7.5 In-water cleaning can be an important part
of biofouling management. In-water cleaning can also introduce different
degrees of environmental risk, depending on the nature of biofouling
(i.e. microfouling versus macrofouling), the amount of anti-fouling
coating system residue released and the biocidal content of the anti-fouling
coating system. Relative to macrofouling, microfouling can be removed
with gentler techniques that minimize degradation of the anti-fouling
coating system and/or biocide release. Microfouling removal may enhance
a ship's hull efficiency, reducing fuel consumption and greenhouse
gas emissions. It is, therefore, recommended that the ship's hull
is cleaned when practical by soft methods if significant microfouling
occurs. In-water cleaning can also reduce the risk of spreading invasive
aquatic species by preventing macrofouling accumulation.
7.6 It may be appropriate for States to conduct
a risk assessment to evaluate the risk of in-water cleaning activities
and minimize potential threats to their environment, property and
resources. Risk assessment factors could include the following:
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.1 biological risk of the biofouling organisms
being removed from the ship (including viability of the biofouling
organisms or the ability to capture biofouling material);
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.2 factors that may influence biofouling accumulation,
such as changes to the operating profile of the ship;
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.3 geographical area that was the source of the
biofouling on the ship, if known; and
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.4 toxic effects related to substances within
the anti-fouling coating system that could be released during the
cleaning activity, and any subsequent damage to the anti-fouling coating
system.
7.7 Personnel proposing to undertake in-water
cleaning should be aware of any regulations or requirements for the
conduct of in-water cleaning, including any regulations regarding
the discharge of chemicals into the marine environment and the location
of sensitive areas (such as marine protected areas and ballast water
exchange areas). Where significant macrofouling growth is detected,
it should be removed or treated (if this can be done without damaging
the anti-fouling system) in accordance with such regulations. Where
available, appropriate technology should be used to minimize the release
of both anti-fouling coating or paint debris, and viable adult, juvenile,
or reproductive stages of macrofouling organisms. The collected material
should be disposed of in a manner which does not pose a risk to the
aquatic environment.
7.8 For immersed areas coated with biocidal anti-fouling
coatings, cleaning techniques should be used that minimize release
of biocide into the environment. Cleaning heavily fouled anti-fouling
coating systems can not only generate biofouling debris, but prematurely
depletes the anti-fouling coating system and may create a pulse of
biocide that can harm the local environment and may impact on future
applications by the port authority for the disposal of dredge spoil.
Depleted anti-fouling coating systems on hulls will rapidly re-foul.
In-water cleaning or scrubbing of hulls for the purpose of delaying
dry-dockings beyond the specified service life of the coating is,
therefore, not recommended.
7.9 Immersed areas coated with biocide-free anti-fouling
coating systems may require regular in-water cleaning as part of planned
maintenance to maintain hull efficiency and minimize the risk of transferring
invasive aquatic species. Cleaning techniques should be used which
do not damage the coating and impair its function.
7.10 Any maintenance or repair activities should
take care not to impede future in-service cleaning and/or maintenance,
e.g., care should be taken to ensure sea chest grates do not become
welded shut during repair work.
7.11 Care should be taken to ensure that any MGPSs
installed are operating effectively to prevent accumulation of biofouling.
7.12 Regular polishing of uncoated propellers
to maintain operational efficiency will also minimize macrofouling
accumulation. Uncoated propeller shafts may require cleaning at the
same time as the propeller. As a ship's routine propeller polishing
will involve the use of divers, it is recommended that this opportunity
is taken to assess sea chests, and other similar areas, for macrofouling.
7.13 Internal seawater cooling systems need to
be regularly monitored to ensure effective biofouling control is maintained.
Seawater cooling systems that operate while the ship is in port may
be vulnerable to biofouling accumulation, and should be closely monitored.
If seawater cooling systems become fouled, they should be appropriately
treated. Any discharge of treated water from internal seawater cooling
systems should be undertaken in accordance with applicable regulations.