IMO Biofouling Guidelines

1. IMO Biofouling Guidelines • MEPC 62 to adopt the Guidelines in July 2011 • BLG 15 February 2011 will be penultimate opportunity to make comments • One difference to normal guidelines: verification process to review their success • INTERTANKO/ICS have already made substantive comments to the draft – but is there scope/justification for more?

2. IMO Biofouling Guidelines Application/Objectives • The Guidelines are intended to provide useful recommendations on general measures to minimize the risks associated with biofouling for all types of ships • To minimize 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 macrofouling.

3. IMO Biofouling Guidelines Definitions • Macrofouling [means large, distinct multicellular organisms visible to the human eye such as barnacles, tubeworms, or fronds of algae]. • Microfouling [(slime layer) means a layer of microscopic organisms including bacteria and diatoms and the slimy substances (usually extracellular polysaccharides) that they produce]. Comment/Challenge • The invasive species risk is limited/reduced with the slime layer. Important for port state to recognise difference when considering prohibition of hull management. • The treatment, management and recommendations for the two types of fouling are very different.

4. IMO Biofouling Guidelines Management Plan (1) • It is recommended that every ship should have a biofouling management plan. The intent of the plan should be to provide effective procedures for biofouling management... • ...The Biofouling Management Plan may be a stand-alone document, or integrated in part, or fully, into the existing ships’ operational and procedures manuals and/or planned maintenance systems. Comment: • Positive element remains that this can be part of the PMS and tied in with NPDES VGP

5. IMO Biofouling Guidelines Management Plan (2) • The Plan should describe the ship’s operating profile that has determined the performance specifications of the ship’s anti-fouling systems and operational practices, including: • typical operating speeds; • periods underway at sea compared with periods berthed, anchored or moored; • typical operating areas or trading routes; • planned duration between dry-dockings/slippings. Comment: • Is this information necessary and/or realistic to produce for the Plan – e.g. is it commercially sensitive, easy to produce for vessels on spot market?

6. IMO Biofouling Guidelines Record Book • It is recommended that a Biofouling Record Book is maintained for each ship. The book should record details of all inspections and biofouling management measures undertaken on the ship... • ...it may be a stand-alone document, or integrated in part, or fully, into the existing ships operational and procedures manuals and/or planned maintenance systems. Comment: • The text also suggests that the record will assist in evaluating the efficacy of the management plan by the owner/operator. Further, it ‘could’ be used by port states control to ascertain the risk the vessel poses in terms of invasive species. • Further extensive record keeping of hull management and maintenance

7. Biofouling Activities • IMO Guidelines Assessment, Review and Commentary • Providing input on current IMO Guidelines due to be completed in 2011 • Guidelines to regulations? • Maintain principle that ports MUST allow hull management operations in their waters

8. IMO Biofouling Guidelines Antifouling System Installation and Maintenance • the installation of MGPSs is encouraged • sea chests should be protected by an anti-fouling coating system Comment: • Standard practice to install MGPS on NBs? • Coating of inlet grates and internal surfaces with an antifouling system?