Australian and New Zealand Environment and Conservation Council, 2000
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 Registration 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 facilities should plan for upgrading to allow for eventual disposal to sewer of waste water and first-flush 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 of 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.
]
