Oil leakage rules in Polar Code versus U.S. EPA rules

September 03, 2013

Shouldn’t the oil leakage rules in Polar Code proposed by the U.S. match U.S. EPA rules?

I am hoping someone can explain to me the position of the United States on the Polar Code relating to oil to sea interfaces on ships compared to the new US EPA Vessel General Permit (VGP).  In the U.S. EPA VGP, that comes into force on Dec. 19, 2013, (Section 2.2.9), it states:   All vessels must use an EAL (Environmentally Acceptable Lubricant) in all oil to sea interfaces, unless technically infeasible.   An EAL is typically considered a readily biodegradable lubricant or seawater.  There is no indecision here – vessels must use it.

However, the proposal put forward by the U.S.A. (DE 57/11/9) relating to the Polar Code states that “non-toxic biodegradable lubricants and water-based systems are available and should be recommended for ships operating in Polar waters.  Mandatory use of such systems may be warranted following further consideration of the long term performance of these systems in Polar waters;”

The statement in the above - “should be recommended”, basically means ‘do it if you want to’.   It allows the ship owner many options that can still permit discharges of oil into the polar seas and oceans.   As for the long term performance of water-based systems, IMO Secretary General Sekimizu just spent 5 days aboard the 50 Let Pobedy last week, a Russian nuclear-powered icebreaker traveling along the Arctic's Northern Sea Route.  That Russian vessel along with the US Coast Guard ships, Healy, Polar Sea and Polar Star, have been working in the Arctic regions for many years using seawater lubricated propeller shaft bearings guaranteeing zero risk of oil pollution from the propeller shaft system.


Craig Carter, Canada


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