VGP Pro Series

VGP Compliance Declaration

VGP Pro Grease (NLGI Class 0, 1, 2)

VGP Pro Grease (NLGI Class 0, 1, 2) an Environmentally Acceptable Lubricant (EAL) according to the definitions and requirements of the US EPA 2013 Vessel General Permit, as described below.

VGP Section 2.2.9
All vessels must use an EAL in all oil to sea interfaces, unless technically infeasible. “Environmentally acceptable lubricants” means lubricants that are “biodegradable” and “minimally-toxic” and are “not bio-accumulative” as defined in Appendix A of the permit.

Environmentally Acceptable Lubricant Definition – VGP Appendix A
In order to be classified as an “Environmentally acceptable lubricant” the oil maker must determine that the lubricant is “biodegradable”,”minimally-toxic” and “not bio-accumulative” as defined in Appendix A ofthe permit. Alternatively, oils that are labeled by one of several programs specified in the permit are regarded as acceptable.

VGP Pro Grease and its components have been evaluated and meets the VGP definition of an Environmentally Acceptable Lubricant.

• Biodegradability / Non Bioaccumulative – VGP Appendix A
  The VGP definitions of “Biodegradable” include grease formulations that contain at least 75% by weight of a constituent substance or constituent substances that give a minimum test result of 60% according to OECD 301B. The 25% of the formulation that need not meet the above biodegradability requirements may be inherently biodegradable or non-biodegradable (but not bio-accumulative). Acceptable test methods to demonstrate inherent biodegradability include >20% according to OECD 301B.
  In order to comply with the 2013 VGP biodegradability / bioaccumulation requirement, it is necessary to consider the constituent substances. Only substances present in the formulation above 0.10% need be assessed.
  The constituent substances of VGP Pro Grease (NLGI Class 0, 1, 2) meet the above requirements.
  
  
• Minimally Toxic – VGP Appendix A
  The VGP definitions for “Minimally-Toxic” greases include achieving acute toxicity results of at least 1000 mg/L according to OECD 201, 202, and 203 (Algae, Daphnia and Fish).
  VGP Pro Grease (NLGI Class 0, 1, 2) meets the above requirements.

California-Specific VGP Compliance Statement:

In addition to federal Vessel General Permit (VGP) requirements, State of California has additional conditions as outlined in the California Clean Coast Act of 2005 and the State Water Resources Control Board’s 401 certification. This includes adherence to stricter discharge prohibitions, the prohibition of hazardous waste discharges as defined by California Code of Regulations Title 22, Section 66261, and Water Code Section 13173, as well as compliance with all effluent limitations and monitoring requirements outlined in the California Ocean Plan and Regional Water Quality Control Plans. The product is certified for VGP Pro Grease (NLGI Class 0, 1, 2) meets the requirements for use in compliance with California’s Water Quality Protection Areas and is free from prohibited substances such as oily bilge water, sewage sludge, and hazardous chemicals as defined under state law.

Record Keeping –VGP Section 4.2
Vessel must keep records on the vessel that include the Technical Data Sheet for all EALs used in Oil-to-Sea interfaces on board the vessel in order to prove compliance with the permit.

Grignard Company LLC, 505 Capobianco Plaza, Rahway, NJ Ph: 732.340.1111 Fx: 732.340.0111 www.grignard.com