# Code Of Practice

for Antifouling

and In-water Hull Cleaning and Maintenance1 

### Table of Contents

Table of Contents.............................................................................................................. ..........1
Preface ........................................................................................................................ ................2 Acknowledgments ................................................................................................................ ......2 Code of Practice for Antifouling ............................................................................................... .3 1. Application, Maintenance, Removal and Disposal of Antifouling Paints.........................3 2. General Requirements ....................................................................................................... 3 3. Application ................................................................................................................ ........5 3.1 Techniques for Pollution Abatement............................................................................5 3.2 Specific Requirements During Application - All Vessels ...........................................5 3.3 Application Procedures for Small Vessels (<25m) .....................................................6 3.4 Application Procedures for Large Vessels (>25m)......................................................6
4. Maintenance................................................................................................................ .......6
5. Removal.................................................................................................................... .........7
5.1 In General ................................................................................................................ ....7
5.2 Releases to Air........................................................................................................... ..7
5.3 Releases to Water ........................................................................................................8 6. Disposal ................................................................................................................... ..........9
7. Conclusion................................................................................................................. ........9 7.1 Major issues addressed include: ....................................................................................10 Code of Practice for In-water Hull Cleaning and Maintenance................................................11 1. Background................................................................................................................... 11 2. Application ................................................................................................................. ......11
3. Procedures .................................................................................................................. ......11 4. Permit Application......................................................................................................... ..122 

# Preface

This Code of Practice for application, use, removal and disposal of antifouling paints was prepared by the ANZECC Maritime Accidents and Pollution Implementation Group with the help of consultants on behalf of ANZECC.
The process leading up to preparation of the Code of Practice has included reviewing (1) fouling problems in Australia and New Zealand, and (2) current and alternative antifoulants. In addition, a widely advertised call for submissions has been made in both countries, several consultative meetings have taken place and there has been a further period of review by ANZECC during preparation of the Code. The Code has been reviewed by regulatory agencies and has agreement from agencies for implementation.
The following document represents a culmination of this process. 

# Acknowledgments

Primary Authors: Dr Marcus S Scammell and Dr Robert Baker, Chem Affairs Pty Ltd, PO Box 980, Lane Cove NSW 2066.
Editors: Kathy Burton et al, Hyder Consulting Pty Ltd
ANZECC Maritime Accidents and Pollution Implementation Group
Pauline Semple Queensland Environmental Protection Agency (Chair) Prue Gaffey Environment Australia (Secretariat) Jane Reynolds Association of Australian Ports and Marine Authorities Kathleen Mackie Environment Australia Paul Nelson Australian Maritime Safety Authority Helge Pedersen Dept of Land Planning and Environment Northern Territory Dr Paul Vogel Department of Environmental Planning Western Australia Ian Kirkegaard Dept for Environment, Heritage and Aboriginal Affairs SA Phillip Johnstone Victorian Environment Protection Authority Jon Delaney Royal Australian Navy - Environment Dr John Volkman CSIRO Mark Bolger Royal Australian Navy - Hydrography Bob Hartley Australian Shipowners Association Jim Huggett Queensland Transport Maritime David Crawford Maritime Safety Authority of New Zealand Lindsay Gow New Zealand Ministry for the Environment Barbara Richardson NSW Environment Protection Authority Jonathon Barrington Australian Quarantine & Inspection Service Rob Dineen Dept of Primary Industries, Water & Environment Tasmania3 

# Code of Practice for Antifouling

1. Application, Maintenance, Removal and Disposal of Antifouling Paints
This Code of Practice applies to the use of all products designed to keep marine vessels and structures free of marine organisms. There are two fundamental modes of action of such products:

1. The coating releases chemicals which inhibit settlement of marine biota i.e . acts as an “antifoulant”, or 2. The coating inhibits successful attachment of marine biota ie. acts as a foulant-release coating.
Typically, the inhibition of settlement is achieved by means of the leaching from the coating of toxic chemicals such as tributyltin or copper, while the inhibition of attachment is achieved through non-stick surface-bound properties associated with chemicals like silicones and PTFE’s that reside in the coating. The principal intended function of all such products, where they are used, whether toxic or not, is as an additional outer coating on vessels, floating, submerged or fixed structures, serving to protect fabric and superstructure against the potentially destructive action of marine biota. It is appropriate to refer to such a product as a “marine protective coating” - MPC. The coating may contain several layers, and may also sub-serve other protective functions beyond that described above.
The leaching of tributyltin from marine paints has been associated with extensive impacts on aquatic organisms, particularly intertidal organisms such as oysters. This has resulted in restrictions on the use of tributyltin worldwide. In Australia, tributyltin can only be used on vessels that are greater than 25m in length (except where exemptions are granted for aluminium vessels) and in New Zealand tributyltin cannot be applied to any vessel. The rules for other marine structures are less clear. The Australian Navy has introduced additional voluntary restrictions on tributyltin usage, with many vessels under 40m in length being required to use copper-based materials.
All antifouling paint formulations, containing substances which could adversely affect the marine environment or agricultural and fisheries industries, must be registered with the National Registration Authority. This registration process helps to ensure that aquatic environments, or the people that work with these coatings, do not become exposed to inappropriate chemicals. It also ensures that appropriate labelling of containers occurs so that hazards to human health can be avoided.
Following is a summary of the major issues involved in protecting the environment whilst handling antifouling paints. Occupational health and safety should be a principal concern and guidelines associated with protection of human health should be adhered to. When best practice improves on the suggestions that follow, best practice should be followed.


### 2. General Requirements
Some form of labelling should be placed on MPC formulations that have been registered, or permitted for use as antifoulants, or are exempt from registration by the National Registration4 Authority so that applicators know that all such products meet current local standards. This would assist in the protection of both human health and of the environment.
The application, maintenance and removal of all antifouling coatings should only be done above the tidal zone at facilities capable of meeting New Zealand and Australian state, territory and commonwealth regulatory requirements for dangerous goods, occupational health and safety and environmental protection, and appropriate standards of best practice. The sale of antifoulants should be restricted to facilities capable of meeting the above requirements. Therefore, Australia and New Zealand should work towards uniform licensing procedures for such facilities.
For example:

• The practice of beaching small vessels for antifouling removal or application is prohibited if the hull is coated with a toxic antifoulant or is being coated with a toxic antifoulant.

• The practice of mooring small vessels in bags, and adding herbicides and/or biocides to the adjacent waters, is not a registered antifouling method with the National Registration Authority and therefore is not legal.

• The underwater cleaning of small and large vessel hulls enhances antifouling release to the water column when the vessel is coated with antifoulants that release toxic substances, as opposed to foulant release coatings (like silicones or teflons) or to untreated hulls. Vessel operators should consult the relevant State agency to determine if in-water cleaning is permitted. All wastes should be contained. The release of coloured materials or turbidity to the water column is an offence under environmental protection regulations.

• Where large vessels (>25m) exclusively or predominantly operate in confined waterways, bays, rivers or estuaries (eg. ferries, barges fishing boats, work vessels, privately-owned pleasure craft), they may be a significant source of toxic substances in the locality. The relevant State agency may prohibit use of particular antifoulants on such vessels (eg. those containing tributyltin). Therefore, operators and those responsible for vessel maintenance should check with the relevant State agency before applying antifoulants.

• New dry docks, slipways and hardstands - no water should run off work areas without treatment to remove toxic substances, turbidity and discolouration. New facilities should be designed and managed so as to allow for eventual disposal to sewer of treated waste water and first-flush runoff.

• Existing dry docks, slipways and hardstands - measures should be adopted to minimise water runoff and certain potentially toxic, turbid or discoloured discharges. Bunds may be used on sealed concrete. Sumps may be used to contain waste water and spillages. Straw bales and woven fibre material may be used to retain suspended solids. Existing facilitiesshould plan for upgrading to allow for eventual disposal to sewer of waste water and firstflush runoff.
Further restrictions on the use of tributyltin in Australian waters are not recommended until adequate alternatives are available. The basis of this recommendation is that efficient antifoulants are required to ensure that exotic species are not imported into local waters. Exotic species can have major impacts on local species and local aquaculture. The effects of5 tributyltin are reversible and will be confined to areas dealing with large vessels. The impacts of exotic species are unpredictable and may not be able to be controlled or restricted. Conversely, the impacts of exotic species may not be reversible. It is proposed to allow for more restrictions on the use of tributyltin paints on larger vessels (>25m) operating in confined waterways, bays, rivers or estuaries. 

### 3. Application
Requirements under dangerous goods and occupational health and safety laws must continue to be met.
3.1 Techniques for Pollution Abatement

• Preparation areas should be bunded to ensure accidental spillage cannot escape to water.

• Spillage should be treated with a suitable absorbent and disposed of as a controlled waste.

• Facilities should be well designed and carefully managed. Alternatively, poorly designed existing facilities should be managed to optimise human and environmental protection;

• All plant and equipment from work areas should be subject to regular preventative maintenance programs to ensure optimum performance.

• Stocks of antifouling paint should be held in labelled containers.

• Antifoulants should be stored in secured and preferably bunded areas.

• Preparation of all antifoulants should take place in areas protected from traffic, with overhead cover.

• Site operators should assume any removed coating is contaminated with biocides and dispose of in accordance with requirements of local environmental and/or waste disposal authorities.

• Established written operational procedures should exist.

• Paint spraying should not be performed in high winds.

• Sheeting should be used to prevent spray drift.
3.2 Specific Requirements During Application - All Vessels

• Cleaning using water is preferred to chemicals.

• High pressure liquid cleaners that operate with detergents, solvents, caustic or acid should only be used if a system exists for collection of waste waters.

• Use of degreasers should be avoided.6 • Discharge of coloured water to the waterway should be avoided.

• Low pressure, high volume spray guns are preferred over high pressure guns.

• Efficient use of all antifouling paints, during their application, should ensure that total losses due to all causes do not exceed 30% of the coating to be applied to the substrate. Consideration should be given to:-

1. maximising coating transfer efficiency during application; 2. blowing back hose lines to the pump on completion of work; 3. using returnable bulk containers; 4. careful planning of coating operations to minimise coating residues and losses; 5. application during optimal weather conditions, if possible.
3.3 Application Procedures for Small Vessels (<25m)

• All surfaces should be protected from over-spray through the use of tarpaulins and sheeting.

• All work should be carried out above the tidal zone.

• Brushes and rollers are preferred over spray equipment, where environmental conditions could result in spray drift off-site.

• Drop sheets should be placed under all surfaces to be painted.
3.4 Application Procedures for Large Vessels (>25m)

• All application of TBT requires the approval of the State agency and the facility must meet the specific requirements of that agency.


### 4. Maintenance
In general maintenance of small and large vessels should be conducted at an appropriate facility, either above the tidal zone or in a dry dock. The hulls of vessels pose a number of risks to the local environment including the release of toxic chemicals from antifouling paints and the release of exotic species that may have fouled the hull. With respect to exotic species, in particular, large vessels (>25m) should be maintained out of the water, whenever possible.

• In-water cleaning of hulls may be permitted in some localities. Consult the relevant State agency and ensure containment of all wastes.

• Cleaning of sea chests, sea suction grids and other hull apertures may be permitted (in Victoria) providing that any debris removed is not allowed to pass into the water column or fall to the sea bed (debris includes all organisms which may be attached). Vessel operators should consult the relevant State agency.

• Polishing of propellers may also be permitted, if vessels are greater than 200t. The relevant agency should be consulted.7 The water blasting, particularly of large vessels (>25m) with self-polishing co-polymer painted hulls is used to remove the hydrolysed layer as well as slimes and light fouling prior to repainting. This process can generate coloured waste water. Coloured run off should be avoided and, where practical, water should be recollected for recycling or released to sewer (with approval of sewerage authorities).



### 5. Removal
Removal processes on small craft (<25m) should use the best available techniques that do not entail excessive cost. The same tarpaulin and sheeting processes should be used when removing paints as have been specified for the application of paints. This would allow cheap collection of wastes for off site disposal.

No removal should be undertaken while the vessel is in the water. Removal should not be undertaken on beaches or in the intertidal zone. All removal should be undertaken at appropriately equipped and approved facilities.
Old antifouling coatings are not to be burnt off. Over the past fifty years antifouling formulae have used a variety of extremely hazardous active chemicals and the practice of burning these paints may place both the operator and people in the immediate vicinity at risk. Further, the burning of antifouling paint residues after removal may generate highly toxic fumes, smoke and gases. All antifouling paint residue should be treated as contaminated waste and should be disposed of in accordance with the requirements of local environmental and/or waste disposal authorities.

5.1 In General

• Measures must be undertaken to contain wash waters and to segregate wash water from non-contaminated flows.

• Measures should be taken to prevent particulate matter being flushed from a dry dock, slipway or hardstand when a vessel is being treated or refloated.

• Measures should be taken to reduce wind-blown particulates.

• Release of either particulates or wet waste, contaminated with tributyltin, into the adjacent water way must be avoided.

• All antifouling wastes should be treated as controlled wastes as they are all contaminated with biocides. Such waste should be collected for disposal at an appropriate facility, in accordance with local environmental and/or waste disposal authorities.

• Paint scrapings should be treated as contaminated waste and disposed of in accordance with the requirements of local authorities.

• Residues should not be washed into the sea.

5.2 Releases to Air8 • Wet abrasion is preferable to dry abrasion, which can create toxic dust.

• Dry grit blasting creates dust problems and methods should be employed to contain this dust.

• Use of wet methods controls particulate emission to air but generally creates high volumes of liquid waste. Ultra high pressure water blasting, with lower volumes of liquid waste, is likely to become widely available in the future.

• Vacuum blasting, or containment blasting, with reusable abrasives and separation equipment is the current best option for removal of used antifouling coatings.
If vacuum or containment blasting is employed emission targets should be as follows:-

1. if operating without wet particulate arrest, exhaust emissions of 35mg/m 3 should be targeted; 2. if operating with wet particulate arrest, exhaust emissions of 20mg/m 3 should be targeted.

5.3 Releases to Water

• Use of water during removal should be minimised by moving towards ultra high pressure water blasting, vacuum or containment blasting.

• Use of high pressure blasting should be minimised and coloured run off should be avoided.

• Where practical, water should be recollected for either recycling or for release to sewer (with the approval of local sewerage authorities) so that the water can be treated.

• Release to sewer, where approved by local authorities, should be controlled to allow maximum dilution in the sewerage system.
The discharging of wastewater, contaminated by antifouling paints, to the sewerage system may cause concern with sewerage managers because sewage treatment is dependent on bacterial processes. Antifouling paints have broad toxic effects and their biocidal impacts on bacteria in sewage systems is unknown. However, the quantities of water flowing through the sewage systems compared to the quantities of waste water evolved during boat cleaning are sufficiently different to allow the yard operator to take advantage of dilution effects. Gradual release of waste water from shipyards to the sewer, i.e. by releasing the water through a very small aperture pipe, will assist in minimising any potential biocidal effects. Approval would need to be sought from the relevant sewerage manager.

• Hosing and brushing down activities, without the use of detergents or abrasives to remove weed and barnacles, generally do not require specialised treatment to retain and dispose of material removed. However, if the material includes live organisms from another country or a distant part of Australia, all debris should be collected for disposal as solid waste. Check with the port or marina management on controls on ballast or fouling organisms.9 

### 6. Disposal of residues

• All antifouling residues should be treated as contaminated wastes, as they are all contaminated with biocides. Such wastes are to be collected for disposal in accordance with requirements of local environmental and/or waste disposal authorities, and prevented from entering adjacent waterways.

• Keeping and disposal of tributyltin contaminated wastes may require special approval ( eg. in NSW), and users should notify local environmental authorities.

• Contaminated wastes, of all types, should be kept in sealed containers.

• Antifouling paint residues should not be burnt owing to their potential high toxicity.

• Contaminated wastes, of all kinds, should be removed by licensed contractors who are advised of the type of the waste, and records should be kept of all such disposed wastes.

• Contaminated grit should be treated as antifouling waste and disposed of in the same way as antifouling paint residue.

• Biological materials (marine biota) removed from antifouled hulls, should be disposed of as solid waste in accordance with local requirements eg. to landfill.

• Liquid wastes are not to be poured into drains. All liquid wastes should be placed in suitable containers, sealed, and disposed of in accordance with local environmental and/or waste disposal authorities.
Where antifouling paints have been removed from old vessels (greater than 10 years old), it should be assumed that the paint residue contains tributyltin, unless test results prove otherwise, and the paint residue should be disposed of at the approved local landfill facility. Antifoulants removed from vessels constructed before the 1970’s may contain a variety of extremely hazardous chemicals, including substances like arsenic, mercury and DDT, and should be disposed of at a local approved landfill facility in which leachates are contained.


### 7. Conclusion
This Code of Practice covers the processes of applying, maintaining, removing and disposing of antifouling paints.10 7.1 Major issues addressed include:

• the need to limit application, maintenance and removal of antifouling coatings to approved, licensed facilities;

• the need for uniform licensing of such facilities;

• the need for more restrictions on use of tributyltin-based antifoulants on craft >25m in length, where these operate in confined waters;

• the need to ensure that new facilities include design and management provisions, to enable eventual disposal to sewer of treated waste waters;

• the need to ensure that existing facilities plan for upgrading to eventual sewer disposal of waste waters.
This Code of Practice also includes other measures aimed at protection of the health of workers and of the environment. When best practice improves on these measures, best practice should be adopted.11 

# Code of Practice for In-water Hull Cleaning and Maintenance

1. Background
(1) In recent years much attention had been focussed on the introduction of exotic marine organisms via ship’s ballast. Another way of transporting exotic marine organisms is via a ship’s hull. (2) To minimise the risk of further exotic organisms establishing in Australian waters, ANZECC in consultation with the Australian Quarantine Inspection Service has established the following Code of Practice for In-water Hull Cleaning and Maintenance

. 

### 2. Application

(1) These requirements shall apply in the Australian waters and are applicable to all commercial vessels. (2) These requirements are to be used with any relevant state environmental protection agency requirements.



### 3. Procedures

(1) No part of a vessel’s hull treated with antifoulant is to be cleaned in Australian waters without the written permission of the Harbour Master, local government or state environmental protection agency (administering authority). (2) In-water hull cleaning is prohibited, except under extra ordinary circumstances and permission will not normally be granted. (3) The cleaning of sea chests, sea suction grids and other hull apertures may be permitted provided that any debris removed (including encrustation, barnacles, weeds) is not allowed to pass into the water column or fall to the sea bed and subject to any other conditions attached to the permit. An application seeking permission to carry out this work must be lodged with the administering authority at least five (5) working days prior to commencement of the anticipated start date. Such application will detail how encrustations, barnacles and other debris will be contained and or collected for disposal as well as the method of disposal. (4) The polishing of ship’s propellors may be permitted subject to any conditions attached to the permit. An application seeking permission to carry out “propellor polishing” must be lodged with the administering authority at least five (5) working days prior to commencement of the work. (5) Applications for permits may be facsimiled to the administering authority.12 

### 4. Permit Application

(Insert logo and contact details)



### Application for Permission to clean sea chests and/or other hull apertures and/or propeller polishing and/or in-water hull cleaning and/or maintenance

To administerin g authorit y : Telephone: Facsimile: Port of:
From (Master/Owner/Agent/Contracto r ): Telephone: Facsimile: Permission is requested to carry out the following work on: Vessel:
From (Time/Date) : To (Time/Date) : At (Berth, if known, or slipway) : Detail of Work:

Method of collection and disposal of encrustation, barnacles etc:



### Office Use Only: Application Denied Approved Approved subject to:

Signature: Position: Date: