Anti-fouling Systems—Survey and Certification

1. Anti-fouling Systems—Survey and Certification Huang Tianbing Marine Biosafety Section Bangkok, June 2009 Views expressed in this presentation are those of the author and should not be construed as necessarily reflecting the views of IMO or its Secretariat.

2. AFS—Survey and Certification • ARTICLE 10 • Survey and Certification • A Party shall ensure that its ships are surveyed and certified in accordance with regulations in Annex 4

3. AFS—Survey and Certification • Annex 4 • Surveys and certification requirements for anti-fouling systems

4. AFS—Survey and Certification Guidelines for survey and certification of anti-fouling systems on ships, adopted by resolution MEPC.102(48); Guidelines for brief sampling of anti-fouling systems on ships, adopted by resolution MEPC.104(49).

5. AFS—Survey, Certification and Inspection • Reference to: • - Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2007 (resolution A.997(25))

6. AFS—Survey and Certification • surveys of ships shall be carried out by • - an Administration nominating surveyors; or • - recognizing organizations • In every case, the Administration assumes full responsibility

7. AFS—Survey and Certification • Ships subject to survey and certification • - 400 gross tonnage and above • - engaged in international voyages • - excluding fixed or floating platforms, FSUs, and FPSOs • (annex 4, regulation 1)

8. AFS—Survey and Certification • The Administration shall establish appropriate measures for ships that are not subject to regulation 1.1 of annex 4 of the Convention, in order to ensure that this Convention is complied with (annex 4, regulation 1).

9. AFS—Survey and Certification • Types of survey • Initial survey (issuance of International Anti-Fouling System Certificate) • - newbuilding • - existing ship, before the International Anti-fouling System Certificate is issued for the first time. • Subsequent survey (endorsement on the Certificate) • - anti-fouling system is changed or replaced • may be needed upon transfer a ship to the flag of another State

10. AFS—Survey and Certification • Repairs generally do not require a survey. • Repairs affecting approximately 25% or more of the anti- fouling system, should be considered as a change or replacement of the anti- fouling system.

11. AFS—Survey and Certification • Survey procedure for Newbuilding: • The surveyor make sure that: • - a request for survey, together with ship’s data (Name of ship; Distinctive number or letters; Port of registry; Gross tonnage and IMO number), is received

12. AFS—Survey and Certification • - a declaration from the manufacturer is received, confirming that the system is in compliance with the Convention and such a declaration should provide the information on:- Type of anti-fouling system • - Name of anti-fouling system manufacturer • - Name and colour of anti-fouling system • - Active ingredient(s) and their CAS number(s)

13. AFS—Survey and Certification • Survey procedure for Newbuilding: • The surveyor should verify: • - verify that anti-fouling system specified by the documentation complies with the Convention; • - verify that anti-fouling system being applied is the same as described in the survey request

14. AFS—Survey and Certification • Survey procedure for Newbuilding • Means of verification • - checking that the product identification on anti- fouling system containers • - Sampling of the anti-fouling system (in most case, wet paint from the paint container) • - Testing of the anti- fouling system • - other checking on site

15. AFS—Survey and Certification • Survey procedure for Newbuilding • Surveys may best be carried out when ship is drydocked • Survey is to verify the compliance with the Convention only, does not cover other aspects not regulated by the Convention, such as AFS durability, corrosion prevention properties

16. AFS—Survey and Certification • Survey for existing ships • .1 AFS declared to be in compliance with the Convention • - sampling, testing or reliable documentation

17. AFS—Survey and Certification • Survey for existing ships (continue) • .2 existing AFS has been removed • verify removal, then follow the procedure for new buildings • .3 if sealer coat is to be applied • verify that the seal coat matches with specified in the request, then follow the same procedure for new buildings

18. AFS—Survey and Certification • Type Approval of anti-fouling systems • - Voluntary, not required by the Convention • - Common in classification society • “Approval of conformity with specified requirement on the basis of systematic examination of one or more specimens of a product representative of the production.”

19. AFS—Survey and Certification • Type Approval Procedure • - application by manufacturer • - assessment of type approval documentation, including quality control and assurance • - initial survey of product and production facilities, including witnessing of type tests • - assessment of survey report and type test results • - certificates retention or renew survey

20. AFS—Survey and Certification • Type Approval Procedure • Successful fulfilment of type approval process leads to issuance of Type Approval Certificate, certifying that anti-fouling system manufacturer is capable of consistently producing a product in compliance with the Convention. Each product is tested extensively to verify that it will perform reliably

21. AFS—Survey and Certification • Type Approval of anti-fouling systems • list of type approved anti-fouling systems, facilitating the ship survey process • sampling is usually not required during ship survey when anti-fouling system is type approved

22. AFS—Survey and Certification

23. AFS—Survey and Certification

24. AFS—Survey and Certification • Organotin which act as chemical catalysts • small quantities of organotin compounds acting as a chemical catalyst are allowed, provided that they are present at a level which does not provide a biocidal effect to the coating. On a practical level, when used as a catalyst, an organotin compound should not be present above 2,500 mg total tin per kg of dry paint. • (Guidelines for survey and certification of AFS on ships, appendix)

25. AFS—Survey and Certification • Example of Organotin which act as chemical catalyst • Silicone elastomer fouling control coatings are classified as biocide-free, they function purely by providing a physical effect, i.e. a ‘non-stick’ slippery surface. Silicone coating often contain organotin catalysts which are added to speed up the initial hardening (curing) of the coating film and control the type of film formed, directly after application to the vessel.

26. AFS—Survey and Certification • Organotin which act as chemical catalysts • - the AFS Convention prohibits the application of any organotin compound acting as a biocide, Organotins which act as chemical catalysts, such as dibutyl tin, are excluded from the prohibition as long as they are not used as a biocide

27. AFS—Survey and Certification • Organotin which act as chemical catalysts • - organotin compounds which act as biocides and those which act as a catalysts can be distinguished from each other by their chemical identity and quantity of the organotin compound present in the dried paint film

28. AFS—Survey and Certification • Organotin which act as chemical catalysts • - organotin compounds which act as biocides are triorganotin compounds (e.g. TBT) which are typically present at 50,000 mg/kg in the dry paint film (measured as Tin) • - organotin compounds which act as catalysts are mono- and di- substituted organotin compounds. They are present at levels below 2,500 mg/kg in the dried paint film (measured as Tin)

29. AFS—Survey and Certification • International Anti-Fouling System Certificate • Model form is contained Appendix 1 to annex 4 of the Convention • Supplemented by a Record of anti-fouling systems

30. AFS—Survey and Certification • Declaration on anti-fouling systems • Apply to ships • - 24 metres or more in length • - less than 400 gross tonnage • - engage in international voyages • - exclude fixed or floating platform, FSUs and FPSOS

31. AFS—Survey and Certification • Declaration on anti-fouling systems • - signed by owner or owner’s authorized agent • - accompanied by appropriate documentation e.g. paint receipt)

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