Professional Skipper Magazine from VIP Publications

EPA SEEKS TO BAN ANTIFOUL PAINTS BY KEITH INGRAM I n march this year submissions closed on the "Application for the Reassessment of a Group of Hazardous Substances" APP201051 – Antifoul paints. In reading the documents it became very clear that the eco-friendly industrial bashing brigade was at work with the Environmental Protection Authority to ban the use or application of most common antifoul paints, while offering no alternative. Clearly this was not good and as such I was given reason to make the following submission which is summarised below. Hull fouling occurs throughout the marine environment and incurs a huge cost to owners in fuel and time lost. As well as the downstream impacts of repairing hull surface destruction, the blocking of sea chests, valves and cooling systems, all of which are capable of putting a vessel at risk at sea if the treatment and protection against bio-foulings remain unchecked. Add to this the further risk to our biosecurity with the unwanted importation of marine invaders, which as history will attest quickly take up residence in our pristine waters and add a further risk and cost to shipping and especially our developing aquaculture industry. In an effort to cut to the chase, speaking from experience, marine foulings fall into three catagories: • Slime – mud and dioton. • Weed. • Shell growth – oysters, mussels and barnacles. To combat or deter the growth of these organisms we use products known as "antifoul" paints, all of which must contain some form of toxin or poison of sufficient strength to counter growth. In saying this, one of the most successful and proven ingredients in antifoul paints is copper, "Cu". This is a naturally occurring mineral around our coastline and within the marine environment. Copper sheathing was first used on sailing ships, even before Captain Cook's voyages to New Zealand, to protect the sturdy wooden hulls from marine fouling and the dreaded teredo wood boring worm. Apart from the increasing number of foreign marine invaders breeching our biosecurity defences and becoming established, nothing has changed. So the use of copper or copper based products should be regarded as our first line of natural defence against bio-fouling in New Zealand waters. This brings me to our next concern and begs the question: Who says, or where is the evidence, scientific proof and justification to ban all the named recognised and accepted toxins in known use, including copper, in the listed toxins in the executive summary on page three of the Environmental Protection Authority report of January 2013? While we agree with the general concept of reassessing hazardous substances, the information relied upon would seem to be flawed, and the main influence appears to be a desire to keep up with overseas regulators rather than develop quantitative data applicable to New Zealand local conditions. The EPA discusses human health and environmental effects as being adverse effects of Anti Foul Paints, however it should be noted that the EPA admits on page 14 of the application that: "There is no epidemiological data currently available for users of AFPs." 16 Professional Skipper May/June 2013 So where is the substantive scientific data to support this application for the reassessment of antifouling paints? The document remains silent on supporting the many claims attempting to justify its release. Whilst it acknowledges this, the EPA has also failed to investigate fully the many other substances, such as solvents, which are contained in AFPs and which may also have an adverse effect on the users' health. Therefore we disagree with the EPA's conclusion on page 14 of the assessment that: "Health risks arising from the exposure to active ingredients during the removal stage of AFPs are related to the method of removal. Exposure due to removal of AFPs is generally expected to be negligible." In our experience, there are more people who remove and apply their own AFPs, many of whom end up covered in the residue of AFPs in the removal process. The same group of people also tend to apply AFPs with brush and rollers which do not pose the same risks as spraying to either themselves or to bystanders. Because AFPs must contain some form of toxin to be effective, we agree that there are some environmental risks posed by the use of AFPs, and agree in principle with attempts to control their unintended leaching into the environment. By this statement we assume that the EPA is talking about the control, collection and disposal of hull cleaning residue, sandings and scrapings. It is totally remiss of the EPA to suggest or attempt to delegate this responsibility to others In the case of the majority of haulout facilities used by small commercial and pleasure craft, we understand that most facilities now have collection areas, sand filters and traps to mitigate against the potential leaching of residue toxins into the marine environment resulting from either sanding, cleaning or the application of AFPs. We note that if the EPA is concerned about small haulout facilities which are up many of our backwaters, then it is a compliance issue to contain residue rather than introducing a blanket ban on recognised suitable products. We do not agree with the emphasis placed on marina and hardstand facilities as being disproportionately responsible for environmental risks, when the EPA cannot effect compliance over the greater marine coastal space for which it remains responsible. It is totally remiss of the EPA to suggest or attempt to delegate this responsibility to others. Diuron has been identified as an active ingredient which will be phased out in four years, yet it is an active ingredient in several products available to boat owners, such as Micron Extra and Awlcraft. We note "this biocide was tested for in Westpark's 2010 Sediment Quality Investigation for its dredging and dumping consents, which found that that it was not detected

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