN procedures, are incorporated for broader compliance.Regulatory Reference:
- EPA 2013 Vessel General Permit (VGP)
- OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic
- EU Ecolabel Programs
- REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals)
By following ASTM D8324-21, marine industry professionals can ensure the selection and use of lubricants that not only protect equipment but also align with stringent environmental and regulatory standards, supporting sustainable, compliant marine operations.
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Frequently Asked Questions
ASTM D8324-21 is a guide published by ASTM International. Its full title is "Standard Guide for Selection of Environmentally Acceptable Lubricants for the U.S. Environmental Protection Agency (EPA) Vessel General Permit". This standard covers: SIGNIFICANCE AND USE 4.1 The purpose of this guide is to provide information on environmentally acceptable lubricants (EALs) used in marine applications. That information includes EAL types, general properties, and recommended means by which their technical performance can be evaluated. In addition, general information on the major environmental standards and other organizations and permits defining, classifying, and regulating the use of EALs are summarized. 4.2 Another goal of this guide is to provide concise tables that describe the biodegradability, ecotoxicity, and bioaccumulation requirements found in the 2013 EPA Vessel General Permit (VGP) for a lubricant to be defined as an EAL. 4.3 The scope of this guide is to provide information, without specific limits, to aid in the selection of EALs and use in marine applications. It is the intention of the preparers of the guide to provide a base knowledge of information on EALs and their use in marine applications to vessel owners and operators, vessel maintenance engineers, and preparers of marine original equipment manufacturer (OEM) lubricant requirements. SCOPE 1.1 This guide provides information, without specific limits, to aid in the selection of environmentally acceptable lubricants (EALs) and use in marine applications. 1.2 Units—The values stated in SI units are to be regarded as the standard. No other units of measurement are included in this standard. 1.3 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use. 1.4 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
SIGNIFICANCE AND USE 4.1 The purpose of this guide is to provide information on environmentally acceptable lubricants (EALs) used in marine applications. That information includes EAL types, general properties, and recommended means by which their technical performance can be evaluated. In addition, general information on the major environmental standards and other organizations and permits defining, classifying, and regulating the use of EALs are summarized. 4.2 Another goal of this guide is to provide concise tables that describe the biodegradability, ecotoxicity, and bioaccumulation requirements found in the 2013 EPA Vessel General Permit (VGP) for a lubricant to be defined as an EAL. 4.3 The scope of this guide is to provide information, without specific limits, to aid in the selection of EALs and use in marine applications. It is the intention of the preparers of the guide to provide a base knowledge of information on EALs and their use in marine applications to vessel owners and operators, vessel maintenance engineers, and preparers of marine original equipment manufacturer (OEM) lubricant requirements. SCOPE 1.1 This guide provides information, without specific limits, to aid in the selection of environmentally acceptable lubricants (EALs) and use in marine applications. 1.2 Units—The values stated in SI units are to be regarded as the standard. No other units of measurement are included in this standard. 1.3 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use. 1.4 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
ASTM D8324-21 is classified under the following ICS (International Classification for Standards) categories: 75.100 - Lubricants, industrial oils and related products. The ICS classification helps identify the subject area and facilitates finding related standards.
ASTM D8324-21 has the following relationships with other standards: It is inter standard links to ASTM D445-24, ASTM D6046-24, ASTM D2070-24, ASTM D7594-24e1, ASTM D7594-24, ASTM D4175-23a, ASTM D5706-23, ASTM D665-23, ASTM D5864-23, ASTM D7421-23, ASTM D445-23, ASTM D5707-23, ASTM D6425-23, ASTM D892-23, ASTM D4175-23e1. Understanding these relationships helps ensure you are using the most current and applicable version of the standard.
ASTM D8324-21 is available in PDF format for immediate download after purchase. The document can be added to your cart and obtained through the secure checkout process. Digital delivery ensures instant access to the complete standard document.
Standards Content (Sample)
This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: D8324 − 21
Standard Guide for
Selection of Environmentally Acceptable Lubricants for the
U.S. Environmental Protection Agency (EPA) Vessel General
Permit
This standard is issued under the fixed designation D8324; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope and Opaque Liquids (and Calculation of Dynamic Viscos-
ity)
1.1 This guide provides information, without specific limits,
D664 Test Method for Acid Number of Petroleum Products
to aid in the selection of environmentally acceptable lubricants
by Potentiometric Titration
(EALs) and use in marine applications.
D665 Test Method for Rust-Preventing Characteristics of
1.2 Units—The values stated in SI units are to be regarded
Inhibited Mineral Oil in the Presence of Water
as the standard. No other units of measurement are included in
D892 Test Method for Foaming Characteristics of Lubricat-
this standard.
ing Oils
1.3 This standard does not purport to address all of the
D943 Test Method for Oxidation Characteristics of Inhibited
safety concerns, if any, associated with its use. It is the
Mineral Oils
responsibility of the user of this standard to establish appro-
D974 Test Method for Acid and Base Number by Color-
priate safety, health, and environmental practices and deter-
Indicator Titration
mine the applicability of regulatory limitations prior to use.
D1264 Test Method for Determining the Water Washout
1.4 This international standard was developed in accor-
Characteristics of Lubricating Greases
dance with internationally recognized principles on standard-
D1298 Test Method for Density, Relative Density, or API
ization established in the Decision on Principles for the
Gravity of Crude Petroleum and Liquid Petroleum Prod-
Development of International Standards, Guides and Recom-
ucts by Hydrometer Method
mendations issued by the World Trade Organization Technical
D1401 TestMethodforWaterSeparabilityofPetroleumOils
Barriers to Trade (TBT) Committee.
and Synthetic Fluids
D1742 Test Method for Oil Separation from Lubricating
2. Referenced Documents
2 Grease During Storage
2.1 ASTM Standards:
D1743 Test Method for Determining Corrosion Preventive
D92 Test Method for Flash and Fire Points by Cleveland
Properties of Lubricating Greases
Open Cup Tester
D2070 Test Method for Thermal Stability of Hydraulic Oils
D93 Test Methods for Flash Point by Pensky-Martens
D2265 Test Method for Dropping Point of Lubricating
Closed Cup Tester
Grease Over Wide Temperature Range
D97 Test Method for Pour Point of Petroleum Products
D2266 Test Method for Wear Preventive Characteristics of
D130 Test Method for Corrosiveness to Copper from Petro-
Lubricating Grease (Four-Ball Method)
leum Products by Copper Strip Test
D217 Test Methods for Cone Penetration of Lubricating D2270 Practice for Calculating Viscosity Index from Kine-
matic Viscosity at 40 °C and 100 °C
Grease
D445 Test Method for Kinematic Viscosity of Transparent D2422 Classification of Industrial Fluid Lubricants by Vis-
cosity System
D2509 Test Method for Measurement of Load-Carrying
This guide is under the jurisdiction of ASTM Committee D02 on Petroleum
Capacity of Lubricating Grease (Timken Method)
Products, Liquid Fuels, and Lubricants and is the direct responsibility of Subcom-
D2596 Test Method for Measurement of Extreme-Pressure
mittee D02.12 on Environmental Standards for Lubricants.
Properties of Lubricating Grease (Four-Ball Method)
Current edition approved April 1, 2021. Published May 2021. DOI: 10.1520/
D8324-21.
D2619 Test Method for Hydrolytic Stability of Hydraulic
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
Fluids (Beverage Bottle Method)
contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM
D2711 Test Method for Demulsibility Characteristics of
Standards volume information, refer to the standard’s Document Summary page on
the ASTM website. Lubricating Oils
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D8324 − 21
D2782 Test Method for Measurement of Extreme-Pressure D7042 Test Method for Dynamic Viscosity and Density of
Properties of Lubricating Fluids (Timken Method) Liquids by Stabinger Viscometer (and the Calculation of
Kinematic Viscosity)
D2783 Test Method for Measurement of Extreme-Pressure
Properties of Lubricating Fluids (Four-Ball Method) D7043 Test Method for Indicating Wear Characteristics of
Non-Petroleum and Petroleum Hydraulic Fluids in a
D2893 Test Methods for Oxidation Characteristics of
Constant Volume Vane Pump
Extreme-Pressure Lubrication Oils
D7373 Test Method for Predicting Biodegradability of Lu-
D3427 Test Method forAir Release Properties of Hydrocar-
bricants Using a Bio-kinetic Model (Withdrawn 2021)
bon Based Oils
D7421 Test Method for Determining Extreme Pressure
D4048 Test Method for Detection of Copper Corrosion from
Properties of Lubricating Oils Using High-Frequency,
Lubricating Grease
Linear-Oscillation (SRV) Test Machine
D4052 Test Method for Density, Relative Density, and API
D7594 Test Method for Determining Fretting Wear Resis-
Gravity of Liquids by Digital Density Meter
tance of Lubricating Greases Under High Hertzian Con-
D4170 Test Method for Fretting Wear Protection by Lubri-
tact Pressures Using a High-Frequency, Linear-Oscillation
cating Greases
(SRV) Test Machine
D4172 Test Method for Wear Preventive Characteristics of
D7752 Practice for Evaluating Compatibility of Mixtures of
Lubricating Fluid (Four-Ball Method)
Hydraulic Fluids
D4175 Terminology Relating to Petroleum Products, Liquid
Fuels, and Lubricants 2.2 DIN Standards:
D4289 Test Method for Elastomer Compatibility of Lubri- DIN 51350-4 Testing in the four-ball tester—Part 4: Deter-
cating Greases and Fluids mination of welding load of consistent lubricants
DIN 51350-5 Testing of lubricants—Testing in the four-ball
D4310 Test Method for Determination of Sludging and
Corrosion Tendencies of Inhibited Mineral Oils tester—Part 5: Determination of wearing characteristics
for consistent lubricants
D5182 Test Method for Evaluating the Scuffing Load Ca-
DIN 51350-5E Testing in the four-ball tester—Part 5: De-
pacity of Oils (FZG Visual Method)
termination of wearing characteristics for consistent lubri-
D5483 Test Method for Oxidation Induction Time of Lubri-
cants
catingGreasesbyPressureDifferentialScanningCalorim-
DIN 51350-6 Shear Stability of Polymer Containing Lubri-
etry
cants
D5706 Test Method for Determining Extreme Pressure
DIN 51354-2 Testing of lubricants; FZG gear test rig;
Properties of Lubricating Greases Using a High-
general working principles
Frequency, Linear-Oscillation (SRV) Test Machine
DIN 51389-2 Determination of lubricants; mechanical test-
D5707 Test Method for Measuring Friction and Wear Prop-
ing of hydraulic fluids in the vane cell-pump; method A
erties of Lubricating Grease Using a High-Frequency,
for anhydrous hydraulic fluids
Linear-Oscillation (SRV) Test Machine
DIN 51517-1 Lubricants—Lubricating oils—Part 1: Lubri-
D5864 Test Method for Determining Aerobic Aquatic Bio-
cating oils C, Minimum requirements
degradation of Lubricants or Their Components
DIN 51517-2 Lubricating oils—Part 3: Lubricating oils CL,
D5949 Test Method for Pour Point of Petroleum Products
Minimum requirements
(Automatic Pressure Pulsing Method)
DIN 51517-3 Lubricating oils—Part 3: Lubricating oils
D5950 Test Method for Pour Point of Petroleum Products
CLP, Minimum requirements
(Automatic Tilt Method)
DIN 51524-3 Pressure fluids—Hydraulic oils—Part 3:
D6046 Classification of Hydraulic Fluids for Environmental
HVLP hydraulic oils, Minimum requirements
Impact
DIN 51538 Testing of lubricants for refrigeration compres-
D6080 Practice for Defining the Viscosity Characteristics of
sors for resistance to ammonia
Hydraulic Fluids
DIN 51757 Determination of Density
D6138 Test Method for Determination of Corrosion-
DIN 51777-2 Determination of Water Content according to
Preventive Properties of Lubricating Greases Under Dy-
Karl Fischer; Indirect Method
namic Wet Conditions (Emcor Test)
DIN 51805 Determination of Flow Pressure of Lubricating
D6304 Test Method for Determination of Water in Petro-
Greases, Kesternich Method
leum Products, Lubricating Oils, and Additives by Cou-
DIN 51807-1 Determination of Water Resistance of Grease
lometric Karl Fischer Titration
DIN 51817-1 Determination of oil separation from greases
D6425 Test Method for Measuring Friction and Wear Prop-
under static conditions
erties of Extreme Pressure (EP) Lubricating Oils Using
DIN 51819-2 Testing of lubricants—Mechanical-dynamic
SRV Test Machine
testing in the roller bearing test apparatus FE8—Part 2:
D6546 Test Methods for and Suggested Limits for Deter-
mining Compatibility of Elastomer Seals for Industrial
Hydraulic Fluid Applications
The last approved version of this historical standard is referenced on
D6973 Test Method for Indicating Wear Characteristics of
www.astm.org.
Petroleum Hydraulic Fluids in a High Pressure Constant
Available from Deutsches Institut für Normung e.V. (DIN), Am DIN-Platz,
Volume Vane Pump Burggrafenstrasse 6, 10787 Berlin, Germany, http://www.din.de.
D8324 − 21
Test method for lubricating greases—applied test bearing: ISO 6614 Determination of water separability of petroleum
oblique ball bearing or tapered roller bearing oils and synthetic fluids
DIN 51819-3 Roller Bearing Test ISO 6618 Determination of acid or base number—Colour-
DIN 51834 Tribological test method using a high-frequency, indicator titration method
linear-oscillation test machine (SRV) ISO 6619 Neutralization number—Potentiometric titration
DIN 53505 Shore A and Shore D hardness testing of rubber method
ISO 6743-4 Lubricants, industrial oils and related products
2.3 Energy Institute Standards:
(class L) —Classification—Part 4: Family H (Hydraulic
IP 121 Determination of oil separation from lubricating
systems)
grease—Pressure filtration method
ISO 7000-2579 Graphical symbols for use on equipment—
IP 326 Determination of extreme pressure properties of
Registered symbols
grease—Timken method
ISO7120 Determinationofrust-preventingcharacteristicsin
IP 530 Determination of the density of grease—Density cup
the presence of water
method
ISO/TR 7620 Rubber materials—chemical resistance
2.4 ISO Standards:
ISO 9120 Determination of air-release properties of steam
ISO 1817 Rubber, vulcanized or thermoplastic—
turbine and other oils—Impinger method
Determination of the effect of liquids
ISO 10253 Water quality—Marine algal growth inhibition
ISO 2137 Determination of cone penetration of lubricating
test
greases and petrolatum
ISO 11007 Determination of rust-prevention characteristics
ISO 2160 Corrosiveness to copper—Copper strip test
of lubricating greases
ISO 2176 Lubricating grease—Determination of dropping
ISO 11009 Determination of water washout characteristics
point
of lubricating greases
ISO 2592 Determination of flash and fire points—Cleveland
ISO 12152 Determination of the foaming and air release
open cup method
properties of industrial gear oils using a spur gear test
ISO 2909 Calculation of viscosity index from kinematic
rig—Flender foam test procedure
viscosity
ISO 12185 Determination of density—Oscillating U-tube
ISO 3016 Determination of Pour Point
method
ISO 3104 Transparent and opaque liquids—Determination
ISO 12925-1 Lubricants, industrial oils and related products
of kinematic viscosity and calculation of dynamic viscos-
(class L)—Family C (gears)—Part 1: Specifications for
ity
lubricants for enclosed gear systems
ISO 3448 ISO viscosity classification
ISO 12937 Determination of water—Coulometric Karl Fis-
ISO 3675 Laboratory determination of density—
cher titration method
Hydrometer method
ISO 13357-1 Petroleum products—Determination of the fil-
ISO 4263-1 Petroleum and related products—Determination
terability of lubricating oils—Part 1: Procedure for oils in
of the ageing behaviour of inhibited oils and fluids—
the presence of water
TOST test—Part 1: Procedure for mineral oils
ISO 13357-2 Determination of the filterability of lubricating
ISO 4263-3 Petroleum and related products—Determination
oils—Part 2: Procedure for dry oils
of the ageing behaviour of inhibited oils and fluids using
ISO 14593 Water quality—Evaluation of ultimate aerobic
theTOSTtest—Part 3:Anhydrous procedure for synthetic
biodegradability of organic compounds in aqueous me-
hydraulic fluids
dium
ISO 4263-4 Determination of the ageing behaviour of inhib-
ISO 14635-1 FZG test method A/83/90 for relative scuffing
ited oils and fluids—TOST test—Part 4: Procedure for
load-carrying capacity of oils
industrial gear oils
ISO 15380 Specifications for categories HETG, HEPG,
ISO 4406 Method for coding the level of contamination by
HEES and HEPR
solid particles
2.5 OECD Standards:
ISO 6072 Rubber—Compatibility between hydraulic fluids
OECD 107 Guideline for Testing of Chemicals
and standard elastomeric materials
OECD 117 Guideline for Testing of Chemicals
ISO 6247 Determination of foaming characteristics of lubri-
OECD 201 Guideline for Testing of Chemicals
cating oils
ISO 6296 Determination of water—Potentiometric Karl Fis- 2.6 U.S. EPA Standards:
cher titration method EPA 2013 Vessel General Permit
ISO 6299 Determination of dropping point of lubricating OCSPP Harmonized Guideline 835.3110 Criteria for Biode-
greases (wide temperature range) gradability Claims on Products Registered under FIFRA
5 7
Available from Energy Institute, 61 New Cavendish St., London, W1G 7AR, Available from Organisation for Economic Cooperation and Development
U.K., http://www.energyinst.org. (OECD), 2 rue André Pascal, 75775 Paris Cedex 16, France, http://www.oecd.org.
6 8
Available from International Organization for Standardization (ISO), ISO AvailablefromUnitedStatesEnvironmentalProtectionAgency(EPA),William
Central Secretariat, Chemin de Blandonnet 8, CP 401, 1214 Vernier, Geneva, Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
Switzerland, https://www.iso.org. http://www.epa.gov.
D8324 − 21
OCSPPHarmonized Guideline 850.1710 Oyster Bioconcen- 3.3 Definitions of Terms Specific to This Standard:
tration Factor (BCF) of Test Compound 3.3.1 accidental loss lubricant, n—lubricant product that is
OCSPPHarmonized Guideline 850.1730 Fish Bioconcentra-
used in closed systems; these products can only be released to
tion Factor (BCF) of Test Compound the environment incidentally.
2.7 SIS Standards:
3.3.2 acute ecotoxicity test, n—protocol in which a repre-
SS 155434 Hydraulic Fluids—Requirements and Test Meth-
sentative subpopulation of organisms is exposed to different
ods
concentrations of a test substance for a short period (typically
SS 155470 Lubricants, Industrial Oils and Similar
24 h to 72 h), after which the impact is observed.
Products—(ClassL)—SpecificationsforFamilyX(Lubri-
3.3.2.1 Discussion—Commonlytheend-pointforacuteeco-
cating Grease)
toxicity testing is lethality and the concentration at which 50 %
2.8 Other Standards: of the exposed population dies (LC50) is reported. However,
sub-lethal effects may also be considered.
1907/2006 Registration, Evaluation, Authorisation and Re-
striction of Chemicals (REACH) 3.3.2.2 Discussion—Exposure periods substantially longer
CEC-L-45-A99 Viscosity Shear Stability of Transmission than 48 h are classified as sub-chronic studies, the exposure
Lubricants period must not constitute a substantial portion of the test
DE-UZ 178 Biodegradable Lubricants and Hydraulic Flu- species’ life span.
ids
3.3.3 bioaccumulation, n—net uptake of a material by an
EN 16807 Liquid petroleum products. Bio-lubricants. Crite-
organism from its environment through exposure by means of
ria and requirements of biolubricants and bio-based lubri-
water and food.
cants
3.3.4 bioaccumulation factor, n—ratio of the contaminant in
FVA 54/7 FZG Micro Pitting Test
an organism to the concentration in the ambient environment.
OSPAR Commission 2005 Protocols on Methods for the
3.3.5 bioconcentration factor, n—ratio of the concentration
Testing of Chemicals Used in the Offshore Oil Industry
of a particular chemical in a living organism to the chemical’s
concentration in the surrounding water.
3. Terminology
3.3.6 gear lubricant, n—material used to lubricate gear
3.1 For definitions of terms used in this standard, refer to
components.
Terminology D4175.
3.3.7 inherently biodegradable, adj—having unequivocal
3.2 Definitions:
evidence of biodegradability.
3.2.1 acute ecotoxicity, n—the propensity of a material to
produce adverse behavioral, biochemical, or physiological
3.3.8 lubricant formulation, n—intended chemical constitu-
effects in non-human organisms or populations in a short
ents of a lubricant.
period of time, usually not constituting a substantial portion of
3.3.9 partial loss lubricant, n—lubricant that is partially
the life span of the organism. D6046
released to the environment during use.
3.2.2 biodegradation, n—the process of chemical break-
3.3.10 polymer, n—compound formed by the reaction of
down or transformation of a material caused by organisms or
simple molecules having functional groups which permit their
their enzymes.
combination to proceed to higher molecular weights under
3.2.3 hydraulic fluid, n—a liquid used in hydraulic systems
suitable conditions.
for lubrication and transmission of power. D6080
3.3.10.1 Discussion—The simple molecules also known as
3.2.4 lubricating grease, n—a semi-fluid to solid product of monomers that make up a polymer can be of a single chemical
configuration or many. They can be reacted to create a broad
a dispersion of a thickener in a liquid lubricant.
3.2.4.1 Discussion—The dispersion of the thickener forms a variation of polymer types including homo, random, and block
polymers.
two-phase system and immobilizes the liquid lubricant by
surface tension and other physical forces. Other ingredients are
3.3.11 readily biodegradable, adj—arbitrary classification
commonly included to impart special properties. D217
of chemicals which have passed certain specified screening
tests for ultimate biodegradability; these tests are so stringent
that it is assumed that such compounds will rapidly and
Available from Swedish Institute for Standards, Box 45443, SE-104 31,
completely biodegrade in aquatic environments under aerobic
Stockholm, Sweden, sis.se/en/.
conditions.
Available from EuropeanAgency for Safety and Health at Work (EU-OSHA),
12 Santiago de Compostela (Edificio Miribilla), 5th Floor, E-48003 Bilbao, Spain,
3.3.12 stern tube lubricant, n—liquid that provides lubrica-
osha.europa.eu.
tion to the bearings supporting the propeller shaft within the
Available from Coordinating European Council (CEC), Services provided by
vessel stern tube.
Kellen Europe, Avenue Jules Bordet 142 - 1140, Brussels, Belgium, http://
www.cectests.org.
3.3.13 total loss lubricant, n—lubricant product that is fully
Available from Blue Angel, www.blauer-engel.de/en/products/business-
released to the environment during use.
municipality/lubricants-hydraulic-fluids.
Available from British Standards Institution (BSI), 389 Chiswick High Rd.,
3.3.14 ultimately biodegradable, adj—having the ability to
London W4 4AL, U.K., http://www.bsigroup.com.
be biodegraded into carbon dioxide, biomass, water, and other
For referenced FVA standard, visit www.agma.org.
For referenced OSPAR protocols, visit www.ospar.org. inorganic substances such as ammonia.
D8324 − 21
4. Significance and Use approved by the European Committee for Standardization
(CEN). One concept of this standard is to evaluate the
4.1 The purpose of this guide is to provide information on
environmental acceptability of a product by testing the biode-
environmentally acceptable lubricants (EALs) used in marine
gradability and ecotoxicity on the product mixture in contrast
applications. That information includes EAL types, general
to the European Ecolabel program in which the focus is on
properties, and recommended means by which their technical
testing of single components and not on the testing of the
performance can be evaluated. In addition, general information
mixture as a whole.
on the major environmental standards and other organizations
6.1.1 The current criteria for a product to obtain EU
and permits defining, classifying, and regulating the use of
Ecolabel status went into force on January 1, 2019 and will be
EALs are summarized.
valid until December 31, 2024. Changes from the previous
4.2 Another goal of this guide is to provide concise tables
iteration now in the current EU Ecolabel criteria include:
that describe the biodegradability, ecotoxicity, and bioaccumu-
6.1.1.1 Replacement of the five application-based lubricant
lation requirements found in the 2013 EPA Vessel General
categories with three classifications based on the potential for
Permit (VGP) for a lubricant to be defined as an EAL.
loss to the environment:
4.3 The scope of this guide is to provide information,
(1) Total loss lubricants (TLL) that include chainsaw oils,
without specific limits, to aid in the selection of EALs and use wire rope lubricants, concrete release agents, total loss greases,
in marine applications. It is the intention of the preparers of the
and other TLL;
guidetoprovideabaseknowledgeofinformationonEALsand (2) Partial loss lubricants (PLL) that include two-stroke
their use in marine applications to vessel owners and operators,
oils, gear oils intended for use in open gears, stern tube oils,
vessel maintenance engineers, and preparers of marine original oils for temporary protection against corrosion, and partial loss
equipment manufacturer (OEM) lubricant requirements.
greases; and
(3) Accidental loss lubricants (ALL) that include hydraulic
5. Classification
and metalworking fluids, closed gear oils intended for use in
closed gears, and accidental loss greases;
5.1 Users of lubricants on marine vessels would like assur-
6.1.1.2 Theadditionoftwonewlubricanttypes:metalwork-
ance that the lubricants they use will allow their systems to
ingfluidsandfluidsfortemporaryprotectionagainstcorrosion;
operate safely with reasonable equipment life. This assurance
6.1.1.3 Easing of renewable content requirements for lubri-
is commonly provided by the lubricant supplier in the form of
cants;
test results from specified methods indicating compliance with
6.1.1.4 Revisions in the specific requirements for excluded,
industry/OEMstandardsordemonstratedsuccessinfieldusein
similar systems, or both. This guide is intended to support limited, or restricted substances;
lubricant producers and marine OEMs to develop testing 6.1.1.5 Revisions in the specific requirements for biode-
protocols that demonstrate the suitability of an EAL lubricant gradability; and
for its intended use, and to be a reference to EAL end users to 6.1.1.6 Addition of three criteria: Criterion 4. Origin,
make more informed decisions on the best EAL type for their Traceability, andAdvertising of Renewable Ingredients; Crite-
application and circumstance. rion 5. Packaging; and Criterion 7. Consumer Information.
5.2 The significance and use of each test method cited in
6.2 Legislation Requiring EALs—Legislation to limit oil
this guide will depend upon the system in use and the purpose and lubricant leakage into the marine environment has been
of the test method. Use the most recent editions of ASTM
implemented by governments through organizations and sys-
International, Organization for Economic Cooperation and
tems including: MARPOLAnnex 1, the International Maritime
Development (OECD), The Coordinating European Council
Organization (IMO); Marine Environment Protection Commit-
(CEC), International Organization for Standardization (ISO),
tee the Convention for the Protection of the Marine Environ-
and U.S. Environmental Protection Agency (EPA) test meth-
ment of the North-EastAtlantic (OSPAR Convention); and the
ods.
U.S. Vessel General Permit.
6.2.1 Oslo/Paris Convention (for the Protection of the
6. Programs and Legislation Promoting or Requiring
Marine Environment of the North-East Atlantic) (OSPAR)—
EALs
Adoptedin1992,OSPARisthegoverningbodythroughwhich
15 governments of the western coasts of Europe together with
6.1 Ecolabel Programs Promoting EALs—National and in-
the European Union work to protect the marine environment of
ternational labeling programs have been used to promote
the northeast Atlantic. The goal of OSPAR is to prevent
environmentally preferred product lubricants. These voluntary
pollutionofthemarineenvironmentthroughcontinuousreduc-
programs set specific requirements for the environmental and
tion of emissions, discharges, and spills of hazardous sub-
technical performance a product shall meet before it may use
stances.
the specific ecolabel. The two most recognized national label-
6.2.2 U.S. EPA VGP:
ing programs have been DE-UZ 178 and SS 155434. The first
international labeling program was the Nordic Swan program 6.2.2.1 On Dec. 18, 2008, the EPA VGP completed new
initially for greases and hydraulic, two-stroke, transmission, permitting requirements for discharges incidental to the normal
and gear oils. The newest of the labeling programs, the operation of a vessel into inland waters or the territorial sea of
European Ecolabel program, has become the most generally the United States under the National Pollutant Discharge
accepted ecolabel internationally. In 2016, EN 16807 was Elimination System (NPDES). Commercial vessels subject to
D8324 − 21
TABLE 1 Summary of Lubricant Compliance Options for 2013 VGP Definition of EAL
Lubricant Compliance Options for 2013 VGP EAL Definition Summary of Compliance Requirements
Lubricant meets Demonstrate with specific test data that the 2013 VGP EAL biodegradability, aquatic toxicity, and bioaccumulation requirements
requirements for EAL as lubricant meets 2013 VGP EAL requirements. are specific for lubricants, greases, and total loss lubricants. Only test methods listed
defined in 2013 VGP. in the 2013 VGP may be used to demonstrate compliance.
Lubricant meets the Demonstrate lubricant is registered with Requirements for Blue Angel, Nordic Swan, European Ecolabel, EPA’s Design for the
requirements of approved environmental program. Environment (DfE),Swedish Standards SS 155434 and 155470
environmental labeling Lubricant meets requirements of OSPAR. Lubricant components meet the pre-screening criteria or they pose little or no risk to
programs listed in the 2013 the environment (PLONOR) chemicals or are on REACH Annex IV or meet the criteria
VGP. of REACH Annex V.
the VGP legislation were those that were greater than 24 m in 7. Classification of EALs
length, had discharges of more than 6116 L of ballast water,
7.1 ISO has classified hydraulic fluid types including envi-
had tonnage of 304 814 kg or more, or operated in California
ronmentally acceptable hydraulic fluids in ISO 6743-4. This
waters.
standard organizes environmentally acceptable hydraulic fluids
6.2.2.2 This VGP repealed a long-standing exclusion of
based on four base stock types from which most environmen-
discharges incidental to the normal operation of vessels from
tally acceptable hydraulic fluids are derived: triglycerides
the NPDES program as required by the U.S. Clean Water Act.
(HETG), polyglycols (HEPG), synthetic esters (HEES), and
Under the Clean Water Act, all discharges of pollutants into
polyalphaolefin and other synthetic hydrocarbons (HEPR).
U.S. waters are prohibited unless authorized by a duly issued
These same four base stocks are the basis for the manufacture
permit. Authorization to discharge is obtained under Section
of virtually all EALs developed for industrial lubricant
402 NPDES permit that authorizes the discharge of a specified
applications, both marine and land-based. For this reason this
amount of a pollutant or pollutants into receiving waters under
guide will expand the use of these acronyms to represent all
certain conditions.
environmentally acceptable lubricants whose basestock is of
6.2.2.3 The 2008 VGP coverage period expired on Dec. 19,
that certain type.
2013 at which time the 2013 VGP coverage (EPA 2013 VGP)
7.2 HETG Lubricants—Triglycerides (Natural Esters)—
started and would continue for the next five-year period until
Theselubricantfluidsarebasedonnaturalestersalsoknownas
Dec.18,2018.The2013VGPmandatestheuseofEALsforall
triglyceride base stocks that originate from animal and plant
oil-to-sea interface applications in vessels constructed on or
sources. As base stocks for environmentally acceptable
after Dec. 19, 2013 and all vessels built before Dec. 19, 2013
lubricants, natural esters are sourced exclusively from plant
unless technically infeasible. If a vessel is unable to use an
sources.The most common types of plant oil used for lubricant
EAL for a required application, the owners/operators shall
base stocks are canola (rapeseed) and soybean oil.
document why they were unable to do so and report the use of
7.2.1 Chemical Origin—Triglycerides (Natural Esters)—
a non-EALproduct to the EPAin their annual report.The 2013
Most plant-sourced oils are triglycerides composed of a glyc-
EPA VGP outlined clear requirements of biodegradability,
erol molecule forming three ester linkages (functional groups)
toxicity, and bioaccumulation for a product to be defined as an
with various fatty acids. The diversity of properties in natural
environmentally acceptable lubricant (see Appendix A and
esters comes from the variation of fatty acids that can comprise
B ). On December 4, 2018, the President signed into law the
the oil. The fatty acids can be of different chain lengths and
“Vessel Incidental Discharge Act” (VIDA) (Title IX of the
number of double bonds (saturated, monounsaturated, di-
Frank LoBiondo Coast Guard Authorization Act of 2018).
unsaturated, tri-unsaturated, and so forth). The physical and
VIDA restructures the way EPA and the U.S. Coast Guard
chemical properties of these plant oils and the hydraulic fluids
(USCG) regulate incidental discharges, primarily from com-
made from them have been well documented and are the result
mercial vessels, into waters of the United States and the
of the structural differences in the fatty acid mixtures that
contiguous zone. Specifically, VIDA amends Clean Water Act
comprise each natural oil source as well as the glycerol
(CWA) Section 312 to include a new subsection titled “Uni-
backbone.
form National Standards for Discharges Incidental to Normal
7.2.2 Compatibility with Mineral Oil, Freshwater, and
Operation of Vessels.” Subsection 312(p) requires EPA to
Seawater—Triglycerides (Natural Esters)—Natural esters are
developnewnationalstandardsofperformanceforcommercial
water insoluble and will form a separate liquid layer on top of
vessel discharges and the USCG to develop corresponding
water because of its lower density. The base oils are mainly
implementing regulations. The existing vessel discharge re-
miscible with hydrocarbon-based lubricants. Incompatibilities
quirements established through the EPA 2013 Vessel General
may result from the additive packages of specific lubricant
Permit(VGP)andtheUSCGballastwaterregulations,andany
products.
applicable state and local government requirements will apply
7.2.3 Key Properties—Triglycerides (Natural Esters)—
until the EPA publishes future standards and the USCG
publishes corresponding implementing regulations (see Table Natural ester-based lubricants possess excellent lubricity with
high-viscosity indices and flashpoints. They typically have
1).
higher pour points and less oxidative stability than EALs using
other basestocks. The combination of hydrocarbon chain
LetterofcorrespondencefromJohnV.Shermanon“StatusonDevelopmentof
length, double bonds (unsaturation) present in natural esters, as
Tables to Describe Environmental Requirements of EALs as stated in the U.S. EPA
2018 Vessel General Permit” received by Dr. In-Sik Rhee, December 6, 2017. well as the glycerol backbone are central reasons for these
D8324 − 21
property differences from other EALs. The greater the and polymeric esters. The majority of synthetic esters that are
unsaturation, the better the low-temperature properties but EALs are of the polyol ester class including those based on
conversely the worse the oxidative stability.As esters, they are trimet
...
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