The only specialised marine publication in Oceania that focuses on the maritime industry, from super yachts to small craft to large commercial ships, including coastal shipping, tugs, tow boats, barges, ferries, tourist, sport-fishing craft
Issue link: https://viewer.e-digitaleditions.com/i/131029
including high levels of copper, arsenic, mercury and you name it. With years of abuse Westhaven is simply not a satisfactory reference point for this situation and as such this evidence and statement of claims should be discarded. Therefore, we challenge the EPA's assumptions in regards to using Fiordland as an example for justification of its report, as it is not robust enough to withstand even a casual scrutiny. I would now like to focus on the development of AFPs. New Zealand is an island nation surrounded by water and we are a relative minnow in the world of shipping. Although it is worthy to note that 99 percent of all goods, trade and exports in and out of the country arrive or leave by ship. Antifouling paints are principally developed for international commercial shipping, whose vessels must remain fuel efficient and their AFP paint costs must also be affordable. Tributyltin based paints were banned in New Zealand in 1999, nine years before the global ban was introduced in 2008. Even today ships from third world nations are still coated in TBT paints and continue to arrive here. Sadly the EPA has no ability to effect compliance on these sinners. In Auckland alone, we have between 2200 to 2400 international ship visits per annum. Combine these visits with other port calls in New Zealand, with many ships having an average stay on our coast of up to 10 days. Any one of these large ships has greater surface area than a marina full of pleasure craft and we have no idea what toxins are being carried in their hull paint systems. We just know that most have clean bottoms and as such these paints contain a high percentage of toxins to be effective. The very toxins that are contained in the proposed phase out or banning list for New Zealand in the EPA document. Why? This raises the next question. If we go ahead and impose the proposed bans, who will effect compliance? We will still have visiting ships exposing a greater risk to our coastal and near shore waters than the entire domestic fleet. Never mind the natural runoff from both urban and rural use of these existing chemicals. Any discussion of a phase out period when we have no proven alternative is just pie in the sky, the stuff of dreamers. Irrespective of any new technology, copper is natural and remains one of the most cost effective ingredients in AFPs available, one that has durability to give a long standing means of protection and as such, we must retain the ability to use copper based products. Period! I would reiterate the importance of retaining the ability for boat owners to carry out their own annual R&M. At the Bucklands Beach Yacht Club haulout facility, we provide a cost effective facility that complies with all the current rules and RMA, because without access to such a facility, many members could not afford to remain in boating. We agree with the report that all careening grids should be banned for fouling removal, bottom paint preparation and antifouling paint application, as there is no existing paint formulation that allows for between tide applications. But would recommend that these grids not be removed by force or law as they are an important facility to do urgent hull fitment, propeller and rudder repairs. A recent NIWA survey has revealed that 69 percent of boat owners are DIY when it comes to servicing, haulout and painting of hull protective paints. At the BBYC we can confirm this trend. We also believe up to 73 percent of both recreational and small commercial craft owners are choosing, as part of cost savings, to prepare and reapply antifoul paint systems to their vessels. Therefore, we strongly oppose any suggestion for the restriction of, or placing prescriptive controls or access to quality AFPs to DIY boat owners. We would also object to the restriction in access to cost effective antifoul paint systems for the DIY user in 18 Professional Skipper May/June 2013 preference of licensed applicators only. We have no objection to some controls being placed on spray applications, but recognise that spraying is beyond most DIY capabilities. As such, we question just what is meant in the document when you suggest additional controls? The document remains silent! Just what does this mean? We ask and expect to be advised and consulted on this subject, so that we might make further comment in a timely manner before such additional controls become law. We would be very concerned if any proposed controls were to deny access for DIY applicators to quality known AFPs as this would lead to the development of pirate backyard production of AFPs. At this point it is timely to note a recent letter to the editor in Professional Skipper magazine March/April page 7, this year relating to a bygone era when DIY pirate additives were added to hull paints to boost the toxin levels. The letter speaks for itself and highlights the real risk of seeing a return to the use of DIY pirate toxin additives available from any garden centre, if the EPA were to impose restrictions on access to quality cost effective antifoul paints. It is because of this very real risk that we oppose any suggested or proposed restriction of access or use by DIY applicators using brush and roller. We also note that there are a range of health and safety rules applicable to commercial applicators of antifoul or any paint system, most around protection from dust and spray. We agree that these measures are applicable for the professional who is doing these tasks day after day. The yard has no ability and nor should they be expected to effect or police compliance on behalf of the EPA However, we do not believe that there is any need for such prescriptive rules for the DIY applicator who is using brush and roller predominently in the open air. Any DIY operator must already comply with the local rules of the yard and they must also take responsibility for his or her own actions and safety, most do. In support of this claim we note that there are no reported public health effects from these activities, other than what might be found to be associated with the DIY home renovator. Apart from advising best practices slipways or haulout yards have no authority or even ability to police application compliance other than the standard yard safety rules pertaining to yard safety, cradles, scaffold, electric tools and so on. The yard has no ability and nor should they be expected to effect or police compliance on behalf of the EPA, when they have no legal responsibilty and as such may end up liable for any ramifications resulting from any action taken on behalf of the EPA. Recommendations to controls: • We strongly recommend that the EPA step back and take a good look at what is currently happening overseas and in the international bio-fouling protection development world wide. • We recommend that instead of taking the forefront in leading when we do not know where the world's AFPs outcome may take us, that the Government and the EPA look at these world developments and adjust their review process to coincide with world trends and changes and not venture where angels fear to tread. • It is important that the domestic fleet can continue to operate on compatible footing with the international fleet in