The Imo Performance Standard For Protect

THE IMO PERFORMANCE STANDARD
FOR PROTECTIVE COATINGS (PSPC)

FOR SEAWATER BALLAST TANKS AND BULK CARRIER DOUBLE HULLS
A GUIDE FOR OWNERS

AND INSPECTORS
PANOS ZACHARIADIS
January 2007
THE IMO PERFORMANCE STANDARD
FOR PROTECTIVE COATINGS (PSPC)
FOR SEAWATER BALLAST TANKS AND BULK CARRIER DOUBLE HULLS
A GUIDE FOR OWNERS AND INSPECTORS

BY PANOS ZACHARIADIS
January 2007
THIS GUIDE CAN BE DOWNLOADED FROM THE SITE OF HELLENIC CHAMBER OF SHIPPING www.nee.gr
CONTENTS:
PREFACE / DISCLAIMER / ACKNOWLEDGEMENTS / REFERENCES.............3
1. APPLICATION (SOLAS vs. IACS)……………………….………………..……..4
2. THE TECHNICAL STANDARDS REFERENCES ………………………….……4
3. AT WHAT COST? ……………………………… ………………………………..5
4. WHAT CHANGED? ………………………………………………………….……..6
5. SPECIFIC COMMENTS ON THE STANDARD …………………… ……......…..7
TABLE 1 ……………………………………………………………………..…………14
ANNEX 3 …………………………………………………………………….…………29
APPENDIX (PICTORIALS)……………………………………….……….………… 31
WORD SEARCH (COMMENTS ON FOLLOWING TOPICS APPEAR ON INDICATED PAGES)
“COATING TECHNICAL FILE (CTF)”……………………………….…9/14/17/19/20/21
“MAINTENANCE”……………………………………………………………………..9/11
“SHOP PRIMER”…………………………….……….…7/10/11/13/15/18-21/23/24/33
“ANNEX 1”………………………………….………………………………..15/16/20/26
“CONDITION BETWEEN COATS”………………………………...……………….16/17
“PRIMARY SURF. PREPARATION” ……………………..…..…10/17/18/19/20/23/33
“SECONDARY SURF. PREPARATION”………………………...………....13/16/20/21
COVER PICTURE COURTESY AMTEC CONSULTANTS & THETA MARITIME.
THE IMO PSPC / A GUIDE FOR OWNERS AND INSPECTORS PANOS ZACHARIADIS
2
PREFACE:
Having taken part in the development of this standard and in the finalization of its
wording during MSC 81, the author has been the recipient of many “interpretation”
questions. It is hoped that this short guide may assist the industry and especially
ship-owners, by clarifying some issues and by pointing out some important areas
which are not readily identifiable from a fast perusal.
This is not a guide on how to effect proper ballast coating. It is primarily a guide to
explain the new IMO regulation standard. It is not intended to be exhaustive nor is it
intended for the highly knowledgeable coating experts. That would be overly
ambitious. Instead it is intended primarily for owner’s representatives at the office (to
aid them when first evaluating if a shipyard submitted specification complies with the
standard) and for owner’s representatives on site (by pointing out the opportunities
and weaknesses of the standard). Special effort has been exerted to be factual and
impartial and thus it is hoped that this guide can be utilized by all relevant parties.
DISCLAIMER:
In the interest of improving shipping construction quality, this guide is distributed free
to the industry. It is intended for general distribution and extracts of information may
be reviewed and reproduced for private use, study or educational purposes, but not
for sale or for use in conjunction with commercial purposes. Any use of such
information must be accompanied by an acknowledgment of the source of the
material and by proper citation. There is no warranty on the completeness and
correctness of information and thus no liability is accepted as a result of its use.
Views and comments expressed are solely those of the author and not necessarily
those of any organizations to which the author belongs.
ACKNOWLEDGEMENTS:
The author wishes to thank the following individuals, organizations and corporations:
- Dr. Les Callow of Amtec Consultants and Eur. Ing. Peter D. Contraros of Theta
Maritime S.A. for proofreading this work and enhancing it by their suggestions. Also
for their hard efforts during MSC 81 and D&E subcommittee to develop the standard.
- Theta Maritime S.A. of Piraeus, Greece for allowing reprint of pictorials and quotes
from Reference 4 (interested readers can contact mail@thetamar.com for Theta’s
Seminar package on PSPC.)
- Mr. Kostas Kitsikopoulos of North Star Marine S.A. for his valuable input stemming
from his immense field experience.
- Dr. Nikos Mikelis for his efforts to properly develop this standard in the IMO
correspondence groups (representing Greece).
- The Hellenic Chamber of Shipping for hosting the guide and making it available for
download.
REFERENCES:
1. NPCA 2006 International Marine & Offshore Coatings Conference, June 7-9,
2006, SSPC Presentation, Update on SSPC Standards for Surface
Preparation of Steel, www.paint.org/meetings/marine/marine5_06.pdf
2. NACE Resource Library, www.nace.org/nace/content/library/coatingSeries
3. Scopes of SSPC Paint Application Standards, Guides and Specifications,
www.sspc.org/standards/pascopes.html#pa2
4. Theta Maritime S.A., Seminar on PSPC, Piraeus, June 29, 2006. Speakers:
Eur. Ing. Peter D. Contraros, Dr. Les Callow, Dr Jane Lomas
5. IACS Procedural Requirement No. 34, www.iacs.org.uk/
6. Abrasive Blasting in Practice, Mario S Pennisi, www.coatfab.com/
abrasive_blasting.htm
3
1. APPLICATION (SOLAS vs. IACS)
The Performance Standard for Protective Coating (PSPC), made mandatory by

SOLAS II-1, A-1, Reg. 3-2, was adopted by the IMO Maritime Safety Committee
(MSC 82) in Istanbul, 8 December 2006.
For SOLAS the dates of entry into force are:
For ships of not less than 500 gross tonnage:

1. for which the building contract is placed on or after 1 July 2008, or
2. in the absence of a building contract, the keels of which are laid or which are
at a similar stage of construction on or after 1 January 2009, or
3. the delivery of which is on or after 1 July 2012.
The coating application (including steel surface preparation etc) shall be in

conjunction with:
1. Coating system approval:

Statement of compliance or Type Approval issued by a third party
2. Coating inspection:
To be carried out by qualified coating inspectors certified to NACE Coating Inspection
level 2 or FROSIO Inspector level III or equivalent, during coating process, to ensure
compliance with the Standard. Results to be included in the Coating Technical File.
3. Verification:
To be carried out by the Administration or recognized organization, consisting of:
a. reviewing the Coating Technical File
b. checking the Technical Data Sheet and Coating system approval
c. checking the coating identification on representative containers
d. checking that the coating inspectors are qualified and check their reports
e. monitor implementation of the coating inspection requirements.
For IACS the dates of entry into force are:
For ships covered by the IACS Common Structural Rules (CSR), i.e. double hull oil
tankers with L > 150 m and bulk carriers with L > 90 m, the standard entered into
force immediately after adoption by MSC 82 on 8 December 2006, as decided by the
IACS Council.
For uniform handling of CSR until 1 July 2008, IACS has adopted a Procedural
Requirement (PR No. 34) covering guidelines and procedures for:
· Type Approval of coatings
· Assessment of coating inspectors’ qualifications
· Administrations’ engagement in inspection procedure agreement
· Verification of application of the PSPC
· Review of Coating Technical File.
2. THE MANDATORY NATURE OF TECHNICAL STANDARDS REFERENCES.
At the time of this writing (January 2007) the current wording of the standard is that of
MSC 82, where the reference standards (ISO, ASTM etc) have been moved from the
main text to footnotes. Since normally footnotes are not mandatory, a paragraph was
proposed by the drafting group of MSC 82 (paragraph 4.4.5) with the intention to
keep the footnotes mandatory. However, although the intention was that, according
4
to some experts, the wording of the paragraph was that typically used for non-
mandatory footnotes/references, (as per paragraphs 6 and 7 of Resolution A.911).
Thus the paragraph was appropriately removed by MSC 82, on the last day without
time to properly close the issue. Resolution A.911 suggests the proper wordings and
actions in cases that references and footnotes are to be mandatory (e.g. paragraph
18.1.1). Thus at present, if one goes “by the book” it can be said that the status of
footnotes is “unclear” since neither the guidelines of Res. A.911 for mandatory nor for
non-mandatory footnotes have been applied. This may mean that MSC may want to
revisit the issue before the regulation comes into effect with some experts advising
that the clarification may be as simple as a one sentence in a resolution (as per Res.
A.911 par.18.1.1).
However the fact is that the references and footnotes are clearly mandatory (since in
the prior version they were located in the main text) and the intention of MSC 82 was
also clear to keep them mandatory. In the opinion of the author there really cannot be
any other way since in many cases the wording of the standard is tied to the specific
reference standard of the footnote. If other, even similar standards where developed
and used, the wording of the main text may have to change in some cases - and that
cannot be. Some flag administrations have already advised that even the present
version leaves no doubt that, when passed into their national regulation, the
footnotes will be mandatory.
Finally IACS has appropriately applied the reference standards as mandatory for
CSR.
3. AT WHAT COST?
As said before this regulation will be a statutory requirement for ships whose contract
is signed on or after July 1, 2008. But for ships built with IACS CSR the standard
applies earlier. i.e. for contracts signed after December 8th, 2006.
Already shipyards have been asking potential owners for price increases for the
ships on which the standard will apply. In most cases the requested price increases
are not wholly justified.
- There have been cases where the shipyard’s standard coating practices are
virtually identical to the rule standard and yet large price increases are requested (on
the reasoning that paperwork and administrative costs for the yard will escalate).
- There have been cases where owners have already built a series of ships
with a yard, whose ballast tank coating specification meets or exceeds that of the
standard. Yet for a subsequent series of identical ships the yard asks for price
increases. The yard’s reasoning here is that its costs and production delays will
increase overall (since ships of other owners with lower coating specification will
need to be upgraded and that will delay the whole production line).
- And finally most shipyards do not have yet a clear idea of the effects and
extent of any possible cost increases. Thus, taking advantage of today’s “seller’s
market” and the relative shortage of berths, they have the luxury to be very liberal in
their estimations so as to exclude any possibility that the yard will be left to absorb
any of the costs.
These price increases are not explicit for CSR ships contracted after December 8th
2006 but are usually lumped together with the going market price of the ship. Thus it
is very difficult for the owner to differentiate the cost increase due to the coating
standard (unless this is applied as owner’s option for pre-December 8th contracts).
In the longer term, the market forces and competition will normalize and incorporate
any increases. As shipyards adapt, the cost increases due to application of this
5
standard will be insignificant compared to the current market value of new ships. But
in the short term, the owner must be alert but also willing to pay the actual and fair
price increase for his ship.
The fair price increase will not be easy to calculate and certainly the first owners after
December 8th 2006 will pay a disproportionate price increase. However some
starting suggestions on how to get a ballpark figure are provided below: It certainly
requires work on the part of the owner but it may save a lot from the original shipyard
extra cost request.
- Resist a generalized and unsubstantiated cost increase request by the

shipyard. Request a detailed breakdown of the items and costs, applicable to your
specific ship (not those applicable to the shipyard in general such as new equipment,
overhead expenses etc.)
- Find out what was the actual shipyard’s ballast tank standard coating
practices before the regulation. There are several ways to do this such as consulting
yard’s existing ship specifications, yard’s published coating quality procedures etc.
But the best way is to consult other owners who have recently built there.
Subsequently any upgrades required to reach the new standard should be identified
and their cost evaluated. The labor cost of any upgrade for the particular shipyard
could be estimated primarily based on the experience of prior clients. There are
owners who have applied upgrades before (e.g. stripe coats, second spray coat, 3-
pass grinding etc) and the requested extra costs for these items are well known to
them. It is hoped that such owners will assist others by disclosing such “commercial”
information. In the final analysis, keeping the shipyards requested increase fair,
reasonable and in check, will be to everyone’s benefit (including the shipyard’s
which would not want to be found in an awkward position when a neighboring
shipyard is requesting substantially lower extra costs.) Some major owners with
substantial recent newbuilding activity are able to mention the labor cost of, say, a
coat of ballast tank paint on a VLCC, by heart (even on a per square meter basis!)
The material costs are of course quite straightforward to calculate.
In short the owner should examine, and pay for, real upgrades applied to his specific
ship.
4. WHAT CHANGED?
For the good shipyards and the prudent owners little has changed. But for shipyards
with poor coating practices, the standard eliminates some unacceptable coating
practices of the past which resulted in early coating failure. Coating failure is
extremely difficult and costly to repair properly after the ship leaves the new building
berth.
However, for a prudent owner about to build a ship, the best approach is to assume
that not much has changed. Informed and in depth checking of the specification and
contract is still required. Applying coating upgrades is still recommended and a good
coating supervision team is also still required.
-SPECIFICATION / CONTRACT:
Despite the application of PSPC and the inspections by the “approved” PSPC
inspector, (see also paragraph 3.2 below) the owner must ensure that his supervision
team has the same supervision rights as before. His coating inspectors must have
prior notifications and access to all relevant inspections and the same authority as
before to accept or reject after their inspection.
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-SUPERVISION TEAM:
Just as the owner’s hull supervision team performs inspections which are also
covered by class, similarly the owners coating supervision team should perform their
own coating inspections even if these are also performed by the “approved” PSPC
inspector. What is more, the owners coating inspectors must familiarize themselves
with the standard and especially with its documentation requirements. Proper
inclusion of all relevant documentation to the Coating Technical File will be invaluable
for the owner in the future, especially in cases of premature coating failure (see
comments below in Table1).
-UPGRADES:
A regulation is always a minimum acceptable standard. Although this coating
standard is a very good basis, it does have certain weaknesses. Thus upgrades for
prudent owners are always recommended. For example the standard does not call
for total shop primer removal (only the damaged primer is to be removed). This is
perhaps the biggest weakness of this standard since shop primers are not the best
foundation for long life coating systems (see also comments in sections 2.3 and 3.2
of Table 1). Furthermore, in some countries the quality of shop primers is not as good
as in others. This can have a detrimental effect to the longevity of the coating. It is
advisable therefore that the owner evaluates the costs and benefits of specifying total
shop primer removal (Sa 2 ½) at block stage or at least blasting to Sa 2. Other
upgrades may be internal coating of ballast piping, etc.
5. SPECIFIC COMMENTS ON THE STANDARD.
FOR EASY REFERENCE, COMMENTS (IN BOLD ITALIC – GRAY

BACKGROUND) ARE INSERTED AFTER RELEVANT PARAGRAPHS OF THE
ORIGINAL IMO TEXT.
ANNEX
PERFORMANCE STANDARD FOR PROTECTIVE COATINGS FOR

DEDICATED SEAWATER BALLAST TANKS IN ALL TYPES OF SHIPS
AND DOUBLE-SIDE SKIN SPACES OF BULK CARRIERS
1 PURPOSE
This Standard provides technical requirements for protective coatings in dedicated
seawater ballast tanks of all type of ships of not less than 500 gross tonnage and
double-side skin spaces arranged in bulk carriers of 150 m in length and upward1 for
which the building contract is placed, the keels of which are laid or which are
delivered on or after the dates referred to in SOLAS regulation II-1/3-2 as adopted by
resolution MSC.215(82).
2 DEFINITIONS
For the purpose of this Standard, the following definitions apply:
2.1 Ballast tanks are those as defined in resolutions A.798(19) and A.744(18).
2.2 Dew point is the temperature at which air is saturated with moisture.
2.3 DFT is dry film thickness.
7
2.4 Dust is loose particle matter present on a surface prepared for painting, arising
from blast-cleaning or other surface preparation processes, or resulting from the
action of the environment.
2.5 Edge grinding is the treatment of edge before secondary surface preparation.
2.6 “GOOD” condition is the condition with minor spot rusting as defined in
resolution A.744(18). Note that IACS definition of “GOOD” is different – see 4.1
2.7 Hard coating is a coating that chemically converts during its curing process or a
non-convertible air drying coating which may be used for maintenance purposes. Can
be either inorganic or organic.
2.8 NDFT is the nominal dry film thickness. 90/10 practice means that 90% of all
thickness measurements shall be greater than or equal to NDFT and none of the
remaining 10% measurements shall be below 0.9 x NDFT.
2.9 Primer coat is the first coat of the coating system applied in the shipyard after
shop primer application.
2.10 Shop-primer is the prefabrication primer coating applied to steel plates, often in
automatic plants (and before the first coat of a coating system).
2.11 Stripe coating is painting of edges, welds, hard to reach areas, etc., to ensure
good paint adhesion and proper paint thickness in critical areas.
1
This Standard applies only to dedicated seawater ballast tanks in all types of ships and double-side
skin spaces in bulk carriers which are constructed of steel.
3 GENERAL PRINCIPLES
3.1 The ability of the coating system to reach its target useful life depends on the
type of coating system, steel preparation, application and coating inspection and
maintenance. All these aspects contribute to the good performance of the coating
system.
3.2 Inspection of surface preparation and coating processes shall be agreed upon
between the shipowner, the shipyard and the coating manufacturer and presented to
the Administration for review. The Administration or recognized organization may, if
it so requires, participate in the agreement process. Clear evidence of these
inspections shall be reported and be included in the Coating Technical File (CTF) (see
paragraph 3.4).
The “official” inspector is to be properly NACE or FROSIO certified and is to be chosen

by agreement between shipyard, owner, paint maker and the Flag Administration (or its
Recognized Organization i.e. class) if the Flag so wishes. It is envisaged that soon
many inspectors/companies located close to shipyards will be set up and thus more
likely to be preferred by shipyards. Painting is very expensive and labor intensive for
shipyards and the paint shop is the usual bottle neck of most shipyards, delaying all
ships under production. Thus the pressures for coating inspectors not to be overly
strict may be quite strong in some cases. It is hoped that such local inspectors will
remain impartial and enforce this SOLAS regulation professionally. However, it is also
envisaged that expatriate companies or individuals may also be certificated by Flag
Administrations in which case they may be the preferred choice of owners. By not
being permanently located in the same city/country as the shipyard, they may be
perceived as more impartial. Finally, the paint maker, who is the undisputed expert on
his paints and who traditionally has been acting as the umpire of any owner-yard
disputes, may be the appropriate choice to provide the PSPC inspector, at least for the
first period of application of this new regulation.
However, it must be stressed that irrespective of who is chosen to be the PSPC

inspector, the duties of the owner’s paint inspector, the paint maker’s inspector and
8
the shipyard paint quality control inspectors remain the same. The PSPC inspector’s
duties cover only the areas (ballast tanks) and issues of the regulation. Proper
painting of a ship covers many more practical items and details inside the ballast tanks
and, of course, all other ship areas apart from the ballast tanks. Also any possible
owner upgrades to the coating will not be the concern of the PSPC inspector.
It is therefore, recommended that owner inspectors are well informed about the new
standard and its technical references, so they can independently verify the proper
application of the PSPC. And they must not give up any existing rights under the
typical owner/yard contract. For example, just because the PSPC inspector checked
and approved the DFT in a tank does not mean that the Owner inspector cannot and
should not do the same. From their part, the shipyard’s and paint maker’s liability has
increased. The standard, under normal operating and maintenance conditions (more
on this later under 3.4.3) calls for the paint to remain in “good” condition for 15 years.
It is certainly not to the yard’s or maker’s interest to have the paints fail after say 5 or 8
years. Thus it is hoped that the yard’s and maker’s inspectors will also endeavor to
strictly apply the standard properly.
3.3 When considering the Standard provided in section 4, the following is to be

taken into account:
.1 it is essential that specifications, procedures and the various different steps in

the coating application process (including, but not limited to, surface preparation) are
strictly applied by the shipbuilder in order to prevent premature decay and/or
deterioration of the coating system;
.2 the coating performance can be improved by adopting measures at the ship

design stage such as reducing scallops, using rolled profiles, avoiding complex
geometric configurations and ensuring that the structural configuration permits easy
access for tools and to facilitate cleaning, drainage and drying of the space to be
coated; and
.3 the coating performance standard provided in this document is based on

experience from manufacturers, shipyards and ship operators; it is not intended to
exclude suitable alternative coating systems, providing a performance at least
equivalent to that specified in this Standard is demonstrated. Acceptance criteria for
alternative systems are provided in section 8.
3.4 Coating Technical File
3.4.1 Specification of the coating system applied to the dedicated seawater ballast
tanks and double-side skin spaces, record of the shipyard’s and shipowner’s coating
work, detailed criteria for coating selection, job specifications, inspection,
maintenance and repair 2 shall be documented in the Coating Technical File (CTF),
and the Coating Technical File shall be reviewed by the Administration.
2
Guidelines to be developed by the Organization.
It is important that the Coating Technical File (CTF) contains a detailed and accurate
report of the whole coating process. In case of premature coating failure, the CTF will
be the best guide to provide indications of what went wrong. Note that the list under
3.4.2 is a minimum recommended list of items. Of particular usefulness for possible
future coating failures will be the recording of failed inspections and any major
9
shipyard repairs to the coating (along with proper identification of location, block / sub-
lock number etc.)
3.4.2 New construction stage
The Coating Technical File shall contain at least the following items relating to this
Standard and shall be delivered by the shipyard at new ship construction stage:
.1 copy of Statement of Compliance or Type Approval Certificate;
This in practice will be provided by the Recognized Organizations (classification

Society) of the Flag Administration.
.2 copy of Technical Data Sheet, including:
(Ensure shop primer data is also included for all the below requirements)
-product name and identification mark and/or number;

-materials, components and composition of the coating system, colours;
-minimum and maximum dry film thickness;
-application methods, tools and/or machines;
-condition of surface to be coated (de-rusting grade, cleanness, profile, etc.);
and
-environmental limitations (temperature and humidity);
.3 shipyard work records of coating application, including:

(Ensure primary surface preparation and inspections and shop primer application and
its inspections are included – whether performed at yard premises or not.
Documentation of these must be signed / verified by PSPC inspector).
-applied actual space and area (in square metres) of each compartment;
-applied coating system;
-time of coating, thickness, number of layers, etc.;
-ambient condition during coating; and
-method of surface preparation;
.4 procedures for inspection and repair of coating system during ship

construction;
.5 coating log issued by the coating inspector – stating that the coating was
applied in accordance with the specifications to the satisfaction of the coating supplier
representative and specifying deviations from the specifications (example of daily log
and non-conformity report, see annex 2);
(Ensure that all stages of primary surface preparation inspections –before and after
blasting / before and after shop primer application- are included.)
(Ensure that all defects/rejections/non-conformances and coating repairs are
recorded).
10
.6 shipyard’s verified inspection report, including:
-completion date of inspection;
-result of inspection;-remarks (if given); and
-inspector signature; and
.7 procedures for in-service maintenance and repair of coating system 2.

Note important comments below regarding .7
3.4.3 In-service maintenance, repair and partial re-coating
In-service maintenance, repair and partial re-coating activities shall be recorded in the
Coating Technical File in accordance with the relevant section of the Guidelines for
coating maintenance and repair. 2
2
Guidelines to be developed by the Organization.
3.4.2.7 and 3.4.3

IMO will develop recommended guidelines for maintenance and repair of the ballast
coating system. It is hoped that these will be practical and not based on the current
unrealistic version of IACS recommendation 87 (which calls for sandblasting, fresh
water washing, use of dehumidifiers etc while the ship is trading, – while its references
to riding repair teams are practically outdated due to STCW requirements and minimal
accommodations and safety equipment capacities of standard design ships.)
A crucial question to the future credibility of the standard will be the extent of linkage
of such maintenance and repair to the target life. Obviously, if each time a defect
develops the owner/operator is required to repair it, the coating will always remain in
better than “good” condition. Based on today’s practical experience a coating applied
properly in accordance with the standard would have no problem remaining within the
“good” definition condition for 15 years (provided the shop primer is substantially
removed). Therefore, imposing maintenance / repair requirements (other than for
mechanical damages) before the 15 year period will practically invalidate the standard.
Until the IMO guidelines are finalized, owners should be alert so that
3.4.2 item .7 above is not used as a maintenance requirement or a
requirement to repair possible coating damages. That would effectively
shift the responsibility to provide a 15 year coating system in “good”
condition from the paint maker and the shipyard to the owner. Item .7 is
clear that the procedures only on how to effect proper maintenance and
repairs to the coating system should be included (i.e. what are the
surface cleanliness requirements, proper environment conditions, tools
to use, etc.). The requirement of .7 is for the paint maker to advise “how
to” repair if or when the owner decides to do maintenance and repairs. It
is not to impose or instruct “when” or “how often” the maintenance and
repair is to be done.
3.4.4 Re-coating
If full re-coating is carried out, the items specified in paragraph 3.4.2 shall be
11
recorded in the Coating Technical File.
3.4.5 The Coating Technical File shall be kept on board and maintained throughout
the life of the ship.
3.5 Health and safety
The shipyard is responsible for implementation of national regulations to ensure the

health and safety of individuals and to minimize the risk of fire and explosion.
4 COATING STANDARD
4.1 Performance standard
This Standard is based on specifications and requirements which intend to provide a

target useful coating life of 15 years, which is considered to be the time period, from
initial application, over which the coating system is intended to remain in “GOOD”
condition. The actual useful life will vary, depending on numerous variables including
actual conditions encountered in service.
It should be noted the definition of “GOOD” condition is different for SOLAS and for
IACS, IACS’ being quite more specific.
The SOLAS definition of GOOD (resolution A.744(18)) is “condition with only minor
spot rusting”.
The IACS definition of GOOD is: “Condition with spot rusting on less than 3% of the
area under consideration without visible failure of the coating. Rusting at edges or
welds, must be on less than 20% of edges or welds in the area under consideration.”
The IACS definition is valid until the SOLAS regulation comes into force after July
2008. It is hoped that by that time the IACS definition is also adopted for SOLAS since,
being appropriate and more specific, is easier to apply for regulation purposes.
4.2 Standard application
Protective coatings for dedicated seawater ballast tanks of all ship types and double-
side skin spaces arranged in bulk carriers of 150 m in length and upward (for IACS
bulk carriers CSR > 90m) shall at least comply with the requirements in this Standard.
4.3 Special application
4.3.1 This Standard covers protective coating requirements for the ship steel structure.
It is noted that other independent items are fitted within the tanks to which coatings
are applied to provide protection against corrosion.
4.3.2 It is recommended that this Standard is applied, to the extent possible, to those
portions of permanent means of access provided for inspection not integral to the ship
structure, such as rails, independent platforms, ladders, etc. Other equivalent methods
of providing corrosion protection for the non-integral items may also be used,
provided they do not impair the performance of the coatings of the surrounding
structure. Access arrangements that are integral to the ship structure, such as increased
stiffener depths for walkways, stringers, etc., are to fully comply with this Standard.
12
With regard to application of the standard to Permanent Means of Access, I should
note that the IMO experts’ intention was firmer than the final wording may indicate
above. However, realizing that, in exceptional cases, full application to non-integral to
the ship structure parts may not be possible, a recommendation (instead of
requirement) was inserted. However the emphasis still is on “to the extent possible”.
Therefore, if it is possible that ladders, platforms etc can be prepared and coated as
per this PSPC, they should. Galvanized or other substitutes should not be acceptable
if there is no valid technical reason for their use.
4.3.3 It is also recommended that supports for piping, measuring devices, etc., be
coated in accordance with the non-integral items indicated in paragraph 4.3.2.
4.4 Basic coating requirements
4.4.1 The requirements for protective coating systems to be applied at ship

construction for dedicated seawater ballast tanks of all ship types and double-side skin
spaces arranged in bulk carriers of 150 m in length and upward meeting the
performance standard specified in paragraph 4.1 are listed in table 1.
4.4.2 Coating manufacturers shall provide a specification of the protective coating

system to satisfy the requirements of table 1. (Note that this includes the shop primer
if it is not totally removed at secondary surface preparation)
4.4.3 The Administration shall verify the Technical Data Sheet and Statement of
Compliance or Type Approval Certificate for the protective coating system.
4.4.4 The shipyard shall apply the protective coating in accordance with the verified
Technical Data Sheet and its own verified application procedures.
4.4.5 Standards referred to in footnotes in table 1 and Annex 1 to this standard are
those acceptable by the Organization. Other standards may be accepted by the
Administration if not inferior to the referenced standards.
13
TABLE 1
FOR EASY REFERENCE, COMMENTS (IN BOLD ITALIC – GRAY

BACKGROUND) ARE INSERTED AFTER RELEVANT PARAGRAPHS
WITHIN THE TABLE. EMPHASES IN THE ORIGINAL IMO TEXT, BY
BOLD OR UNDERLINE, IS OURS.
Table 1 – Basic coating system requirements for dedicated seawater ballast tanks
of all type of ships and double-side skin spaces of bulk carriers of 150 m and
upwards
Characteristic/
Reference Requirement
Standards
1 Design of coating system
.1 Selection of the The selection of the coating system should be considered by the parties
coating system involved with respect to the service conditions and planned maintenance.
The following aspects, among other things should be considered:
.1 location of space relative to heated surfaces;

.2 frequency of ballasting and deballasting operations;
.3 required surface conditions;
.4 required surface cleanliness and dryness;
.5 supplementary cathodic protections, if any (where coating is
supplemented by cathodic protection, the coating should be compatible with
the cathodic protection system).
Coating manufacturers shall have products with documented satisfactory

performance records and technical data sheets. The manufacturers should
also be capable of rendering adequate technical assistance. Performance
records, technical data sheet and technical assistance (if given) shall be
recorded in the Coating Technical File.
In IMO terminology “shall” is an absolute requirement (as opposed to

“should” which may denote either a requirement or just a
recommendation). It is important that, apart from class, the owner
requires to review such documented performance records (especially
for new or alternate type coatings) and be satisfied that the submitted
performance records can adequately predict the future satisfactory
performance of the product. The regulation requires that these per-
formance records must be included in the Coating Technical File (CTF).
In order not to hamper innovation, the standard allows alternative/
equivalent systems and schemes but not always on very strict testing
criteria. Thus, we cannot overstress the importance of CTF for the
owner. In a way it is the owner’s best insurance policy. One result of
this regulation is the proper distribution of responsibility among the
parties involved. If all parties are aware that all relevant inspection/
testing/ performance records are kept in a folder for the life of the ship,
this is obviously a big incentive for extra diligence and
professionalism. All the owner needs to do is ensure the regulation is
followed and all relevant information and documentation is included in
the CTF for possible future reference.
Coatings for application underneath sun-heated decks or on bulkheads

forming boundaries of heated spaces shall be able to withstand repeated
heating and/or cooling without becoming brittle.
14
For existing/proven systems this may be said to be complied. For new/
alternative systems the flexibility test of Annex 1 is insufficient. For
this reason the group of experts reported “The group noted the need
for a flexibility test and invited the Committee to encourage industry to
develop a suitable test” (Report of the group of experts, MSC 81/WP.13
Paragraph 21). Such test to confirm the ability of a system to stay
flexible as it ages during repeated flexing of the substrate plate (as it
actually occurs in ships) should be developed and incorporated in the
testing requirements of Annex 1.
.2 Coating type Epoxy based systems.
Other coating systems with performance according to the test procedure in

annex 1. Unfortunately the tests of Annex 1 alone cannot confirm
satisfactory future performance. The paint makers being aware of this
will have to use their own technology and testing to ensure the
equivalent performance of alternate coating systems. (See subsequent
comments with regard to Annex 1 – page26).
A multi-coat system with each coat of contrasting colour is recommended.
The top coat shall be of a light colour in order to facilitate in-service

inspection.
.3 Coating pre- Epoxy based systems tested prior to the date of entry into force of this
qualification test Standard in a laboratory by a method corresponding to the test procedure in
annex 1 or equivalent, which as a minimum meets the requirements for
rusting and blistering;
Note that this paragraph seriously relaxes the testing requirements for
systems tested before July 2008. As advised even the full testing
requirements of Annex 1 are insufficient to guarantee good
performance for the target life. Therefore owners are urged to require
that the full testing procedures/results/ documentation, based on
which the system used on their ship was approved, are fully included
in the CTF. This way, in case of premature coating failure there will be
a proper record to re-examine.
or which have documented field exposure for 5 years with a final coating
condition of not less than “GOOD” may be accepted. This is another
somewhat relaxed requirement (5 years instead of 10 or 15) however it
is not unreasonable if the following recommendations are followed:
a) The documentation should involve several ships, both oil tankers

and bulk carriers, built in different shipyards of different countries.
b) all ballast tanks should be inspected.
c) the whole system under which the coating was applied (surface
preparation, number of coats, DFT etc) should be similar or inferior to
this standard (this requires that good building records are available).
For example the field cases should not involve ships of extra high
coating specification, or for which e.g. all shop primer was blasted at
block stage (secondary preparation). On the contrary, the 5 year field
exposure is particularly used to allow retention of the shop primer (see
3.2). Thus the documentation must clearly show that the primer was
actually retained.
d) Pull off tests should be performed to test the adhesion of shop
primer with main coats. The possible degradation of shop primer to be
closely examined.
e) The majority of ships in the sample should exhibit 5 year coating
condition well below the maximum limit of the “good” definition.
15
In that respect, the IACS current Procedural Requirement 34, to inspect
only visually the surface coating condition of only one vessel, is
considered totally insufficient.
For all other systems, testing according to the procedure in annex 1, or
equivalent, is required. See subsequent comments with regard to Annex
1 (page 26).
.4 Job specification There shall be a minimum of two stripe coats and two spray coats, except
that the second stripe coat, by way of welded seams only, may be reduced in
scope where it is proven that the NDFT can be met by the coats applied in
order to avoid unnecessary over thickness. Any reduction in scope of the
second stripe coat shall be fully detailed in the CTF.
It is perhaps an oversight that the recommended thickness of each
spray coat is not mentioned. As per standard good practice, the two
spray coats should be of approximately same DFT with a maximum
deviation of, say, 10% (i.e. about 160 µm each coat on average – min -
max. thickness range 145 – 175 µm ). The reason for the two coats is
that one covers the pinholes/pores of the other. Obviously this cannot
be achieved if one coat is too thin and the other too thick.
With regard to the proper sequence of main coat or stripe coat to be

applied first, opinions differ. In the experience of the author, it is much
preferable, after secondary surface preparation, to apply a full coat
first thus reducing the possibility for the plate to “turn” (i.e. develop
flush rust) or be contaminated. This results in the second stripe coat
being applied last which, being recommended to be of different shade
than the final main coat, may not be cosmetically pleasing. However,
longevity of coating should be the primary consideration.
Second stripe coat reduction: Owners may be due partial credit if the
second stripe coat is extensively reduced on welds.
Stripe coats shall be applied by brush or roller. Roller to be used for

scallops, ratholes, etc., only. Although clear enough, the use of roller was
verbally reconfirmed during MSC 82 (informal drafting group under
Chairmanship of Germany) to be applicable only for “holes”. Rollers
are not to be used for free edges and welds.
Each main coating layer shall be appropriately cured before application of

the next coat, in accordance with coating manufacturer’s recommendations.
Similarly expired over coating intervals should be checked.
Surface contaminants such as rust, grease, dust, salt, oil, etc. shall be
removed prior to painting with proper method according to the paint
manufacturer’s recommendation. Abrasive inclusions embedded in the
coating shall be removed. Job specifications shall include the dry-to-recoat
times and walk-on time given by the manufacturer. The underlined
sentence in bold above was specially inserted at MSC 81 “to clarify the
requirements for surface preparation between coats” (Report of the
group of experts MSC 81/WP.13, paragraph 10).
WITH REGARD TO CLEANLINESS BETWEEN COATS:

Note that there is no mention regarding the limits of cleanliness
between coats (e.g. salt < 50 mg/m2, dust limits etc). The reason is
that the ISO reference standards of table 1(e.g. reference 6 - cleanliness
testing) were developed for contaminants on the steel substrate before
paint application. However, for salt, the same ISO patch test can be
perfectly used on paint, provided the coating is cured/totally dry. The
salt limit between coats should actually be stricter than the 50 mg/m2
with most experts recommending less than 30 mg/m2. The maker
should be consulted for his specification on the salt limit but, since the
16
rule requires removal of salt, in no case it should be more than 50
mg/m2.
For the other contaminants apart from salt (rust, dust, grease, oil, etc.)
the same major criterion as for secondary preparation is applicable.
That is IF IT IS VISIBLE TO THE EYE, IT MUST BE REMOVED. To what
limit? So that it is not visible any more.
IMPORTANT POINT: Note also that it is not the “removal or not” that is
subject to (or according to) the paint manufacturer’s recommendation.
It is only the method of removal that is according to the paint
manufacturer’s recommendation. Thus removal of the contaminants
between coats is required and the paint manufacturer will suggest the
proper method to remove them.
It is worth mentioning that another usual inter-coat failure is due to

amine bloom which develops when the blocks are moved from the
heated painting sheds to cold outside air before the coating is dry or
cured. Amine bloom also develops when summer type coatings are
used in cold weather. Repair in such case is by total block reblasting.
(Source: Ref.4).
The standard requires that the top coat is of light color and
recommends contrasting color for each coat layer (Table 1, 1.2). If this
recommendation is followed, meaning that the first coat will be dark,
some contaminants may be more easily visible. Otherwise, other
methods should be followed to ensure the surface is clean from dust
etc (such as running a white gloved hand over the surface or a clean
white cloth and examining the glove or cloth for dirt).
The vast majority of early coating failures in practice (70%) occur from
peeling of the second coat from the first. Thus cleanliness of surface
before second coat application is of extreme importance and so is the
thorough inspection of the surface before second coat. This
inspection is now required as part of this regulation (Paragraphs 6.1.2
second sentence and 6.2 Block assembly item 4).
.5 NDFT (nominal total NDFT 320 µm with 90/10 rule for epoxy based coatings, other systems to
dry film thickness)3 coating manufacturer’s specifications.
Attention should be Maximum total dry film thickness according to manufacturer’s detailed
paid here in using specifications.
only the proper
magnetic gauges Care shall be taken to avoid increasing the thickness in an exaggerated way.
and calibration of Wet film thickness shall be regularly checked during application.
the reference Note that over thickness (instead of insufficient DFT) has become a
standard. common problem with recent shipyard practices of using large spray
nozzles for faster coverage, and it is much more difficult to repair. Over
thickness will result in cracking of paint. Owners are urged to obtain
the paint manufacturer’s maximum allowed thickness (required to be
included in CTF) and ensure this is not exceeded in any area of the
coating.
Thinner shall be limited to those types and quantities recommended by the

manufacturer.
3
Type of gauge and calibration in accordance with SSPC-PA2: 2004. Paint Application Specification No.2.
17
2 PSP (Primary Surface Preparation)
.1 Blasting and Sa 2½; with profiles between 30-75 µm

Profile. 4, 5 There was extensive consideration by MSC 81 to include here the initial
steel condition (A, B, C or D) before primary surface preparation. Only
steel condition A or B should be acceptable for ship construction and
especially for ballast tank areas. As per standard good practice
conditions C and especially D are not acceptable as shipbuilding steel
(see also Appendix). Finally it was considered that the specification of
profile 30-75 µm automatically excludes steel plates with original
condition C or D, since on these plates the pittings, after the rust scale
is removed, are so deep and extensive that a profile of 30-75 is
meaningless (i.e. the peaks and valleys -peak to peak- are higher/
deeper than 75 µm).
Under paragraphs 6.1.2 (second sentence) and 6.2(primary surface

preparation), inspections before and after blasting as well as after
primer application are required.
With regard to profile, a fast check for owner’s inspector may be by

using the ISO comparator disk for Medium (S-shotblast) or Medium (G-
gridblast) profiles. Provided the steel initial condition was A or B they
should indicate profiles very similar to the standard’s. Even better
some ISO comparator disks indicate clearly what the profile is.
Blasting shall not be carried out when:

.1 the relative humidity is above 85%; or
.2 the surface temperature of steel is less than 3°C above the dew point.
Checking of the steel surface cleanliness and roughness profile shall be

carried out at the end of the surface preparation and before the application of
the primer, in accordance with the manufacturer’s recommendations.
Note that the incoming plate before blasting should be relatively clean.
Oil, grease and excessive salt contamination on the incoming plates
should be removed first to the extent possible before blasting (since
blasting will push these contaminants into the steel pores and profile).
Oil and grease is removed by appropriate thinners. Salt is removed by
fresh water washing (the 50 mg/m2 limit is not valid for this pre-
blasting stage; it is valid for after blasting and before shop primer
application).
Blasting grit is recycled and absorbs contaminants. The grit should be

tested for salt and contaminants too.
Note that the manufacturer must specify the min-max DFT thickness of
the primer and this must be measured after application. Overthickness
of shop primer is particularly detrimental since it results in mechanical
weakness and disbonding, leading to total system failure.
Note that in some cases the steel plates arrive at the yard already shop
primed from the steel plant or paint subcontractors. In such cases
such shop primer must be totally removed to Sa 2 ½ unless all
requirements of the standard have been complied with, such as
inspection requirements of section 6.2, cleanliness/compatibility/
maximum thickness requirements along with all proper documentation
of such tests and inspections by the PSPC inspector. If the shop primer
remains, it will be the foundation of the system. Thus utmost care is
required that this first preparation stage is done properly. If the owner’s
inspectors cannot attend such primary surface preparation at the steel
plant or subcontractor, they should obtain the detailed inspection
reports of the PSPC inspector and subsequently perform regular spot
18
checks at the shipyard, by removing the shop primer from test areas to
check the profiles and any contaminant presence etc.
.2 ≤ 50 mg/m2 of sodium chloride.
It is very important that the surface is salt free below the reference limit
just prior to shop primer application. Inspectors should familiarize
Water soluble salt themselves with the referenced ISO test. Excessive salt contamination
limit equivalent to may require fresh water washing. Blasting grit is recycled and absorbs
NaCl 6 contaminants. The grit should be tested for salt and contaminants too.
.3 Shop primer Zinc containing inhibitor free zinc silicate based or equivalent.
Note that epoxy type or epoxy based shop primers are not acceptable
unless the procedure of section 3.2 is followed in which case the epoxy
primer can be used only with the particular epoxy type system of the
main coats. Even then, epoxy based shop primers should be avoided
when possible. Since they are hard to remove they tend to hide defects
and contaminants of the substrate steel. (Note that irrespective of
primer condition-damaged or good- all welds must be totally primer
free to Sa 2 ½ - see par. 3.2). In addition, a major problem with epoxy
primers is that they interfere with the good penetration of the weld.
While the surface of the weld may look good, void areas underneath
are common (egg shell effect). If a shipyard or paint maker insists on
using epoxy based primer, owners are urged to ensure all procedures
of the standard are followed with regard to primary surface
requirements and complete documentation with all tests/inspections is
included in the Coating Technical File. In addition, a good program of
checking of the welds by the hull inspectors (by use of pointed
hammer) should be established.
Compatibility with main coating system shall be confirmed by the coating

manufacturer.
Note that the statement of compatibility must be provided by the main
coating system manufacturer (not by the shop primer manufacturers
who in many cases are small local outfits). The statement must be
specific confirming the compatibility of the specific shop primer used
to the specific subsequent epoxy coating. General or generic
statements should not be acceptable. Furthermore, the compatibility
should be confirmed by the main system manufacturer to be applicable
for the target / design life of the system (of 15 years). Since most shop
primers degrade fast, a compatibility confirmation applicable only for
the start of the coating system’s life has little or no value (see also
comments under section 3.2 of Table 1). It is important to include this
statement in the Coating Technical File.
3 Secondary surface preparation
.1 Steel condition7 The steel surface shall be prepared so that the coating selected can achieve
an even distribution at the required NDFT and have an adequate adhesion by
removing sharp edges, grinding weld beads and removing weld spatter and
any other surface contaminant. Note that plates with initial condition C or
D cannot achieve the above requirement (of even distribution and
adequate adhesion).
Edges to be treated to a rounded radius of minimum 2 mm, or subjected to

three pass grinding or at least equivalent process before painting. The “at
least equivalent process” refers to automatic round cutting tools used
by some advanced yards.
4
Reference standard: ISO 8501-1: 1988/Suppl: 1994. Preparation of steel substrate before application
of paints and related products – Visual assessment of surface cleanliness.
19
5
Reference standard: ISO 8503-1/2: 1988. Preparation of steel substrate before application of paints
and related products – Surface roughness characteristics of blast-cleaned steel substrates.
6
Conductivity measured in accordance with ISO 8502-9: 1998. Preparation of steel substrate before
application of paints and related products – Test for the assessment of surface cleanliness.
7
Reference standard: ISO 8501-3: 2001 (grade P2). Preparation of steel substrate before application of
paints and related products – Visual assessment of surface cleanliness.
General Comment:
Owner superintendents are urged to obtain copies and familiarize themselves with the
referenced ISO and SSPC standards, which, where appropriate, they include the
approved testing methods for contaminants.
.2 Surface treatment4 Sa 2½ on damaged shop primer and welds.

Perhaps the word “damaged” was intentionally not included in the
definitions of this standard so that it may have as broad a meaning as
possible. Rusted, burned, scratched, soft, but also heated (not only
burned) and degraded primer is damaged primer. Heating the primer
causes zinc evaporation and thus reduced protection. Primer
discoloured by welding fumes and with white rust is also damaged
primer.
IMO debated whether all shop primer (not only the damaged) should be
removed. And for good reason. As per prior studies, retaining the
primer may be acceptable for 5 or even 10 year systems but not for 15
year systems. For example, DnV guidelines for 15 ± 3 years
specification state “preferably, all shop primer [should be] blasted off
until fresh Sa 2.5 surface is obtained on all surface areas”. However,
such a requirement was finally considered too strict.
Shop primers are intended to temporarily protect the plate after

primary surface preparation for 1 - 2 months until secondary surface
preparation is effected. Zinc silicate primers degrade whereas epoxy
primers have worse safety problems (as stated under 2.3). Thus to date
shop primers are not the appropriate foundation for long life coating
systems. And there is no guarantee that the testing requirements of
Annex 1 will prove sufficient. In fact most, if not all, shop primers used
today can easily pass the prequalification test of Annex 1 irrespective
of their quality (Ref.4). Thus it is doubtful that a system can reach a 15
year life in good condition with today’s shop primer quality.
Under the circumstances, since the intact primer may remain as a

foundation, proper primary surface preparation becomes a critical step.
- Inspections and testing before and after blasting and before and after
shop primer application are required with all relevant documentation
included in the CTF, and,
- Subsequently, at secondary surface preparation, it must be ensured
that only clean, solid, good primer is retained. If the primer, for
example, scratches easily by fingernail then it is degraded or bad
quality primer and must be removed. It certainly cannot be a solid
foundation of a 15 year system, and
- The coating system manufacturer’s compatibility statement must
make explicit mention to the regulation’s target / design life of 15 years
for the coating system. (Thus, if the maker is indeed willing to back up
its claim that it is o.k. to leave the primer, that should be acceptable to
the owner. If the maker does not provide such explicit compatibility
confirmation then obviously he is not certain that the primer is up to
the job and the owner should not accept the primer to be retained).
Sa 2 removing at least 70% of intact shop primer, which has not passed a
pre-qualification certified by test procedures in 1.3.
Primers not having passed the tests of Annex 1 or the 5 year field test
and/or not confirmed compatible by the main coating system
20
manufacturer etc., must be removed by at least 70%. Note that 70%
removal means by volume (depth) of primer, not by area of plate. All
square meters of the surface must be blasted. Thus when finished the
plate must be free of primer everywhere with only a light sheen of
primer remaining visible (i.e. a see-through, not opaque, layer of primer
remaining -say less than 10µm DFT- producing a just visible
discoloration).
If the complete coating system comprising epoxy based main coating and
shop primer has passed a pre-qualification certified by test procedures in 1.3,
intact shop primer may be retained provided the same epoxy coating system
is used. The retained shop primer shall be cleaned by sweep blasting,
high pressure water washing or equivalent method.
Note comments on epoxy based shop primers under paragraph 2.3 of
Table 1. The sentence in bold above applies to all types of retained
primers (zinc silicate and epoxy). Of the stated cleaning methods
sweep blasting is by far preferable. If high pressure washing is used
the pressure should be at least 340 bar (5,000 PSI). SSPC (the Society
for Protective Coatings) defines low pressure washing as below 5000
PSI and high pressure washing as 5,000 – 10,000 PSI (340-680 bar).
If a zinc silicate shop primer has passed the pre-qualification test of 1.3 as
part of an epoxy coating system, it may be used in combination with other
epoxy coatings certified under 1.3, provided that the compatibility has been
confirmed by the manufacturer by the test in accordance with paragraph 1.7
of appendix 1 to annex 1 without wave movement.
This paragraph virtually allows any zinc silicate shop primer to be used
with any subsequent epoxy coat system with a test that, in the opinion
of the author, is not sufficient to confirm compatibility. For example a
primer may test well with a surface tolerant type epoxy but this cannot
mean that this primer can be used with other not so tolerant epoxy
systems.
Ultimately it is the main coating system manufacturer who assumes the

responsibility to confirm the compatibility of the primer to the main
coats for the design life of the system, so owners are again urged to
ensure that such a statement is included by the main coating system
maker in the CTF. With the assumption of such responsibility and the
prospect of coat failure before the 15 years due to the primer, it is
hoped that paint makers will be deterred from issuing “iffy” compati-
bility statements en-mass. Paint manufacturers are well aware of the
insufficiency of the tests of Annex 1 (see comments page 26). Logically
it is to the maker’s benefit to avoid gamble, resist shipyard pressures
and require the Sa 2, 70% intact primer removal option for all today’s
primers. The past notion that the paint maker’s responsibility extends
only to the one or two years guarantee period is certainly revised with
this new regulation.
.3 Surface treatment Butts St 3 or better or Sa 2½ where practicable. Small damages up to 2% of

after erection4 total area: St 3. Contiguous damages over 25 m2 or over 2% of the total area
of the tank, Sa 2½ should be applied.
The best results are by vacuum blast machines. Although blasting is
preferable, unless done by vacuum nozzle, blasting sand may spread
everywhere in the tank possibly clogging pipe suction bells, vents and
scallops. Good cleaning is required in such cases which depending on
method used (manual labour or vacuum) may produce more damages
to the coating. On the other hand St 3 may not always result in proper
profile for good paint adhesion. Owners should weigh the above
advantages and disadvantages of the two methods. Erection seams are
some of the most defect prone areas being revealed during the trading
of the ship.
21
Coating in overlap to be feathered.
.4 Profile In case of full or partial blasting 30-75 µm, otherwise as recommended by

requirements5 the coating manufacturer.
Regarding profile, see comments under paragraph 2.1 of Table 1.
.5 Dust 8 Dust quantity rating “1” for dust size class “3”, “4” or “5”. Lower dust size
classes to be removed if visible on the surface to be coated without
magnification.
Dust sizes 3, 4, 5 are large sizes (specs) of dust visible to the naked
eye. Spec sizes 1 and 2 are not normally visible unless they are
present in large quantities. In such case they must be removed to
quantity rating 1 (which is quite below visible by naked eye).
Note that the rule is: IF IT IS VISIBLE, IT MUST BE REMOVED. Dust may
be hard to see on a metal surface. If in doubt, rubbing a white glove /
cloth on the surface for about 30 - 40 cm and examining it for dirt may
help (obviously running a white cloth on the surface for many meters
may well pick up visible dust on the cloth; but it is not the intention of
the regulation that such dust should be removed. Some dust in such
small quantities will not effect proper bonding of coating and will not
be detrimental to the coating).
.6 Water soluble salts ≤ 50 mg/m2 of sodium chloride.

limit equivalent to
NaCl after blasting/ See comment under paragraph 2.2 of Table 1.
grinding6
No oil contamination.
As also stated under 2.1, it is preferable that visible oil and grease is
first removed to the extent possible before blasting. Note that the
standard requires removal of all oil –not only the visible one. A simple
test for oil is the water-break test (checking if water is beading on the
surface which indicates presence of oil and grease).
.7 Oil contamination
4 Miscellaneous
.1 Ventilation Adequate ventilation is necessary for the proper drying and curing of
coating. Ventilation should be maintained throughout the application process
and for a period after application is completed, as recommended by the
coating manufacturer.
A crucial step to be adhered to. Its misapplication has been identified

as the cause of many subsequent coating failures (e.g. when yard
workers leave for the day and they turn the power off all operating
equipment – including ventilators or dehumidifiers).
But careful: Ventilation may carry dust, grit, salt and other
contaminants onto wet paint. (source: Ref.4)
8
Reference standard: ISO 8502-3:1993. Preparation of steel substrate before application of paints and
related products – Test for the assessment of surface cleanliness.
.2 Environmental Coating shall be applied under controlled humidity and surface conditions, in
conditions accordance with the manufacturer’s specifications. In addition, coating shall
not be applied when:
.1 the relative humidity is above 85%; or
.2 the surface temperature is less than 3°C above the dew point.
22
Another important requirement. Its non-adherence has been identified
as the cause of many system failures.
.3 Testing of coating3 Destructive testing should be avoided.
Dry film thickness shall be measured after each coat for quality control
purpose and the total dry film thickness shall be confirmed after completion
of final coat, using appropriate thickness gauges (see annex 3).
It is important that the first main coat is checked for total and uniform
coverage (145-175 mm DFT). Also, extensive DFT testing is required
after the first stripe coat to determine possible DFT overthickness areas
on welds (so that the second stripe coat is waved). Note that the
regulation states that DFT should be measured after each coat (not just
after each main coat). That includes main coats and stripe coats (as
opposed to other sections of regulation, e.g. 1.2, where reference is only
to main coats.)
.4 Repair Any defective areas, e.g. pin-holes, bubbles, voids, etc. should be marked up
and appropriate repairs effected. All such repairs shall be re-checked and
documented.
Most long term coating breakdown initiates at pin holes associated with
free edges & occasionally along welds. Stress concentration makes this
effect much worse. Low voltage sponge pin hole detectors can be used
to detect non-visible pin holes. These pin holes are the most common
cause of coating breakdown in ballast tanks (source: Ref.4)
5 COATING SYSTEM APPROVAL
Results from prequalification tests (table 1, paragraph 1.3) of the coating system shall
be documented, and a Statement of Compliance or Type Approval Certificate shall be
issued if found satisfactory by a third party, independent of the coating manufacturer.
In practice this will be issued by IACS / class.
6 COATING INSPECTION REQUIREMENTS
6.1 General
6.1.1 To ensure compliance with this Standard, the following shall be carried out by
qualified coating inspectors certified to NACE Coating Inspector Level 2, FROSIO
Inspector Level III or equivalent as verified by the Administration.
6.1.2 Coating inspectors shall inspect surface preparation and coating application
during the coating process by carrying out, as a minimum, those inspection items
identified in section 6.2 to ensure compliance with this Standard. Emphasis shall be
placed on initiation of each stage of surface preparation and coatings application
as improper work is extremely difficult to correct later in the coating progress.
Note that the above sentence in bold includes primary surface preparation (before and
after blasting) and shop primer application. Also stripe coats applications (inspections
before and after).
Representative structural members shall be non-destructively examined for coating
thickness. The inspector shall verify that appropriate collective measures have been
23
carried out.
6.1.3 Results from the inspection shall be recorded by the inspector and shall be
included in the CTF (refer to annex 2, Example of Daily Log and Non-conformity
Report).
6.2 Inspection items
Construction Inspection items

stage
Primary surface 1 The surface temperature of steel, the relative humidity and the dew point shall be
preparation measured and recorded before the blasting process starts and at times of sudden
changes in weather.
Note to ensure steel plate condition A or B only (see 2.1 of Table 1). Oil,
grease and excessive salt to be removed, as much as possible, before
blasting.
2 The surface of steel plates shall be tested for soluble salt and checked for oil,
grease and other contamination.
Proper profile to be also checked (2.1 of Table 1).
3 The cleanliness of the steel surface shall be monitored in the shop primer
application process. Also regular checks are needed between the blasting
plant and the shop primer plant (source: Ref. 4)
4 The shop primer material shall be confirmed to meet the requirements of 2.3 of
table 1.
Ensure that the compatibility confirmation is by the main system maker and
makes reference to the system target life of 15 years.
Thickness If compatibility with the main coating system has been declared, then the
thickness and curing of the zinc silicate shop primer to be confirmed to conform to
the specified values.
Block assembly 1
After completing construction of the block and before secondary surface
preparation starts, a visual inspection for steel surface treatment including edge
treatment shall be carried out. Any oil, grease or other visible contamination to be
removed.
2
After blasting/grinding/cleaning and prior to coating, a visual inspection of the
prepared surface shall be carried out. On completion of blasting and cleaning and
prior to the application of the first coat of the system, the steel surface shall be
tested for levels of remaining soluble salts in at least one location per block.
3 The surface temperature, the relative humidity and the dew point shall be
monitored and recorded during the coating application and curing.
4 Inspection to be performed of the steps in the coating application process
mentioned in table 1.
5 DFT measurements shall be taken to prove that the coating has been applied to the
thickness as specified and outlined in annex 3.
Erection 1 Visual inspection for steel surface condition, surface preparation and verification
of conformance to other requirements in table 1, and the agreed specification to be
performed.
24
2 The surface temperature, the relative humidity and the dew point shall be
measured and recorded before coating starts and regularly during the coating
process.
3 Inspection to be performed of the steps in the coating application process
mentioned in table 1.
Note that the above are minimum inspection requirements (as stated in paragraph 6.1.2
of the regulation).
VERIFICATION REQUIREMENTS
The following shall be carried out by the Administration prior to reviewing the
Coating Technical File for the ship subject to this Standard:
.1 check that the Technical Data Sheet and Statement of Compliance or Type
Approval Certificate comply with this Standard;
.2 check that the coating identification on representative containers is consistent

with the coating identified in the Technical Data Sheet and Statement of Compliance
or Type Approval Certificate;
.3 check that the inspector is qualified in accordance with the qualification

standards in paragraph 6.1.1;
.4 check that the inspector’s reports of surface preparation and the coating’s
application indicate compliance with the manufacturer’s Technical Data Sheet and
Statement of Compliance or Type Approval Certificate; and
.5 monitor implementation of the coating inspection requirements.
8 ALTERNATIVE SYSTEMS
8.1 All systems that are not an epoxy based system applied according to table 1 of this
Standard are defined as an alternative system.
8.2 This Standard is based on recognized and commonly used coating systems. It is
not meant to exclude other, alternative, systems with proven equivalent performance,
for example non epoxy based systems.
8.3 Acceptance of alternative systems will be subject to documented evidence that

they ensure a corrosion prevention performance at least equivalent to that indicated in
this Standard.
8.4 As a minimum, the documented evidence shall consist of satisfactory performance

corresponding to that of a coating system which conforms to the Coating Standard
described in section 4, a target useful life of 15 years in either actual field exposure
for 5 years with final coating condition not less than “GOOD” or laboratory testing.
Laboratory test shall be conducted in accordance with the test procedure given in
annex 1 of this Standard. See prior comments under 1.3 of Table 1.
25
ANNEX 1
TEST PROCEDURES FOR COATING QUALIFICATIONFOR DEDICATED

SEAWATER BALLAST TANK OF ALL TYPES OF SHIPS ANDDOUBLE-
SIDE SKIN SPACES OF BULK CARRIERS COATING
1 Scope
These Procedures provide details of the test procedure referred to in paragraphs 5 and
8.3 of this Standard.
2 Definitions
Coating specification means the specification of coating systems which includes the
type of coating system, steel preparation, surface preparation, surface cleanliness,
environmental conditions, application procedure, acceptance criteria and inspection.
3 Testing
Coating specification shall be verified by the following tests. The test procedures shall
comply with appendix 1 (Test on simulated ballast tank conditions) and appendix 2
(Condensation chamber tests) to this annex as follows:
.1 For protective coatings for dedicated seawater ballast tanks, appendix 1 and
appendix 2 shall apply.
.2 For protective coatings for double-side spaces of bulk carriers of 150 m in

length and upwards other than dedicated seawater ballast tanks, appendix 2 shall
apply.
COMMENTS ON ANNEX 1
• The coating prequalification test is set out in Annex 1 Appendices 1 & 2.

• Appendix 1 is the “Marintek” wave tank test, which is used to test for corrosion
& osmotic blistering.
• Appendix 2 is a standard condensation chamber test, which is used to test for
cold wall blistering.
• The test was originally set up to assess the performance of soft coatings.
• The reason these tests were used is simply that they are the only
internationally accepted tests. But they were developed for different reasons
and are not the most appropriate tests for the purposes of this standard.
• Any reasonable epoxy coating will achieve B-1.
• This test does not rank coatings in terms of known service performance, i.e. the
short term test cannot predict the long term performance.
• The test in the Standard only gives confidence of non serious failure within the
traditional guarantee period of one or two years.
(Source: Reference 4: Theta Maritime S.A., Seminar on PSPC, Piraeus, June 29, 2006,
Eur. Ing. Peter D. Contraros, Dr. Les Callow, Dr Jane Lomas)
26
APPENDIX 1
TEST ON SIMULATED BALLAST TANK CONDITIONS
(Sections 1 and 2 omitted)
3 Acceptance criteria
3.1 The test results based on section 2 shall satisfy the following criteria:
Item Acceptance criteria for epoxy Acceptance criteria for

based systems applied according alternative systems
to Table 1 of this Standard
Blisters on panel No blisters No blisters
Rust on panel Ri 0 (0%) Ri 0 (0%)
Number of pinholes 0 0
Adhesive failure > 3.5 MPa Adhesive failure
between substrate and coating or > 5 MPa Adhesive failure between
between coats for 60% or more of substrate and coating or between
the areas. coats for 60% or more of the areas.
Cohesive failure > 3 MPa Cohesive failure in > 5 MPa Cohesive failure in
coating for 40% or more of the coating for 40% or more of the
area. area.
Cathodic protection current < 5 mA/m2 < 5 mA/m2
demand calculated from
weight loss
Cathodic protection; < 8 mm < 5 mm
disbondment from artificial
holiday
Undercutting from scribe < 8 mm < 5 mm
U-bar Any defects, cracking or Any defects, cracking or
detachment at the angle or weld detachment at the angle or weld
will lead to system being failed. will lead to system being failed.
3.2 Epoxy based systems tested prior to the date of entry into force of this Standard
shall satisfy only the criteria for blistering and rust in the table above. Note however
that all tests of section 2 must be performed and results must be reported (as required
by section 4 for all systems).
3.3 Epoxy based systems tested when applied according to table 1 of this Standard
shall satisfy the criteria for epoxy based systems as indicated in the table above.
3.4 Alternative systems not necessarily epoxy based and/or not necessarily applied
according to table 1 of this Standard shall satisfy the criteria for alternative systems as
indicated in the table above.
4 Test report
The test report shall include the following information:
.1 name of the manufacturer;
27
.2 date of tests;
.3 product name/identification of both paint and primer;
.4 batch number;
.5 data of surface preparation on steel panels, including the following:

-surface treatment;
-water soluble salts limit;
-dust; and
-abrasive inclusions;
.6 application data of coating system, including the following:

-shop primed;
-number of coats;
14
-recoat interval ;
14
-dry film thickness (DFT) prior to testing ;
14
-thinner ;
14
-humidity ;
14
-air temperature ; and
-steel temperature;
.7 test results according to section 2; and
.8 judgment according to section 3.
14
Both of actual specimen data and manufacturer’s requirement/recommendation.
APPENDIX 2
CONDENSATION CHAMBER TEST

(Sections 1 and 2 omitted)
3 Acceptance criteria
3.1 The test results based on section 2 shall satisfy the following criteria:
Item Acceptance criteria for epoxy Acceptance criteria for

based systems applied according alternative systems
to table 1 of this standard
Blisters on panel No blisters No blisters
Rust on panel Ri 0 (0%) Ri 0 (0%)
Number of pinholes 0 0
28
Adhesive failure > 3.5 MPa Adhesive failure
between substrate and coating or > 5 MPa Adhesive failure between
between coats for 60% or more of substrate and coating or between
the areas. coats for 60% or more of the areas.
Cohesive failure > 3 MPa Cohesive failure in > 5 MPa Cohesive failure in
coating for 40% or more of the coating for 40% or more of the
area. area.
3.2 Epoxy based systems tested prior to the date of entry into force of this Standard
shall satisfy only the criteria for blistering and rust in the table above. Note however
that all tests of section 2 must be performed and results must be reported (as required
by section 4 for all systems).
3.3 Epoxy based systems tested when applied according to table 1 of this Standard
shall satisfy the criteria for epoxy based systems as indicated in the table above.
3.4 Alternative systems not necessarily epoxy based and/or not necessarily applied
according to table 1 of this Standard shall satisfy the criteria for alternative systems as
indicated in the table above.
4 Test report
According to section 4 of appendix 1.
ANNEX 2
EXAMPLE OF DAILY LOG AND NON-CONFORMITY REPORT
(Omitted)
ANNEX 3
DRY FILM THICKNESS MEASUREMENTS
The following verification check points of DFT are to be taken:
.1 one gauge reading per 5 m of flat surface areas;

.2 one gauge reading at 2 to 3 m intervals and as close as possible to tank
boundaries, but not further than 15 mm from edges of tank boundaries;
Such tank boundaries are welds and free edges which are prone to DFT over and
under - thickness. Thus the rule requires measurement as close to the weld or
free edge as possible.
.3 longitudinal and transverse stiffener members:

One set of gauge readings (i.e. 2 gauge readings – see .4 below) as shown below,
29
taken at 2 to 3 m run and not less than two sets between primary support
members; (regarding underlined sentence: if stiffener is between Primary support
members and its length is less than 3 m, then at least 2 sets of gauge readings (=
4 gauge readings) must be taken.)
Primary support members
Figure 3
NOTE: Arrows of diagram indicate critical areas and should be understood to

mean indication for both sides.
.4 3 gauge readings for each set of primary support members and 2 gauge readings
for each set of other members as indicated by the arrows in the diagram;
This sentence defines the meaning of “set of gauge readings”. For Primary
Support Members one set = 3 gauge readings and for other members one set = 2
gauge readings. The location of individual gauge readings should be selected
from those indicated in the diagram (However see note after .8 below).
.5 for primary support members (girders and transverses) one set of gauge readings
(i.e. 3 gauge readings) for 2 to 3 m run as shown in figure 3 above but not less
than three sets (in case the member is less than 3 m length);
.6 around openings one gauge reading from each side of the opening;
.7 five gauge readings per square metre (m2) but not less than three gauge readings
taken at complex areas (i.e. large brackets of primary support members); and
.8 additional spot checks to be taken to verify coating thickness for any area
considered necessary by the coating inspector.
The above measurement requirements in paragraphs .1 - .7 are the rule minimum. The
rule minimum requirements were intentionally kept reasonable due to all the required
accompanied documentation. However, paragraph .8 was specifically inserted to
ensure that the rule minimum requirement will not be used as a restriction to take
additional measurements anywhere considered necessary. The clear goal is to ensure
that the DFT is appropriately verified everywhere.
***
30
APPENDIX (pictorials)
A precision Nickel Comparator Plate which conforms to International Standard

ISO 8503 for grit and shotblast surface roughness comparison measurement
_________________________________________________________________
• Condition A - intact mill scale

• Condition B - weathered mill scale with rust
• Condition C - totally rusted
• Condition D - totally rusted with pits present
Initial Condition C Blasted Condition C

(Unacceptable profile)
Initial Condition D Blasted Condition D

31
Blasted Condition G
Note: Above blasted conditions are not necessarily to Sa 2 ½ but used to

illustrate the unacceptable profile variations due to pitting excessive hills and
valleys. Condition C and especially D usually occur when the steel has been
left in the open for long periods of time, or has been transported by sea in
unprotected conditions from distant steel producing countries. Initial condition
G is similar to D but with old degraded layers of paint.
Source of pictorials: Reference 1

___________________________________________________________________
FOLLOWING PICTORIALS FROM REFERENCE 4
Grit Embedded in Paint Embedded Grit in Weld Coating
Grit Embedded in Paint Surface D Grade blasted to Sa 2 ½
32
Oil (leaking from rollers) on Plates Poor Primary Preparation
to be Blasted This material will always remain on
the steel, if the shop primer is not
totally removed.
Shop Primer Can Easily Hide Rust White Rust is Damaged Shop Primer
Some yards attempt to “repair” the Blocks such as that shown here, could
shop primer. require total blasting as per PSPC (since
there is hardly any intact or undamaged
primer left).
33
The light colour is where standing Amines on the surface prevented the
water has removed amine curing second coat from adhering to the first
agent from the coating coat
Typical Rust Grade A Typical Rust Grade B

(Acceptable plate initial condition) (Acceptable plate initial condition)
Typical Rust Grade C Typical Rust Grade D

(Unacceptable plate initial condition) (Unacceptable plate initial condition)
***
34

The Imo Performance Standard For Protect

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THE IMO PERFORMANCE STANDARD

FOR PROTECTIVE COATINGS (PSPC)

A GUIDE FOR OWNERS

A GUIDE FOR OWNERS AND INSPECTORS

PREFACE / DISCLAIMER / ACKNOWLEDGEMENTS / REFERENCES.............3

1. APPLICATION (SOLAS vs. IACS)……………………….………………..……..4

2. THE TECHNICAL STANDARDS REFERENCES ………………………….……4

3. AT WHAT COST? ……………………………… ………………………………..5

4. WHAT CHANGED? ………………………………………………………….……..6

5. SPECIFIC COMMENTS ON THE STANDARD …………………… ……......…..7

WORD SEARCH (COMMENTS ON FOLLOWING TOPICS APPEAR ON INDICATED PAGES)

“COATING TECHNICAL FILE (CTF)”……………………………….…9/14/17/19/20/21

“CONDITION BETWEEN COATS”………………………………...……………….16/17

“PRIMARY SURF. PREPARATION” ……………………..…..…10/17/18/19/20/23/33

“SECONDARY SURF. PREPARATION”………………………...………....13/16/20/21

COVER PICTURE COURTESY AMTEC CONSULTANTS & THETA MARITIME.

The Performance Standard for Protective Coating (PSPC), made mandatory by

For SOLAS the dates of entry into force are:

For ships of not less than 500 gross tonnage:

The coating application (including steel surface preparation etc) shall be in

1. Coating system approval:

For IACS the dates of entry into force are:

2. THE MANDATORY NATURE OF TECHNICAL STANDARDS REFERENCES.

- Resist a generalized and unsubstantiated cost increase request by the

5. SPECIFIC COMMENTS ON THE STANDARD.

FOR EASY REFERENCE, COMMENTS (IN BOLD ITALIC – GRAY

PERFORMANCE STANDARD FOR PROTECTIVE COATINGS FOR

The “official” inspector is to be properly NACE or FROSIO certified and is to be chosen

However, it must be stressed that irrespective of who is chosen to be the PSPC

3.3 When considering the Standard provided in section 4, the following is to be

.1 it is essential that specifications, procedures and the various different steps in

.2 the coating performance can be improved by adopting measures at the ship

.3 the coating performance standard provided in this document is based on

3.4 Coating Technical File

3.4.2 New construction stage

.1 copy of Statement of Compliance or Type Approval Certificate;

This in practice will be provided by the Recognized Organizations (classification

.2 copy of Technical Data Sheet, including:

-product name and identification mark and/or number;

.3 shipyard work records of coating application, including:

.4 procedures for inspection and repair of coating system during ship

.7 procedures for in-service maintenance and repair of coating system 2.

3.4.3 In-service maintenance, repair and partial re-coating

3.4.2.7 and 3.4.3

3.5 Health and safety

The shipyard is responsible for implementation of national regulations to ensure the

4.1 Performance standard

This Standard is based on specifications and requirements which intend to provide a

4.2 Standard application

4.3 Special application

4.4 Basic coating requirements

4.4.1 The requirements for protective coating systems to be applied at ship

4.4.2 Coating manufacturers shall provide a specification of the protective coating

FOR EASY REFERENCE, COMMENTS (IN BOLD ITALIC – GRAY

.1 location of space relative to heated surfaces;

Coating manufacturers shall have products with documented satisfactory

In IMO terminology “shall” is an absolute requirement (as opposed to

Coatings for application underneath sun-heated decks or on bulkheads

.2 Coating type Epoxy based systems.

Other coating systems with performance according to the test procedure in

A multi-coat system with each coat of contrasting colour is recommended.

The top coat shall be of a light colour in order to facilitate in-service