Environmentally Acceptable Lubricants

Brian Smith, FHWA
Marella Buncick, FHWA

The mission of the Office of Federal Lands Highway (FLH), of the US Department of Transportation (USDOT), Federal Highway Administration (FHWA), is to improve transportation to and within Federal and Tribal Lands by providing technical services to the highway/transportation community, including scenic roads and roads in National Refuges, National Parks, and some of our nation's most pristine environments. Construction work in must be sensitive to the environment including sensitive aquatic areas.
In the fall of last year, FLH began preparing for inquiries from contractors and Federal Land Management Agency Partners regarding environmentally acceptable lubricants to use in construction equipment during work in water or near other sensitive areas. The FHWA Resource Center (RC) assisted in preparing information that would help resolve regulatory restrictions such as environmental monitors put on construction work near sensitive aquatic areas.
FHLD and FHWA RC are gathering and reviewing information on Environmentally Acceptable Lubricants (EALs) with the intent of providing solid recommendations and perhaps revising the contract language for future projects to provide some flexibility for contractors while ensuring protection of our nation's pristine aquatic resources.
The term environmentally acceptable lubricant (EAL) describes those lubricants that have been demonstrated to meet standards for biodegradability, toxicity and bioaccumulation potential that minimize their likely adverse consequences in the aquatic environment, compared to conventional lubricants. Environmentally Acceptable Lubricant (EAL) is the most favorable classification by USEPA. EALs are "readily biodegradable".

The document -EPA 800-R11-002, November 2011 -defines what USEPA is calling "Environmentally Acceptable Lubricants" and how EALs are differentiated from other marketed products that use terms e.g., "environmentally friendly", 'green product", "no sheen", "white, non-toxic", "food grade", "ash-less formulation", "plant based", "inherently biodegradable", etc.

EPA has made EALs a requirement in its 2013 Vessel General Permit. Now their use is increasing and EALs' percentage of the total lubricant market is growing. A quick google search will turn up a number of products that are EAL compliant. Buyers and searchers should know the right search terms and the principal national and international labeling certification programs associated with EPA approved EALs.

EALs must be classified as "practically non-toxic or relatively harmless" by U.S. Fish & Wildlife Service Toxicity Classification. EALs characteristics have been evaluated and identified using certain American Society for Testing and Materials (ASTM) testing standards and are readily biodegradable and non-bioaccumulative. Other key properties of "Environmentally Acceptable Lubricants" (EALs) water solubility and non-sheening properties.
This presentation will cover the characteristics, market availability, feasibility, and advantages and disadvantages of four types of EAL base formulations.

Abstract Keywords
water quality