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Majestic Rev. 01
Majestic Rev. 01
Majestic Rev. 01
Biofouling
Management Plan
Majestic
IMO: 9694438
(For compliance with IMO Resolution MEPC.207(62): Guidelines for the Control and Management of Ships’ Biofouling to
Minimize the Transfer of Invasive Aquatic Species, adopted on 15 July, 2011, hereafter referred to as the Biofouling Guidelines).
Note:
1) This Plan is written in the working language of the crew i.e. English.
2) This plan has been issued by Bernhard Schulte Shipmanagement (Cyprus) who are the managers of the vessel. No
alteration or revision shall be made to any part of it without the prior approval of the issuer.
Contents
1. Ship particulars 4
2. Introduction 5
3. Record of Circulation 7
4. Record of Amendments 9
5. Purpose of the Plan 10
6. Definitions 11
7. Objectives 12
8. Description of the ship’s anti-fouling systems 13
9. Description of the ship’s operating profile 14
10. Description of areas on the ship susceptible to biofouling 15
Biofouling Management Action Plan 16
11.1.6 Stern tube seal assemblies and the internal surfaces of rope guards 17
1. Ship particulars
Contents Data
Ship’s name Majestic
Ship type 1 Container vessel
Flag Singapore
2. Introduction
By adopting the International Convention for the Control and management of Ships' Ballast
Water and Sediments, 2004 (the BWM Convention), member states of the International
Maritime Organization (IMO) made a clear commitment to minimising the transfer of invasive
aquatic species by shipping.
Studies have shown that biofouling can also be a significant vector for the transfer of invasive
aquatic species. Biofouling on ships entering the waters of states may result in the
establishment of invasive aquatic species which may pose threats to human, animal and
plant life, economic and cultural activities and the aquatic environment.
While the International Convention on the Control of Harmful Anti-Fouling Systems on Ships,
2001 (the AFS Convention) addresses anti-fouling systems on ships, its focus is on the
prevention of adverse impacts from the use of anti-fouling systems and the biocides they may
contain, rather than preventing the transfer of invasive aquatic species.
The potential for invasive aquatic species transferred through biofouling to cause harm has
been recognised by the IMO, the Convention on Biological Diversity (CBD), several UNEP
Regional Seas Conventions (e.g., the Barcelona Convention for the Protection of the
Mediterranean Sea Against Pollution), the Asia Pacific Economic Cooperation forum (APEC),
and the Secretariat of the Pacific Region Environmental Program (SPREP).
All ships have some degree of biofouling, even those which may have been recently cleaned
or had a new application of an anti-fouling coating system. Studies have shown that the
biofouling process begins within the first few hours of a ship's immersion in water. The biofouling
that may be found on a ship is influenced by a range of factors, such as:
1. design and construction, particularly the number, location and design of niche areas
2. the specific operating profile, including factors such as: operating speeds; ratio of time
underway compared with time alongside, moored or at anchor; and where the ship is
located when not in use (e.g., open anchorage or estuarine port)
3. places visited and trading routes; and
4. Maintenance history, including: the type, age and condition of any anti-fouling coating
system; installation and operation of anti-fouling systems; and dry-docking/slipping and
hull cleaning practices.
Implementing practices to control and manage biofouling can greatly assist in reducing the
risk of the transfer of invasive aquatic species. Such management practices can also improve
a ship's hydrodynamic performance and can be effective tools in enhancing energy
efficiency and reducing air emissions from ships. This concept has been identified by the IMO
in its Guidance for the Development of a Ship Energy Efficiency Management Plan (SEEMP).
The Biofouling Guidelines are intended to provide a globally consistent approach to the
management of biofouling. As scientific and technological advances are made, the
Guidelines will be refined to enable the risks to be more adequately addressed. Port states,
flag states, coastal states and other parties that can assist in mitigating the problems
associated with biofouling should exercise due diligence to implement the Biofouling
Guidelines to the maximum extent possible
Good record keeping is critical to the success of a sound biofouling management
programme. Compliance can be verified and managed more effectively if accurate records
are maintained and stored in an organised manner.
Biofouling Management Plan
IMO Number: 9694438
The Plan should be available for viewing on request by a port state authority.
Biofouling Management Plan
IMO Number: 9694438
3. Record of Circulation
This document is to be circulated to the ship’s staff that will be responsible for biofouling
management.
4. Record of Amendments
The holder of the controlled copy of this Plan shall record all amendments in the table
below and send a notification to all holders of the Plan describing the changes that have
been made.
The purpose of the Plan is to outline measures for the control and management of ships'
biofouling in accordance with the Biofouling Guidelines. It provides operational guidance
for the planning and actions required for ships' biofouling management.
Organisations or shipping agents representing ship owners and operators should be familiar
with the requirements of state authorities with respect to biofouling management and
treatment procedures, including information that will be needed to obtain entry clearance.
Verification and detailed information concerning state requirements should be obtained by
the ship before arrival.
Implementation of an effective biofouling management regime is critical for minimising the
transfer of invasive aquatic species. The biofouling management measures to be
undertaken on a ship should be outlined in this Biofouling Management Plan, and records of
biofouling management practices should be kept in a Biofouling Record Book.
Biofouling Management Plan
IMO Number: 9694438
6. Definitions
AFS Convention means the International Convention on the Control of Harmful Anti-Fouling Systems on
Ships, 2001.
Anti-fouling coating system means the combination of all component coatings, surface treatments
(including primer, sealer, binder, anti-corrosive and anti-fouling coatings) or other surface treatments,
used on a ship to control or prevent attachment of unwanted aquatic organisms.
Anti-fouling system means a coating, paint, surface treatment, surface, or device that is used on a
ship to control or prevent attachment of unwanted organisms.
Biofouling means the accumulation of aquatic organisms such as micro-organisms, plants, and
animals on surfaces and structures immersed in or exposed to the aquatic environment. Biofouling
can include micro fouling and macro fouling (see below).
In-water cleaning means the physical removal of biofouling from a ship while in the water. Invasive
aquatic species means a species which may pose threats to human, animal and plant life, economic
and cultural activities and the aquatic environment.
Marine Growth Prevention System (MGPS) means an anti-fouling system used for the prevention of
biofouling accumulation in internal seawater cooling systems and sea chests and can include the use
of anodes, injection systems and electrolysis.
Member states mean states that are members of the International Maritime Organization.
Macro fouling means large, distinct multi-cellular organisms visible to the human eye such as
barnacles, tubeworms, or fronds of algae.
Micro fouling means microscopic organisms including bacteria and diatoms and the slimy substances
that they produce. Biofouling comprised of only micro fouling is commonly referred to as a slime layer.
Niche areas means areas on a ship that may be more susceptible to biofouling due to different
hydrodynamic forces, susceptibility to coating system wear or damage, or being inadequately, or not,
painted, e.g., sea chests, bow thrusters, propeller shafts, inlet gratings, dry-dock support strips, etc.
Port state authority means any official or organization authorized by the government of a port state to
verify the compliance and enforcement of standards and regulations relevant to the implementation
of national and international shipping control measures.
Ship means a vessel of any type whatsoever operating in the aquatic environment and includes
hydrofoil boats, air-cushion vehicles, submersibles, floating craft, fixed or floating platforms, floating
storage units (FSUs) and floating production storage and off-loading units (FPSOs).
Treatment means a process which may use a mechanical, physical, chemical or biological method to
remove or render sterile, invasive or potentially invasive aquatic species fouling a ship.
Biofouling Management Plan
IMO Number: 9694438
7. Objectives
The objectives of the Biofouling Management Plan (based on the Biofouling Guidelines) are
to provide practical guidance to any interested parties, on measures to minimise the risk of
transferring invasive aquatic species from ships' biofouling. It is important that biofouling
management procedures be effective as well as environmentally safe, practical, designed
to minimise costs and delays to the ship, and based on the Guidelines whenever possible.
To minimise the transfer of invasive aquatic species, a ship should implement biofouling
management practices, including the use of anti-fouling systems and other operational
management practices to reduce the development of biofouling. The intent of such
practices is to keep the ship's submerged surfaces and internal seawater cooling systems as
free of biofouling as practical. A ship following this guidance and minimising macro fouling
would have a reduced potential for transferring invasive aquatic species via biofouling.
The management measures outlined within this Plan are intended to complement current
maintenance practices carried out within the industry.
Biofouling Management Plan
IMO Number: 9694438
The Plan describes the anti-fouling systems in place for different parts of the ship, including:
− the type(s) of anti-fouling coating systems applied
− details of where anti-fouling systems are and are not applied or installed
− the manufacturer and product names of all coatings or products used in the anti-fouling
coating systems; and
− the anti-fouling system specifications (including dry film thickness for coatings, dosing
and frequency for MGPSs, etc.) together with the expected effective life, operating
conditions required for coatings to be effective, cleaning requirements and any other
specifications relevant for paint performance.
Anti-fouling systems and operational practices are the primary means of biofouling
prevention and control for existing ships' submerged surfaces, including the hull and niche
areas.
An anti-fouling system can be a coating system applied to exposed surfaces, biofouling
resistant materials used for piping and other unpainted components, marine growth
prevention systems (MGPSs) for sea chests and internal seawater cooling systems, or other
innovative measures to control biofouling. If an appropriate anti-fouling system is not
applied, biofouling accumulation increases.
The anti-fouling system used should comply with the AFS Convention, where necessary.
Previous reports on the performance of the ship's anti-fouling systems should be included, if
applicable, and the AFS certificate or statement of compliance or other documentation
should also be referenced, as appropriate.
Additional information about the installed anti-fouling system can be found in Appendix 1.
International Anti Fouling System Certificate in Appendix 2
Biofouling Management Plan
IMO Number: 9694438
The diagram below identifies the location of those areas of the ship that are particularly
susceptible to biofouling (including access points in the internal seawater cooling systems).
If necessary these should show both the side and bottom views of the ship.
See also Appendix 4 for plans and drawings of the ship identifying the relevant locations.
Low Sea
Chest
Bow Thruster
MGPS
Low sea
chest
MGPS
External hull surfaces: Areas above water level to 1. Propeller turning for ½ hour every
- vertical sides be inspected in port and day after first 7 days of static
- flats
maintained. All other areas condition and henceforth every
to be inspected and day. 2. Short Sailing for min. 1 hour at
boot top
-
maintained in dry dock as Full speed after 15 days of static
- bow dome required. condition , OR
- transom Ahead/Astern short kick every 3
days in static condition.
11.1.6 Stern tube seal assemblies and the internal surfaces of rope guards
Biofouling Management Plan
IMO Number: 9694438
Exposed sections of stern tube seal assemblies and the internal surfaces of rope guards
should be carefully painted with anti-fouling coating systems appropriate to the degree of
water movement over and around these surfaces.
inspections as necessary to address any situations of elevated risk. Specific occasions when
an in-water inspection may be appropriate, include:
− before and after any planned period of inactivity or significant or unforeseen change to
the ship's operating profile
− before undertaking in-water cleaning to determine the presence of known or suspected
invasive aquatic species or other species of concern on the ship
− after a known or suspected marine pest or other species of concern is discovered in a
ship's internal seawater cooling systems
− following damage to, or premature failure of, the anti-fouling system.
It is recommended that ship operators identify niche areas on the ship that may
accumulate biofouling to enable these areas to be effectively targeted during inspections.
These areas may include:
- propeller thrusters and propulsion units
− sea chests
− rudder stock and hinge
− stabiliser fin apertures
− rope guards, stern tube seals and propeller shafts
− cathodic protection anodes
− anchor chain and chain lockers
− free flood spaces inherent to the ship’s design
− sea chest and thruster tunnel grates
− echo sounders and velocity probes
− overboard discharge outlets and sea inlets
− areas prone to anti-fouling coating system damage or grounding (e.g., areas of the hull
damaged by fenders when alongside, leading edges of bilge keels and propeller shaft
"y" frames).
Diver and remotely operated vehicle (ROV) surveys can be practical options for in-water
inspections although they do have limitations regarding visibility and available dive time
compared with the area to be inspected, and difficulties with effectively accessing many
biofouling prone niches.
It may be appropriate for states to conduct a risk assessment to evaluate the risk of in-water
cleaning activities and minimise potential threats to their environment, property and
resources.
Risk assessment factors could include:
− biological risk of the biofouling organisms being removed from the ship (including viability
of the biofouling organisms or the ability to capture biofouling material)
− factors that may influence biofouling accumulation, such as changes to the operating
profile of the ship
− the geographical source of the biofouling on the ship, if known
− toxic effects related to substances within the anti-fouling coating system that could be
released during the cleaning activity, and any subsequent damage to the anti-fouling
coating system.
Personnel proposing to undertake in-water cleaning should be aware of any regulations or
requirements for the conduct of in-water cleaning, including any regulations regarding the
discharge of chemicals into the marine environment and the location of sensitive areas
(such as marine protected areas and ballast water exchange areas).
Where significant macro fouling growth is detected, it should be removed or treated (if this
can be done without damaging the anti-fouling system) in accordance with such
regulations.
Where available, appropriate technology should be used to minimise the release of both
anti-fouling coating and paint debris, and viable adult, juvenile, or reproductive stages of
macro fouling organisms.
The collected material should be disposed of in a manner which does not pose a risk to the
aquatic environment.
For immersed areas coated with biocidal anti-fouling coatings, cleaning techniques should
be used that minimise release of biocide into the environment. Cleaning heavily fouled
anti-fouling coating systems can not only generate biofouling debris, but prematurely
depletes the anti-fouling coating system and may create a pulse of biocide that can harm
the local environment and may impact on future applications by the port authority for the
disposal of dredge spoil.
Depleted anti-fouling coating systems on hulls will rapidly re-foul. In-water cleaning or
scrubbing of hulls for the purpose of delaying dry-dockings beyond the specified service life
of the coating is therefore not recommended.
Immersed areas coated with biocide-free anti-fouling coating systems may require regular
in-water cleaning as part of planned maintenance to maintain hull efficiency and minimise
the risk of transferring invasive aquatic species. Cleaning techniques should be used which
do not damage the coating and impair its function.
Regular polishing of uncoated propellers to maintain operational efficiency will also
minimise macro fouling accumulation. Uncoated propeller shafts may require cleaning at
the same time as the propeller. As a ship's routine propeller polishing will involve the use of
divers, it is recommended that this opportunity is taken to assess sea chests, and other
similar areas, for macro fouling.
Any maintenance or repair activities should take care not to impede future in-service
cleaning and/or maintenance, e.g., care should be taken to ensure sea chest grates do
not become welded shut during repair work.
Biofouling Management Plan
IMO Number: 9694438
MGPS is always running. Both, high & low sea chests are protected by MGPS system and
changeover is possible.
This system is applied to the sea chests and sea water pipe lines to protect them against fouling
and prevention of pipes from marine growth.
Maintenance is done as mentioned in the instruction book for MGPS system and detailed in the
ships Planned Maintenance System.
4. Sea chest filters to blow with air and frequency of sea chest filters inspection and cleaning
(mechanical) to increase.
MGPS is anode & electrical system, so no such chemical inspection or treatment carried out
on board
Biofouling Management Plan
IMO Number: 9694438
• As per SMS checklist SHE 31, SHE 35, SHE 38 to be followed prior doing any
maintenance.
If the crew cleans the ship from biofouling such works shall be conducted by, or under
the direct supervision of the ship owner, master or responsible officer. The biological
waste is taken care of and disposed in accordance with the relative Conventions and
local requirements.
Ship maintenance and recycling facilities should adopt measures (consistent with
applicable national and local laws and regulations) to ensure that viable biofouling
organisms or chemical and physical pollutants are not released into the local aquatic
environment. These measures include:
1. capturing biological material to minimise the risk of organism survival and establishment
and other impacts of biological material being released into the aquatic environment
2. treating and/or disposing of captured biological material in an environmentally
appropriate manner
3. scheduling of ships' arrival and departure at cleaning and maintenance facilities and at
locations where ships are moored while waiting for cleaning and maintenance to
minimise the risk of fouled ships contaminating other ships and the surrounding
environment
4. removing biofouling from all underwater surfaces of a ship when in dry-dock, including
niche areas
5. lowering or extending retractable equipment such as stabilisers, thrusters, transducers
and similar when a ship is in dry-dock or slipped, to permit access for the removal of
biofouling from the equipment and its housing.
Biofouling Management Plan
IMO Number: 9694438
A Biofouling Record Book is maintained onboard each ship and records are also available
in the Planned Maintenance System.
The Book should record details of all inspections and biofouling management measures
undertaken on the ship. This is to assist the ship owner and operator in evaluating the
efficacy of the specific anti-fouling systems and operational practices on the ship in
particular, and of the Biofouling Management Plan in general.
The Record Book could also help interested state authorities to quickly and efficiently assess
the potential biofouling risk of the ship, and thus minimise delays to ship operations.
The Biofouling Record Book may be a stand-alone document, or integrated in part, or fully,
into the existing ships' operational and procedural manuals and/or planned maintenance
system.
It is recommended that the Biofouling Record Book be retained on the ship for the life of the
ship.
Information that should be recorded in a Biofouling Record Book includes:
1. details of the anti-fouling systems and operational practices used (where appropriate as
recorded in the Anti-fouling System Certificate), where and when the systems were
installed, the areas of the ship coated, system maintenance and, where applicable,
system operation
2. the dates and location of dry-dockings, including the date the ship was re-floated, and
any measures taken to remove biofouling or to renew or repair the anti-fouling system
3. the date and location of in-water inspections, the results of those inspections and any
corrective action taken to deal with observed biofouling
4. the dates and details of inspection and maintenance of internal seawater cooling
systems, the results of these inspections, and any corrective action taken to deal with
observed biofouling and any reported blockages
5. details of when the ship has been operating outside its normal operating profile,
including any details of when the ship was laid-up or inactive for extended periods of
time.
An example Biofouling Record Book and the information to be recorded are included in
Appendix 3 of this Plan.
Biofouling Management Plan
IMO Number: 9694438
The Biofouling Management Officer (Chief Engineer) is responsible for implementing the
procedures of the Biofouling Management Plan.
His role is to:
− ensure the safety of the ship and crew
− ensure that biofouling management and/or treatment procedures are followed and
recorded
− ensure adequate personnel and equipment are available for the execution of the
planned biofouling management operations
− ensure all required biofouling management records are maintained and up-to-date,
including the Biofouling Record Book
− where required, prepare the appropriate national or port biofouling declaration form
before arrival
− undertake familiarisation and training of crew in biofouling management requirements
and applicable shipboard systems and procedures
− perform other duties, as specified by the company.
The Master must ensure that the Biofouling Management Plan is clearly understood by the
appointed officer and by any other ship’s staff that may be involved.
The Biofouling Management Officer must keep the Master advised on the progress of
biofouling management operations and any envisaged deviations from the agreed Plan.
Biofouling Management Plan
IMO Number: 9694438
Training for ships' masters and crews should include instructions on the application of
biofouling management and treatment procedures, based on the information contained in
Appendices 5 and 6.
Instruction should also be provided on:
1. maintenance of appropriate records and logs
3. benefits to the ship of managing biofouling and the threats posed by not applying
management procedures
4. biofouling management measures and associated safety procedures
Copy of the certificate is available in the PAL certificate module and in the vessels certificate file.
Biofouling Management Plan
IMO Number: 9694438
Flag: Singapore
Diagram of ship indicating underwater hull form (showing both side and bottom views of the ship, if
necessary) and recognised biofouling niches:
See section 10 of this plan.
Biofouling Management Plan
IMO Number: 9694438
1. Introduction
The Biofouling Guidelines recommend that a Biofouling Record Book is maintained for each ship.
This should record the details of all inspections and biofouling management measures undertaken
on the ship.
3. any hull cleaning that was performed while dry-docked, including areas cleaned,
method used for cleaning and the location of dry-dock support blocks
4. any anti-fouling coating system, including patch repairs, that was applied while dry-
docked (detail the type of anti-fouling coating system, the area and locations it was
applied to, the coating thickness achieved and any surface preparation work
undertaken (e.g., complete removal of underlying anti-fouling coating system or
application of new anti-fouling coating system over the top of existing anti-fouling
coating system))
5. name, position and signature of the person in charge of the activity for the ship.
2.2 When the hull area, fittings, niches and voids below the waterline have been inspected by divers:
1. date and location of the ship when diver-surveyed and reason for survey
5. any supporting evidence of the actions taken (e.g., report from the classification society
or contractor, photographs and receipts)
6. name, position and signature of the person in charge of the activity.
2.3 When the hull area, fittings, niches and voids below the waterline have been cleaned by divers:
1. date and location of the ship when cleaning/treatment occurred
2.4 When the internal seawater cooling systems have been inspected and cleaned or treated:
1. date and location of the ship when inspection and/or cleaning occurred
2. general observations with regard to biofouling of internal seawater cooling systems (i.e.,
extent of biofouling and predominant biofouling types, e.g., mussels, barnacles,
tubeworms, algae, slime)
3. any cleaning or treatment undertaken
5. any supporting evidence of the actions taken (e.g., report from the classification society
or contractor, photographs and receipts)
6. name, position and signature of the person in charge of the activity.
2.5 For ships with a MGPS fitted:
1. records of operation and maintenance (such as regularly monitoring the electrical and
mechanical functions of the systems)
2. any instances when the system was not operating in accordance with the Biofouling
Management Plan.
2.6 Periods of time when the ship was laid up/inactive for an extended period of time:
1. date and location where the ship was laid up
4. precautions taken to prevent biofouling accumulation (e.g., sea chests blanked off).
2.7 Periods of time when ship operating outside its normal operating profile:
1. duration and dates when the ship was not operating in accordance with its normal
operating profile
2. reason for departure from normal operating profile (e.g., unexpected maintenance
required).
2.8 Details of official inspection or review of ship biofouling risk (for ships arriving internationally, if
applicable):
1. date and location of the ship when inspection or review occurred
4. name, position and signature of the person in charge of the activity for the ship.
2.9 Any additional observations and general remarks:
1. Since the ship was last cleaned, has the ship spent periods of time in locations that may
significantly affect biofouling accumulation (e.g., fresh water, high latitude (Arctic and
Antarctic) or tropical ports)?
Biofouling Management Plan
IMO Number: 9694438
- Resolution MEPC.207(62)
National or local requirements for the Guidelines for the Control and Management of Ships’
Biofouling to Minimize the Transfer of Invasive Aquatic Species, including report forms (where
applicable).
This section should be maintained up-to-date by the Biofouling Management Officer by inserting local
regulations as applicable.
1 General
The regional requirements described in this section include particular requirements specified by the
United States of America. If and when other Flag Administrations issue requirements additional to
the IMO Resolution MEPC.207(62) “2011 Guidelines for the Control and Management of Ship’s
Biofouling to Minimize the Transfer of Invasive Aquatic Species”, these will be included in future
updates of these guidance notes.
2 United States of America
To support the ongoing objective of further reducing the potential risk of the spread of invasive
aquatic species by shipping, the U.S. Coast Guard and the State of California have incorporated
regulations specifying operational measures aimed at preventing the spread of invasive aquatic
species via biofouling. The prevention of biofouling is an important component of the ballast water
management plan.
2.1 U.S. Coast Guard
In accordance with 33 CFR 151.2050(e), every vessel equipped with ballast tanks operating in U.S.
Waters is required to rinse anchors and anchor chains when the anchor is retrieved to remove
organisms and sediments at their places of origin. In addition, these vessels are required by 33 CFR
151.2050(f) to remove fouling organisms from the vessel’s hull, piping, and tanks on a regular basis
and dispose of any removed substance in accordance with local, State and Federal regulations.
To assist the Owners/operators and ship’s crew, as well as Coast Guard Inspecting Officers/Teams,
in the management of biofouling, the U.S. Coast Guard regulations specify that the required Ballast
Water Management Plan shall include detailed fouling maintenance procedures. While the
regulations do not detail the items to be included within the fouling maintenance procedures, the
Coast Guard has advised that IMO Resolution MEPC.207(62) and the latest draft of the California
State Lands Commission (specifically Section 2298.4 entitled “Biofouling Management Plan”)
provide a basis for developing a vessel-specific biofouling management plan. The Coast Guard has
also advised that inclusion of such a biofouling management plan in the required Ballast Water
Management Plan or a reference in the Ballast Water Management Plan to an independent
vessel-specific Biofouling Management Plan would satisfy this regulation.
Coast Guard regulations do not currently require Ballast Water Management Plans to be approved.
However, approval of the Ballast Water Management Plan will be required when the IMO Ballast
Water Management Convention enters into force.
2.2 U.S. Environmental Protection Agency
As required by part 4.1.3 of the 2008 Vessel General Permit (VGP), a comprehensive vessel
inspection must be conducted by qualified personnel at least once every 12 months. Qualified
personnel include the Master or Owner/operator of the vessel, if appropriately trained, or
appropriately trained marine or environmental engineers or technicians or an appropriately trained
representative of a vessel’s class society acting on behalf of the Owner/operator (Class Surveyor).
These comprehensive annual inspections must cover all areas of the vessel affected by the
requirements in the VGP that can be inspected without forcing a vessel into dry-dock. Special
attention should be paid to those areas most likely to result in a discharge, likely to cause or
contribute to non-compliance of water quality standards, or violate effluent limits established in the
VGP. Areas that inspectors must examine include, but are not limited to:
i) Vessel’s hull for attached living organisms, flaking anti-fouling paint, exposed organotin
(tin based chemicals used in marine anti-fouling paints) surfaces such as TBT (tributyltin)
Biofouling Management Plan
IMO Number: 9694438
immersed surfaces or a sealer-coat must be applied to prevent any residual TBT leaking
in to the environment. The EPA is unaware of any non-biocidal use of TBT which would
result in a residual presence in anti-fouling paints, hence, the EPA has reaffirmed that
there must be zero discharge of TBT from vessel hulls.
Other less toxic organotins, such as dibutyltin, are used in very small quantities as
catalysts in biocide-free coatings that can be applied to immersed areas of ships to
control fouling. Biocidal-free coatings create a slick surface to which fouling organisms
cannot firmly attach. To function properly, the coating surface must remain smooth and
intact, and not leak into the surrounding water. Because these less toxic organotins are
used as a catalyst in the production of biocide-free coatings, such production may
result in trace amounts of organotin in anti-fouling coatings. The EPA has interpreted the
provisions of Part 2.2.4 of the VGP which apply to TBT “or any other organotin
compound” to authorize the use of non-biocidal coatings which contain these trace
amounts of catalytic organotin (other than TBT) under the following conditions:
i) The trace amounts of organotin are not used as biocides. On a practical level,
when used as a catalyst, organotin compounds should not be present above
2500 mg total ton per kilogram of dry paint.
ii) The coating is not designed to slough or otherwise peel from the vessel’s hull.
Incidental amounts of coating may be released by abrasion during cleaning or
after contact with other hard surfaces (e.g., moorings).
In addition and in accordance with Part 4.1.4 of the 2008 VGP, the vessel’s
Owner/operator must make any dry dock reports prepared by the class or their
flag Administrations available to EPA or an authorized representative of EPA
upon request. If a dry dock report from either class or the flag Administrations is
not available, the Owner/operator must prepare a dry dock report that is to be
made available to the EPA or an authorized representative of EPA upon request.
The dry dock report is to include the following:
• The chain locker has been cleaned for both sediments and living organisms.
• The vessel hull, propeller, rudder, thruster gratings, sea chests, and other
surface areas of the vessel have been inspected for attached living organisms
and those organisms have been removed or neutralized.
• Any anti-fouling hull coatings have been applied, maintained and removed
consistent with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA
Label), if applicable. Any exposed existing coating or any new coating does not
contain biocides or toxics that are banned for use in the United States.
• All cathodic protection, anodes or dielectric coatings have been cleaned
and/or replaced to reduce flaking.
• All pollution equipment is properly functioning.
2.3 State of California
In addition to the above U.S. Federal requirements, the State of California will require the
Master, Owner, operator, or person in charge of a vessel carrying or capable of carrying
ballast water that operates in the waters of the State of California to maintain a Biofouling
Management Plan that was prepared specifically for the vessel that shall, upon request, be
made available to commission staff for inspection and review.
For vessels that intend to operate in California waters, it is recommended that the biofouling
management plan be established as a standalone document referenced in the ballast
water management plan so that amendments to the biofouling management plan can be
made when California finalizes its regulations. Additional information on the California State
Lands Commission (CSLC) draft regulations is available on the CSLC website.
Owners/operators, Masters, and crew are to note that the draft State of California Biofouling
Regulations requires vessel’s to maintain and retain a vessel-specific Biofouling Record Book
on board the vessel.