Method 2
Clasification Society 2024 - Version 9.40
Statutory Documents - IMO Publications and Documents - Resolutions - Marine Environment Protection Committee - Resolution MEPC.356(78) - 2022 Guidelines for Brief Sampling of Anti-Fouling Systems on Ships - (adopted on 10 June 2022) - Annex - 2022 Guidelines for Brief Sampling of Anti-Fouling Systems on Ships - Appendix - Possible methods for brief sampling and analysis of anti-fouling systems on ships - organotin and/or cybutryne - Method 2

Method 2

1 Purpose of this method

1.1 This method provides sampling and analysis procedures to identify the presence of organotin compounds and/or cybutryne in the anti-fouling systems on ships. The method is designed such that the sampling and the first stage analysis could be carried out by ship surveyors or port State control officers (PSCOs) on the survey/inspection site, e.g. at a dry dock.

1.2 The method for organotin compounds is based on a two-stage analysis (case A under paragraph 4.6 of the Guidelines). The first stage detects total tin as an indicator for the presence of organotin and the second stage is necessary only in the case that the first stage analysis providing a positive result to detect specific organotin compounds.

1.3 The method for cybutryne analysis (case B under paragraph 4.6 of the Guidelines) is based on a one-step analysis based on the gas chromatography/mass spectrophotometry analytical method (GC/MS).

1.4 A simplified approach to detect organotin and cybutryne (case C under paragraph 4.6 of the Guidelines) is based on a one-step analysis using the gas chromatography/mass spectrophotometry analytical method (GC/MS).

2 Sampling

2.1 The sampling is carried out by using abrasive paper rubbing on the surface of the anti-fouling system. This results in collection of paint fragments of the anti-fouling system from a thin area, less than several micrometres in depth from the surface, which do not affect the coatings lying underneath such as sealers.

2.2 Abrasive paper is pasted on a disc of approximately 10 mm in diameter. Rubbing the surface of the anti-fouling system with the disc collects several milligrams of the sample on to the abrasive paper.

2.3 The sampling device consists of an electric motor, two (or three) rotating rods on each of which a disc is attached, and a battery for electric power supply. The discs are pressed on to the surface of the ship's hull by spring coils. The discs rotate counter-clockwise while the rods turn clockwise around the centre of the device. A schematic diagram is given in figure 1.

Figure 1. Schematic diagram of sampling device

2.4 A sampling point is selected such that the anti-fouling system is intact over an area of approximately 50 cm x 50 cm or more.

2.5 Depending on the substances targeted as listed in Annex 1 of the AFS Convention:

  • Case A. For the analysis of organotin only, at each sampling point, three sets of sampling, or more if necessary, should be carried out to obtain at least six specimens.

  • Case B. For the analysis of cybutryne only, at each sampling point, three sets of sampling, or more if necessary, should be carried out to obtain at least six specimens.

  • Case C. For the analysis of organotin and cybutryne, at each sampling point, three sets of sampling, or more if necessary, should be carried out to obtain at least six specimens.

2.6 The device is pressed on the ship's hull where it is appropriate to be sampled and held by hand. The electric motor is switched on to slide along the painted surface to lightly scrape off the fragments of the paint onto the abrasive paper. After the sample collection, each disc is removed from the device and stored in an inert container.

2.7 Sampling should normally be carried out with the sampling device. However, in the case that accessibility to the sampling point is poor, it is acceptable to collect samples with the discs by hand if necessary.

3 Analysis

Case A. Analysis of organotin only

3.1 The first-stage analysis

  • .1 The first-stage analysis is assumed to be carried out on the spot of the survey or inspection, e.g. dry docks and sea ports. In order to accomplish the on-site analysis, X-ray fluorescence analysis (XRF) is used in this method to detect total tin content.

  • .2 Analytical characteristics, such as detection limit and accuracy, are highly dependent on the type of the instrument, i.e. type of X-ray tube, spectrometer, optical arrangement (filters or collimators), etc. Among several types of the XRF instruments, an energy-dispersive spectrometer with a silicon drift detector (SDD), which is compact in size and able to be operated without liquid nitrogen, is preferable to the present analytical system for a field use, whereas wave-length dispersion system or solid-state detector are also available if the analysis is carried out at laboratories.

  • .3 Software customized for the tin analysis is prepared to assist the operator, who is assumed to be a ship surveyor or PSCO, to detect total tin in the specimens.

  • .4 The customized software may in advance need a calibration curve of the characteristic X-ray intensity of tin in relation to the tin content particularly in the range of 0.1 to 0.5%.

  • .5 After the preparation including the warming-up of the XRF instrument and starting-up of the computer, a specimen (sampling disc) is placed on the sample stage of the instrument. Afterwards, analysis is executed by the customized software. A single batch of analysis for one specimen normally takes five minutes and the result is shown on a display automatically.

  • 6. Since the XRF analysis does not affect any properties of the specimens, all of the collected specimens (six to nine specimens), including those for the second analysis and storage, are able to be used for this analysis.

3.2 Interpretation of the result at the first-stage analysis

  • .1 Following the procedures above, XRF data of six, or nine, specimens are obtained for each sampling point. Omitting the maximum and minimum values from the data, an average of the tin content is calculated from the intermediate values for the representing value of the sampling point.

  • .2 Compliance with the Convention is assumed when none of the tin contents (average values) from the samples do not exceed the sum of the threshold (2,500 mg per kg) and a tolerance (500 mg per kg).

  • .3 When one or more average values of samples from different sampling points do not meet the above criteria, the samples should be sent to a laboratory for the second stage analysis. Regardless of the results, it is also possible to undergo the second stage analysis when the surveyor or PSCO considers that it is necessary to do so.

3.3 Second-stage analysis

  • .1 Since the second-stage analysis provides the final and definitive results of the samples, the method should be thoroughly reviewed by experts based on scientific evidence. The following is a brief summary of a tentative methodology for the second stage analysis.

  • .2 The collected paint specimens are removed from the abrasive paper and total mass is measured with an electronic balance to an order of 0.1 mg. The specimens are hydrolysed with sodium hydroxide aqueous solution, extracted with organic solvent, and then derivatized with propylmagnesium bromide. After cleaning up the extract, analysis using high resolution gas chromatography/mass spectrometry (GC/MS) is carried out. For quantification analysis, tetrabutyl tin d36 is added as the internal standard.

  • .3 These analyses provide the data of chemical species and their content (mg per kg of the specimens). The content of organotin is obtained in a unit of mg per kg of dry paint.

Case B. For the analysis of cybutryne only

3.4 The collected paint specimens are removed from the abrasive paper and total mass is measured with an electronic balance to an order of 0.1 mg. The following procedure is proposed for determining the concentration of cybutryne:

  • .1 sample extraction using ethyl acetate with added internal standard (ametryn) using an ultrasonic bath for 15 minutes;

  • .2 centrifugation of the samples at 600 rcf for 5 minutes;

  • .3 analysis of the supernatant using high resolution capillary GC/MS, with the MS operating in SIM mode;

  • .4 quantification using reference cybutryne solutions and an internal standard normalization procedure; and

  • .5 modified GC/MS methods resulting in an expanded measurement uncertainty (k=2; 95% confidence) of 25% are acceptable.

Case C. Simplified approach to detect organotin and cybutryne

3.5 The collected paint specimens are removed from the abrasive paper and total mass is measured with an electronic balance to an order of 0.1 mg. The following procedure is proposed for determining the concentration of organotin and cybutryne:

  • .1 sample extraction using toluene with added internal standard (ametryn) using an ultrasonic bath for 15 minutes;

  • .2 addition of sodium hydroxide aqueous solution to hydrolyse the sample and to facilitate the extraction to the toluene;

  • .3 centrifugation of the samples at 600 rcf for 5 minutes;

  • .4 collection of the supernatant and derivatization with propylmagnesium bromide;

  • .5 clean-up of the extract;

  • .6 analysis of the toluene solution using high resolution capillary GC/MS, with the MS operating in SIM mode;

  • .7 cybutryne quantification using reference cybutryne solutions and an internal standard normalization procedure; organotin quantification using tetrabutyl tin d36 is added as the internal standard; and

  • .8 modified GC/MS methods resulting in an expanded measurement uncertainty (k=2; 95% confidence) of 25% are acceptable.

4 Compliance with the Convention

Case A. Analysis of organotin only

4.1 Compliance with the Convention for organotin compounds is assumed when the results from the second-stage analysis meet the following requirements at the same time:

  • .1 no more than 25% of the total number of samples yield results above 2,500 milligrams tin as organic form per kilogram dry paint (2,500 mg Sn/kg of dry paint); and

  • .2 no sample of the total number of specimens shows a concentration of tin as organic form higher than the sum of the threshold value plus the tolerance range, i.e. no sample must exceed the concentration 3,000 mg Sn/kg dry paint.

4.2 When the result does not meet the above criteria, it is interpreted to mean that organotin compounds are present in the anti-fouling system at a level where they would act as a biocide.

Case B. Analysis of cybutryne only

4.3 Compliance with the Convention for cybutryne is assumed when the results from the cybutryne analysis meet the following criterion:

  • .1 the average value of the total number of specimens shows a concentration below the threshold plus the tolerance range, i.e. 1,250 mg of cybutryne per kg of dry paint.

4.4 When the result does not meet the above criterion, it is interpreted to mean that cybutryne is present in the anti-fouling system at a level where it would act as a biocide.

Case C. Simplified approach to detect organotin and cybutryne

4.5 Compliance with the Convention for organotin compounds and cybutryne is assumed when the results from the cybutryne and organotin analysis meet the two conditions below:

  • .1 for organotin, the average value of the total number of specimens shows a concentration below the threshold plus the tolerance range i.e. 3,000 mg Sn/kg of dry paint; and

  • .2 for cybutryne, the average value of the total number of specimens shows a concentration below the threshold plus the tolerance range, i.e. 1,250 mg of cybutryne per kg of dry paint.

4.6 When the results do not meet one of the conditions above, it is interpreted to mean that organotin compounds or cybutryne are present in the anti-fouling system at a level where they would act as a biocide.

Appendix to Method 2

RECORD SHEET FOR THE SAMPLING AND ANALYSIS OF ANTI-FOULING SYSTEMS ON SHIP HULLS – ORGANOTIN COMPOUNDS AND/OR CYBUTRYNE

    Record number:
Section 1: Administration
1. Country

2. Location

3. Date

4. Reason for survey/inspection

 
5. Details of the ship

  5.1 Name of ship

  5.2 Distinctive number or letters

  5.3 Gross tonnage

5.4 Year of build
  5.5 Owner or operator of ship

  5.6 Flag State

5.7 Class of ship
  5.8 Authority of AFS certificate

  5.9 Date of issue

  5.10 Date of last endorsement

  5.11 IMO number

  5.12 Name of shipmaster

  5.13 Product name of anti-fouling system

  5.14 Name of manufacturer

  5.15 Name of shipyard where applied

  5.16 Comments

6. Inspecting official's details

  6.1 Name

  6.2 Comments

Section 2: Sampling and analysis

Case A. Analysis of organotin only

         
      Record number  
  Sampling and Stage 1 analysis (X-ray fluorescence analysis)  
  Date: Instrument I.D.    
         
Sample location Specimen I.D. Sample disc Content of tin max min Average
(mg/kg)
A A1 ☐ abrasive        
A2 ☐ metal        
A3 ☐ others       Average
A4 ☐ abrasive    
A5 ☐ metal       mg/kg
A6 ☐ others       ☐ > 2,500 mg/kg
A7 ☐ abrasive       ☐ > 3,000 mg/kg
A8 ☐ metal        
A9 ☐ others        
B B1 ☐ abrasive        
B2 ☐ metal        
B3 ☐ others       Average
B4 ☐ abrasive        
B5 ☐ metal       mg/kg
B6 ☐ others       ☐ > 2,500 mg/kg
B7 ☐ abrasive       ☐ > 3,000 mg/kg
B8 ☐ metal        
B9 ☐ others        
C C1 ☐ abrasive        
C2 ☐ metal        
C3 ☐ others       Average
C4 ☐ abrasive        
C5 ☐ metal       mg/kg
C6 ☐ others       ☐ > 2,500 mg/kg
C7 ☐ abrasive       ☐ > 3,000 mg/kg
C8 ☐ metal        
C9 ☐ others        
D D1 ☐ abrasive        
D2 ☐ metal        
D3 ☐ others       Average
D4 ☐ abrasives        
D5 ☐ metal       mg/kg
D6 ☐ others       ☐ > 2,500 mg/kg
D7 ☐ abrasive       ☐ > 3,000 mg/kg
D8 ☐ metal        
D9 ☐ others        
 
☐ Stage 2 required ☐ ___ samples out of ___ are above 2,500 mg/kg ☐ Compliant
☐ sample(s) ___ is (are) above 3,000 mg/kg
Sampled by Analysed by
Signature Signature
  Record number:
Stage 2 analysis (Gas chromatography/mass spectrometry)
Date        
Instrument I.D.
Comments on the method
Sample I.D. Specimen used Content of tin (XFR analysis) (mg/kg) Content of tin (as organotin) (mg/kg) Compliance
A       ☐ > 2,500 mg/kg
☐ > 3,000 mg/kg
B       ☐ > 2,500 mg/kg
☐ > 3,000 mg/kg
C       ☐ > 2,500 mg/kg
☐ > 3,000 mg/kg
D       ☐ > 2,500 mg/kg
☐ > 3,000 mg/kg
4. Conclusion
  ☐Not compliant ___ samples out of ___ are above 2,500 mg/kg
  sample(s) ___ is (are) above 3,000 mg/kg
  ☐Compliant      
5. Additional comments
6. Laboratory Name
7. Analysed by 8. Signature

Case B. Analysis of cybutryne only

Record number
Sampling and gas chromatography/mass spectrometry analysis
Date: Instrument I.D.
   
Sample location Specimen I.D. Sample disc Comments on the samples and sampling Comments on the sample location
procedure
A A1 ☐ abrasive    
A2 ☐ metal    
A3 ☐ others    
A4 ☐ abrasive    
A5 ☐ metal    
A6 ☐ others    
A7 ☐ abrasive    
A8 ☐ metal    
A9 ☐ others    
B B1 ☐ abrasive    
B2 ☐ metal    
B3 ☐ others    
B4 ☐ abrasive    
B5 ☐ metal    
B6 ☐ others    
B7 ☐ abrasive    
B8 ☐ metal    
B9 ☐ others    
C C1 ☐ abrasive    
C2 ☐ metal    
C3 ☐ others    
C4 ☐ abrasive    
C5 ☐ metal    
C6 ☐ others    
C7 ☐ abrasive    
C8 ☐ metal    
C9 ☐ others    
D D1 ☐ abrasive    
D2 ☐ metal    
D3 ☐ others    
D4 ☐ abrasive    
D5 ☐ metal    
D6 ☐ others    
D7 ☐ abrasives    
D8 ☐ metal    
D9 ☐ others    
   
Average concentration of cybutryne (mg of cybutryne per kg of dry paint)  
Sampled by Analysed by
Signature Signature

Case C. Simplified approach to detect organotin and cybutryne

Record number
Sampling and gas chromatography/mass spectrometry analysis
Date: Instrument I.D.
   
Sample location Specimen I.D. Sample disc Comments on the samples and sampling Comments on the sample location
procedure
A A1 ☐ abrasive    
A2 ☐ metal    
A3 ☐ others    
A4 ☐ abrasive    
A5 ☐ metal    
A6 ☐ others    
A7 ☐ abrasive    
A8 ☐ metal    
A9 ☐ others    
B B1 ☐ abrasive    
B2 ☐ metal    
B3 ☐ others    
B4 ☐ abrasive    
B5 ☐ metal    
B6 ☐ others    
B7 ☐ abrasive    
B8 ☐ metal    
B9 ☐ others    
C C1 ☐ abrasive    
C2 ☐ metal    
C3 ☐ others    
C4 ☐ abrasive    
C5 ☐ metal    
C6 ☐ others    
C7 ☐ abrasive    
C8 ☐ metal    
C9 ☐ others    
D D1 ☐ abrasive    
D2 ☐ metal    
D3 ☐ others    
D4 ☐ abrasives    
D5 ☐ metal    
D6 ☐ others    
D7 ☐ abrasives    
D8 ☐ metal    
D9 ☐ others    
 
Average content of organotin (mg of organotin per kg of dry paint)  
Average concentration of cybutryne (mg of cybutryne per kg of dry paint)  
Sampled by Analysed by
Signature Signature
Section 3: Final conclusion
1. Conclusion
  ☐ Anti-fouling system is compliant with the AFS Convention 2001.
  ☐ Anti-fouling system is NOT compliant with the AFS Convention 2001.
2. Comments  
3. Processed official  
3.1 Name 3.2 Date
3.3 Signature  
4. Authorized administrator  
4.1 Name 4.2 Date
4.3 Signature  

Copyright 2022 Clasifications Register Group Limited, International Maritime Organization, International Labour Organization or Maritime and Coastguard Agency. All rights reserved. Clasifications Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Clasifications Register'. Clasifications Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Clasifications Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.