The VGP is an important regulation for most commercial vessels sailing in US coastal waters and inland waterways. It protects the marine environment by placing restrictions on the discharges permitted in US waters. Not only does it cover operational discharges such as oil, ballast water, and bilge water, it also sets strict requirements concerning sterntube lubricants. Despite initially intending to release the third version of the VGP in late 2017, the EPA has now set a new date of March 2019 for the update—and plans to include a consultation period of at least 30 days.
One of the most significant stipulations of the VGP regulation is the requirement to use environmentally acceptable lubricants (EALs) at all oil-to-sea interfaces. This has proven to be a challenge for some ship owners, as EALs are not compatible with all sealing materials. There has even been a number of instances of damaged seals and bearings, which have been attributed to low-quality lubricants. Ship owners should therefore always check their seal component supplier’s list of approved lubricants before switching to EALs.
The EPA strongly encourages owners/operators of eligible vessels to seek permit coverage prior to December 18, 2018, as coverage under the 2013 VGP cannot be obtained after that date.
Current VGP requirements remain in place
The current VGP regulation will continue to apply until the new version enters force. Any vessels currently covered by VGP 2.0 are not required to take any further action. However, operators of new vessels with a keel laid prior to December 18, 2018 are required to file a notice of intent (NOI). New vessels with keel laid after this date will be covered once VGP 3.0 is published in its final form and the ship’s operator has filed the necessary NOI.
If you need more information on VGP requirements, visit www.vgp2013.com. There you can find various FAQs and a handy conformity check to help you ensure compliance with the EPA’s regulation.