Marine coatings regulation
Coatings are used all around a ship both for protective and for aesthetic reasons but until September 2008 when the International Convention on the Control of Harmful Anti-fouling Systems on Ships came into force seven years after it was adopted by the IMO there had been virtually no regulations affecting coatings beyond basic safety.
SOLAS rules cover fire hazard
What regulation there was in SOLAS was concerned solely with the hazards arising from paint in store. It is worth covering these regulations here as the main hazard is fire and aboard any ship fire is among the most feared of all potential problems. It should therefore come as no surprise to know that SOLAS says that there should be no sources of potential ignition in paint lockers and the lockers should be protected from fire by a variety of means. Those fire protection measures include a requirement for;
- A carbon dioxide system, designed to give a minimum volume of free gas equal to 40% of the gross volume of the protected space;
- A dry powder system, designed for at least 0.5 kg powder/m3;
- A water spraying or sprinkler system, designed for 5 L/m2 min. Water spraying systems may be connected to the fire main of the ship; or
- A system providing equivalent protection, as determined by the Administration.
In all cases, the fire protection system must be operable from outside the protected space. These are of course common sense regulations but ones which highlight the fact that paints and coatings are not harmless substances and have hazards associated with them that need consideration.
Fire in a paint store is one thing but since the majority of a ship’s structure is painted or coated in some way, SOLAS also has something to say about the characteristics of coatings in case of fire. These are contained in SOLAS II-2 regulation 6 which states:
Smoke generation potential and toxicity
The purpose of this regulation is to reduce the hazard to life from smoke and toxic products generated during a fire in spaces where persons normally work or live. For this purpose, the quantity of smoke and toxic products released from combustible materials, including surface finishes, during fire shall be limited.
2.1 Paints, varnishes and other finishes
Paints, varnishes and other finishes used on exposed interior surfaces shall not be capable of producing excessive quantities of smoke and toxic products, this being determined in accordance with the Fire Test Procedures Code.
2.2 On passenger ships constructed on or after 1 July 2008, paints, varnishes and other finishes used on exposed surfaces of cabin balconies, excluding natural hard wood decking systems, shall not be capable of producing excessive quantities of smoke and toxic products, this being determined in accordance with the Fire Test Procedures Code.
The latter point was a result of a fire in 2006 on board the cruise ship Star Princess in which one passenger died and several more suffered from smoke inhalation after a fire began on the balcony of one of the passenger cabins. It is believed that the fire was started by a lighted cigarette igniting a polycarbonate balcony divide and rapidly spread to other parts of the balcony and surrounding areas.
At war with nature
Shipping’s battle with the forces of nature is one that has been fought from the days of wooden ships. Over time, preventing biofouling has involved the use of many different materials and chemicals from sheets of copper to poisonous compounds. Some of these were very successful but their undesirable side effects attracted the attention of science and the environmental movement which wanted to see them controlled and prohibited from use.
Unlike so much IMO regulation which details what ships must do or carry, the International Convention on the Control of Harmful Anti-fouling Systems on Ships which was adopted in October 2001 but only came into force on 17 September 2008 is totally geared to preventing the use of certain products. The convention covers all vessels including FSUs and FPSOs.
Initially the product at which the convention was aimed was tributyltin (TBT), a substance developed through the 1960s and first used in the 1970s and which the IMO itself concedes is probably the most effective biocide so far devised for the maritime industry. Before the convention came into force all of the leading coatings manufacturers had already ceased production of TBT products and were developing replacement products. Not all of the new coatings used on the hulls are affected by the convention because the technologies that have been developed sometimes are designed not to kill but merely to make attachment to the hull more difficult.
Essentially there are now three different methods used in products for coating for the underwater parts of a ship: anti-foulings contain a biocide to kill organisms that adhere to the full, foul release coatings are designed to prevent organisms attaching by a variety of methods and hard coats present a smooth surface which can be cleaned using equipment that would remove or damage the other two types of coating. The technologies employed in each case may vary from product to product and some manufacturers describe some products as having more than one means of operation.
As with most IMO treaties, there is provision for countries to opt out of it but should they do so their vessels will not be welcome in most parts of the world. Any party to the treaty is obliged to apply it to vessels flying their flag or which they otherwise have some control over, and to prevent any vessel of whatever flag entering their ports. Since most of the world’s major economies are parties to the treaty, only a very few domestic vessels and some trading between adjacent countries that are not signatories can afford to ignore the treaty.
Testing for banned products by Port State Control inspectors is allowed under the convention but there is very little evidence to suggest that this is done on any great scale. Ships above 400gt are obliged to undergo an initial survey before the ship is put into service or before the International Anti-fouling System Certificate required under regulation 2 or 3 of the convention is issued for the first time. Ships are also obliged to undergo a survey when the anti-fouling systems are changed or replaced and the details of the survey recorded on the certificate.
The certificate records the type of anti-fouling used, the manufacturer, where it was applied and by whom and even extends to the colour of the coating. Generally, as long as the certificate appears to be in order, PSC inspectors are unlikely to order tests on the coatings although this can never be discounted. The convention includes a clause which states that a ship shall be entitled to compensation if it is unduly detained or delayed while undergoing inspection for possible violations of the convention.
The Black List
As mentioned earlier, the International Convention on the Control of Harmful Anti-fouling Systems on Ships does not approve any products but is purely a prohibiting convention with a black list of banned substances. Today, organotin is still the only substance on the banned list which is contained as Annex I to the convention. However, there are expectations that other products may be added over time. Copper-based products which now feature in many biocidal anti-fouling products are often mentioned as being likely candidates for future banning.
However, in August 2016 the prospect of an imminent ban on copper receded when it was announced that after thorough scientific evaluation of the use of dicopper oxide, copper thiocyanate and coated copper flake as antifouling substances within the EU Biocidal Products Regulation 528/2012, the ECHA Biocidal Product Committee has determined that these copper compounds are approved for use as active substances in commercial and yacht (pleasure craft) antifouling products. The committee also allowed for application by both professional and non-professional users. These three compounds are the only copper compounds to have received approval to date but importantly they are the forms of copper most commonly used in current antifouling paints, either as sole biocide or in conjunction with a co-biocide.
As always with EU regulations things are not so straightforward and the regulations require that manufacturers submitted applications for approval of all their copper-based antifouling products by 1st January 2018. Products containing zinc pyrithione will have a later deadline. Paints must be approved by each country in which it will be marketed.
For any product to be added to the IMO black list, an amendment is required under article 16 of the convention which will first be subject to a lengthy investigation process described in articles 6 and 7. As the shipping industry in general and the coatings manufacturers in particular are likely to be aware of any move to add a substance to the banned list well in advance of any action actually being taken, the length of time needed for the process is not likely to cause headaches for operators. Even so the convention does allow any vessel affected by an amendment to Annex I a period of grace of up to 60 months or until the coatings were due for renewal whichever is the earlier.
Stopping species transfer
It is somewhat ironic that the ban on TBT was brought in because a build-up of the biocides from anti-foulings was causing casualties among some species and yet now new regulation looks certain to encourage more of the same in a bid to stop the spread of invasive species.
The realisation that species can be transferred around the world other than in ballast water seems to have finally dawned on regulators and in July 2011 the IMO a issued MEPC.207(62) entitled 2011 Guidelines for the control and management of ship’s biofouling to minimize the transfer of invasive aquatic species. The document came with a request for IMO member states to take action to implement the guidelines as fully as possible.
So far there has been no international movement to make the guidelines binding but just as with the matter of ballast water treatment, some local attempts are being made to enact legislation. Not surprisingly, California has been a leader in this regard as there is no Federal US regulations on the issue – although the USCG regulations on ballast water treatment do make mention of biofouling management.
The IMO guidelines have been picked up by several classification societies and some coatings manufacturers. Consequently, there are now a number of model biofouling management plan (BMP) templates available free of charge and ready advice on offer. A typical BMP will record details of hull coatings and provide practical guidance on measures to minimise the risk of transferring invasive species from ships’ biofouling.
That guidance would cover maintenance of anti-fouling systems and operational strategies such as matching coatings to environmental conditions likely to be encountered. A good BMP would ensure that factors such as slow steaming or long periods of inactivity are taken into account and paying particular attention to areas such as propellers, rudders, thrusters, anchors and chains, sea chests and chain lockers where conditions can permit organisms to survive for quite long periods.
Unless a vessel’s flag state or a port state declares otherwise, the guidelines are voluntary but something that a prudent ship operator should consider implementing. As well as providing practical experience for the time when regulation eventually arrives, successfully managing biofouling also has a beneficial effect on ship efficiency and thus reduces fuel bills.
New partnership heralds changes
One reason advanced for the present lack of commitment to making the guidelines mandatory is that the delays and machinations around ratification of the ballast water convention has been a factor. That may be changing, in Summer 2017 the GloFouling Partnerships project – a collaboration between the Global Environment Facility (GEF), the United Nations Development Programme (UNDP) and the International Maritime Organization (IMO) – was established.
This development mirrors events around ballast water where the 2004 convention and the framework for approving systems was driven by the GloBallast partnership. The new body will address the transfer of aquatic species through biofouling and will focus on the implementation of the IMO Guidelines.
The GEF, UNDP and IMO collaboration has already proved to be highly successful through its 3-tier (“Glo-X”) implementation model for driving legal, policy and institutional reforms, delivering capacity-building activities and encouraging technology transfer through public-private partnerships at the global, regional and national levels. The GloBallast project completed its work in 2017. The ongoing GloMEEP project is aimed at supporting the implementation of energy efficiency measures for shipping.
Efficiency standard already here
Mandatory coatings, their application and maintenance are not yet things that operators need to worry about but as from the 1 January 2013 ships have been required to implement a Ship Energy Efficiency Management Plan (SEEMP). Under IMO regulations the exact date for individual ships is the first intermediate or renewal survey after 1 January 2013 and so with a very few exceptions most ships should now have a SEEMP in place.
Since hull fouling has an obvious detrimental effect on a ship’s efficiency it is evident that the matter of anti-fouling should be covered in its SEEMP. Taking voluntary action on biofouling is something that many operators do as a matter of course could but formalising procedures could make a ship more attractive to potential charterers and an obvious concern for environmental matters is likely to influence official inspectors in a positive way.
The various claims made by makers of hull coatings with regard to performance and fuel saving potential have long been treated with some jaundiced suspicion by operators and with no universal method for measuring the savings achieved this is understandable.
However, the development of ISO 19030 as a new standard for Measurement of changes in hull and propeller performance is considered a major step forward. This standard complements ISO 15016 (for sea trials) focussing on in-service monitoring. ISO 19030 uses a 3-tiered approach, reflecting different levels of accuracy.
ISO 19030 was finalised in 2016 following three years of development by a wide range of industry stakeholders including coating and propeller manufacturers, academics, ship owners and data analysts. It became effective in March 2017 and enables ship owners and operators to compare hull and propeller solutions, and select the most efficient option for their vessels and fleets.
As well as outlining general principles for the measurement of changes in hull and propeller performance, the standard also defines a set of performance indicators for hull and propeller maintenance, repair and retrofit activities. It is not mandatory and for it to apply to any product, the ship operator must establish a monitoring regime which may well deter many operators from making use of the standard.
The general principles outlined and performance indicators defined are applicable to all ship types driven by conventional fixed pitch propellers, where the objective is to compare the hull and propeller performance of the same ship to itself over time. Support for additional configurations such as variable pitch propellers or podded propulsion systems will, if justified, be included in later revisions.
Every shipowner should know that ballast tanks have historically proven a troublesome part of the ship to maintain and also that any failure in their structure can have catastrophic results. Any movement of the ship can start a scouring process inside the tank by the sand and sediments taken in during ballasting. Cleaning and coating of tanks was most often carried out more to meet cost and time limits rather than to a high standard. Inspection of ballast tanks during construction, repair and in service was also often a cursory process and the standard of training sometimes such that difficult to spot deficiencies were overlooked.
As work at the IMO on the 2004 ballast water treatment convention was coming to a close attention there, and in IACS, turned to addressing the issues of ballast tank coatings. In 2006 at MSC82 the IMO adopted Resolution MSC.215(82) Performance standard for protective coatings of dedicated seawater ballast tanks on all new ships and of double-side skin spaces of bulk carriers, which was made mandatory by way of amendments to SOLAS regulations II-1/3-2, also adopted at the session.
The amendments subsequently entered force in 2008 and applied to newbuild contracts from that date. As from July 2012 most vessels delivered are covered by the new standards. The resolution title is generally referred to in abbreviated form as PSPC. Existing ships built before 2008 and those contracted before then but commenced later are not covered by the regulation.
Four years after the PSPC for ballast tanks was adopted by the IMO, a similar regulation was adopted to cover the cargo tanks of crude oil tankers. It would appear that the move was necessary due to the move from single-hull to double-hull crude oil tankers. The phenomenon of accelerated corrosion in cargo oil tanks had begun to be investigated in the mid to late 1990s when double-hull tankers became common.
A 1997 report by OCIMF suggested that in addition to the more conventional corrosion mechanisms, a possible contributory cause of accelerated corrosion has been microbial attack from bacteria in the cargo oil. It would appear that, as crude oil is often loaded at temperatures higher than ambient air and sea temperatures, during the loaded passage the temperature of the cargo tank structure is being maintained at higher levels than normal due to the insulating effect of the double hull spaces.
A new SOLAS Regulation II-1/3-11, which entered into force on 1 January 2012, on corrosion protection of cargo oil tanks of crude oil tankers, requires cargo oil tanks to be protected against corrosion and makes IMO Resolution MSC.288(87) Performance Standard for Protective Coatings for Cargo Oil Tanks of Crude Oil Tankers mandatory.
Health and safety
All coatings products contain substances known as volatile organic compounds (VOCs) which are released into the atmosphere during application and curing of the coating. The level of VOCs is frequently controlled by local regulations particularly in the developed world and places such as shipyards may be subject to inspection to ensure rules are being adhered to.
In most instances this will be a matter for the contractor and not the ship operator to concern themselves with. However, VOCs present both a health and fire risk and should be taken into consideration when crew are carrying out any repair and maintenance to coating systems. A prudent operator would include the risk assessment in its ISM procedures and should ensure that any other hazards associated with any particular product are identified from the maker’s material safety data sheets (MSDS) or other issued safety advice.
There are other safety issues for an operator to consider when crew are tasked to work on coatings. These include use of PPE and more generally applying safe practices for working at heights, overside and in enclosed spaces.
More safety related coating issues were highlighted by an announcement by the London P&I Club in October 2016. These include a lack of anti-skid deck paint in key areas, a lack of hazard marking of protruding objects and platforms, and low awareness of the dangers of snap-back zones.
The club recommends that ships’ officers conduct a risk assessment of their mooring stations to establish the best location for anti-skid areas, and the use of a prescribed additive to the deck paint, which can usually be found in the ship’s coating technical file. Good surface preparation is essential to a long life, says the club, as it is believed that 70% of premature coating breakdown on ships is attributable to poor surface preparation.
The club emphasises that hazard markings make trip hazards more visible, and says officers should also not overlook dangers at head height when conducting a risk assessment of a mooring station.
Poor awareness of snap-back zones, meanwhile, continues to feature as a regular negative finding on club inspections. The latest (2015) edition of the Code of Safe Working Practices for Merchant Seaman makes clear reference to a particular industry-wide confusion over the area of snap-back zones being marked on the deck. It states, ‘The painting of snap-back zones on mooring decks should be avoided because they may give a false sense of security’.”