Updated 17 Oct 2019
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 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 issued EPC.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 are no Federal US regulations on the issue – although the USCG regulations on ballast water treatment do make mention of biofouling management.
Australia and New Zealand also have local regulations and some ships have already fallen foul of these rules. In at least two cases, ships were either prevented from entering New Zealand waters or were required to move after having arrived and their biofouling management found to be deficient. The ships were not allowed to return until their hulls were declared sufficiently free of fouling. No financial penalties were imposed by the authorities, but the operational costs associated with use of divers, cleaning of the hull and delays were substantial.
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 along with ready advice. 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, 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 are something that a prudent ship operator should consider implementing.
As well as providing practical experience for the time when global regulation eventually arrives, successfully managing biofouling also has a beneficial effect on ship efficiency and thus reduces fuel bills.
The GloFouling Partnerships project
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 IMO – was established.
This development mirrors events around ballast water where the 2004 convention and the framework for approving systems were 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 three-tier implementation model (termed ‘Glo-X’) 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 when the Ballast Convention came into effect and the ongoing GloMEEP project is aimed at supporting the implementation of energy efficiency measures for shipping.
In November 2018, 12 countries were selected to spearhead the work of the GloFouling project: Brazil, Ecuador, Fiji, Indonesia, Jordan, Madagascar, Mauritius, Mexico, Peru, the Philippines, Sri Lanka and Tonga. The GEF is providing a $6.9M grant to deliver a range of governance reforms at national levels, through numerous capacity-building activities, training workshops and opportunities for technology adoption to help address the issue of invasive species.
Strong participation from private sector stakeholders is also expected. While the IMO will focus on shipping, UNESCO’s Intergovernmental Oceanographic Commission (IOC) will join the three main partners to lead the approach to other marine sectors with a view to developing best practices that may address the transfer of invasive aquatic species through improved biofouling management.
IOC-UNESCO is working with the GloFouling project to increase awareness of this environmental challenge among key stakeholders. The World Ocean Council (WOC) has been selected to engage and channel the participation of private sector companies for the development of best industry practices in non-shipping sectors such as aquaculture and oil and gas extraction.
In October 2019, an IMO-GloFouling R&D Forum was held in Melbourne aimed at bringing together regulatory bodies, stakeholders and representatives from shipping and other maritime industries, academia, leading scientific experts and technology development leaders in the field of biofouling management for a comprehensive overview of research and development and technology commercialisation.
This first edition of the IMO-GloFouling R&D Forum was described as an opportunity to discuss the main aspects of biofouling management in shipping just before the review of the IMO Biofouling Guidelines commences in early 2020.