American Chemical Technologies
Neptune Series- EAL
Scott Kovanda
Marine Division Product Manager
EPA- Vessel General Permit
approved base stocks
•
•
•
•
PAO (HEPR)
Water
Vegetable Oil (HETG)
Synthetic Esters (HEES)
•
Polyalkylene Glycols
(HEPG)
Favorable Environmental
Properties for Neptune
Transport Canada
U.S. Coast Guard
Commandant
United States Coast Guard
2703 Martin Luther King Jr. Ave , S.E.
Stop 7509
Washington, DC 20593-7509
Staff Symbol: CG-ENG-5
Phone: (202) 372-1424
Fax: (202) 372-1926
16714/2014-327
8 JUL 2014
Mr. Scott Kovanda
American Chemical Technologies
485 E. Van Riper Road
Fowlerville, Michigan 48836
Subj: OIL OR OIL-LIKE DETERMINATION FOR NEPTUNE LUBRICANTS
Dear Mr. Kovanda:
This letter is in response to your e-mail of May 2, 2014 in which you asked whether a number of
lubricants under the Neptune product line are considered an oil or chemical. The following
products are considered chemicals and not as oil or oil-like substances:
Neptune AW-46 (contains Polyether polyol)
Neptune AW-68 (contains Polyether polyol)
Neptune 32 (contains Polyether polyol)
Neptune 109 (contains Polyalkylene glycol)
Neptune 159 (contains Polyalkylene glycol)
If you have any questions regarding this matter, please contact me by telephone at (202) 3721424, or by e-mail: [email protected].
Sincerely,
P. A. Keffler
Acting Chief, Hazardous Materials Division
By direction of the Commandant
Good morning Mr Burton,
My apologies for the delay in my reply to you.
I have reviewed the use of polyalkylene glycol hydraulic fluids, it is not classed as
a marine pollutant under the Regulations for the Prevention of Pollution from
Ships and for Dangerous Chemicals and is viewed as non-toxic.
Transport Canada does not “approve” the choice of lubricants or hydraulic fluids
used on ships, that said from an environmental protection view, polyalkylene
glycol hydraulic fluids do seem to offer advantages over some conventional
hydraulic fluids which can be toxic, irritants, and be classed as oil. As the
compound is used in cosmetics and skin creams, from a safety point of view, this
poses fewer risks to crews who would be handling hydraulic fluids.
In short, we would have no objection to the use of your product.
I hope this provides the clear answer you seek. If the Canadian Coast Guard or
Public Works and Government Services Canada people have further concerns,
they can contact me directly.
Kind regards,
Paul Topping Manager, Environmental Protection
Gestionnaire, Protection de l'environnement Transport Canada - Marine Safety
Transports Canada - Sécurité Maritime
t: 613-991-3168 c: 613-220-5735 f: 613-993-8196
e: [email protected]
PAG’s are the only true non-sheening
EAL
-PAG’s pass the US EPA 40 CFR 435 Static Sheen Test.
-PAG’s specific gravity is greater than 1.
-All other EAL’s have a specific gravity of less than 1 meaning they will float
on the waters surface if spilled.
PAG fluid spill
PAG fluid stirred
U.S.C.G. SFLC’s Stance on EAL’s
 USCG SFLC: (Surface Forces Logistics Center)
 Engineering Arm for the U.S. Coast Guard
 “The preferred environmentally acceptable lubricants for
use onboard USCG cutters are the PAG based
lubricants.”
 Ed Guervara- Lubricant expert from the Navy
 Kevin Danahy- Propulsion expert