Biofouling causes global environmental problems and some regions have already put strategies in force, warns the UK P&I Club
Biofouling “poses many challenges to the marine industry, among which the global environmental problems of invasive aquatic species (IAS) and greenhouse gas (GHG) emissions stand out.”
Those are the opening words of a report prepared for BWTT by the UK P&I Club based on advice the club first published in its Legal Update series of papers in November 2017. The research behind that was prepared by Madlene Wangrau, who was then a postgraduate researcher on a placement with the club, who said at the time that her work “suggests that 70-80% of IAS introductions occur through biofouling, and new areas are constantly being invaded.” Her work has been developed further by the club's legal team for this publication.
IAS are defined as species that may pose threats to human, animal and plant life, economic and cultural activities and the aquatic environment. Their introduction to new environments “has been identified as one of the greatest threats to the world’s freshwater, coastal and marine environments,” the club’s report said.
Although it is challenging to quantify global impacts specifically for biofouling species, the impacts of invasive species are significant. For example, the costs arising from the introduction of the zebra and quagga mussels into the US alone have been estimated at around US$1Bn per year.
Based on Ms Wangrau’s work, the club believes that the spread of IAS via ship biofouling was previously underestimated. “The problem has intensified over the last few decades due to increased traffic volume [and] studies show that biofouling species are causing enormous damage,” its report said. This damage includes not only biodiversity loss but also damage in other areas, including tourism, marine resources, property and infrastructure and human health. “The problem thus requires urgent international attention. The consensus is that the prevention of the introduction of IAS is more efficient and more economical than combating IAS,” the club’s report advised.
Hull fouling also has an impact on GHG emissions because it increases hull and propeller resistance, which in turn increases fuel consumption and GHG emissions. As a result, measures related to managing ships’ biofouling can in many cases be effective in enhancing ships’ energy efficiency.
IMO’s approach to hull fouling
Following the adoption of IMO’s Ballast Water Management Convention (BWMC), the organisation developed its 2011 Guidelines for the Control and Management of Ships’ Biofouling to Minimise the Transfer of Invasive Aquatic Species with the aim of providing a globally consistent approach to the management of biofouling.
Those guidelines “represent a decisive step towards reducing the transfer of IAS by ships but their implementation is problematic,” the UK Club’s report suggested. “Due to a mixture of technical, scientific, environmental and economic factors, the biofouling issue is more complex than most other shipping pollution issues,” it explained.
Implementing the guidelines requires enhanced awareness, technical co-operation and proper mobilisation of existing resources, it said. But since the guidelines are voluntary, “the private sector is lacking in incentives to develop innovative biofouling reduction and remediation technologies.”
To take on these challenges, IMO’s secretariat is implementing technical co-operation activities under its Integrated Technical Cooperation Programme to raise awareness of the implications of IAS carried in hull fouling and to support global implementation of the guidelines.
One initiative launched in August last year was the GloFouling Partnerships, which is a collaboration of the Global Environment Facility (GEF), the United Nations Development Programme (UNDP) and IMO. At the time of writing in February, the project was going through a detailed preparation phase before it starts work. It is designed to help developing countries minimise the impacts of aquatic biofouling by focusing on developing and strengthening institutional resources to implement the 2011 biofouling guidelines.
In the same manner as the GEF-UNDP-IMO GloBallast Partnerships, which came to an end in June 2017 after a decade of work, the GloFouling Partnerships project aims to catalyse a similar global transformation in reducing the transboundary introduction of IAS via biofouling with the additional benefit of reducing GHG emissions.
UK P&I’s approach
In its report, the UK P&I Club set out its own stance on biofouling: “the urgency of the problem is not being adequately conveyed and few incentives are being created for stakeholders to address the problem.”
It recommends to its members that they comply with IMO’s 2011 biofouling guidelines even though they are still voluntary. It described their introduction as “an important move” and said that “all stakeholders stand to benefit from better control and management of hull fouling.” It is also reminding members, particularly those whose ships will be calling at ports in regions with special biofouling requirements, to start tailoring their biofouling management plans to the specific requirements of those states.
The club also supports the GloFouling Partnerships project and is bringing its work to the attention of its members through its legal publications and loss-prevention initiatives.
Regional biofouling regulations
Some countries and regions have already set out requirements that ships must meet to reduce the impact of hull fouling on their coastal waters. In its report, the UK P&I Club provided details of actions being taken in Australia, California and New Zealand.
Australia’s Biosecurity Act 2015 applies to the shipping sector and regulates the biosecurity risks associated with goods, people and conveyances entering Australia.
Under the act, the Department of Agriculture and Water Resources is investigating new biofouling management options for ships arriving in Australian territory. At the time of writing, in February, a Regulation Impact Statement was being prepared following consultation with industries, the community and other stakeholders. The National Biofouling Management Guidelines for the aquaculture industry are designed to help shipowners and operators, and the wider maritime industry, to manage and control biofouling of ships.
As this issue goes to press in late April, a bill, the Biosecurity Amendment (Miscellaneous Measures) Bill 2017, has been introduced into Australia’s parliament that proposes changes to the Biosecurity Act 2015.
• For more information visit http://bit.ly/BWTT-AusFouling.
California’s Biofouling Management to Minimize the Transfer of Nonindigenous Species from Vessels Arriving at California Ports (Article 4.8) regulations have been effective since 1 October 2017. They apply to:
• All ships of 300 gt or above that carry, or are capable of carrying, ballast water that arrive at a Californian port.
• Ships delivered on or after 1 January 2018 and to other ships on completion of their first regularly scheduled out-of-water maintenance (ie drydocking) on or after that date.
Biofouling management requirements under the regulations include:
• Development and maintenance of a Biofouling Management Plan.
• Development and maintenance of a Biofouling Record Book.
• Implementation of mandatory biofouling management of the ship’s wetted surfaces.
• Implementation of mandatory biofouling management for ships that undergo an extended residency period.
It is possible to submit a petition for alternative methods of compliance with the requirements of Article 4.8, and the California State Lands Commission has released a guidance document to improve knowledge about the regulations and how to comply with them.
• For more information visit http://bit.ly/BWTT-CalFouling.
New Zealand’s Craft Risk Management Standard came into effect as this issue of BWTT was published in May.
Ships must arrive in New Zealand with a ‘clean hull’ which, for ships staying up to 20 days and only visiting designated ports, allows a slight amount of biofouling with additional fouling (up to 5% cover) allowed in niche and other areas.
If ships are staying for 21 days or longer, or wish to visit areas not approved as Places of First Arrival (places that are not approved ports, such as Milford Sound), the requirements are stricter. In those areas, the only biofouling that long-stay ships are allowed to have is a slime layer and gooseneck barnacles.
There are three ways that a ship can meet the requirements:
• Clean or treat their
• Maintain a clean hull through best practice maintenance.
• By applying approved treatments.
• For more information, visit http://bit.ly/BWTT-NZFouling.
US Coast Guard
Since 21 June 2012, the US Coast Guard (USCG) has required ships to have a biofouling management plan on board. This biofouling management plan may be a stand-alone document or integrated as part of the ship’s operational procedures and referenced in the ballast water management plan. If referenced as a separate plan, the fouling maintenance and sediment removal procedures should be available for inspection. It is important that these procedures and plans are specific to each ship.
A complete biofouling management plan should include the following information:
• An introduction for the ship’s crew to explain the need for biofouling management.
• Ship particulars.
• Description of the anti-fouling systems applied.
• Description of the ship’s operating profile.
• Description of the areas susceptible to biofouling and actions taken for each area.
• Description of the operation and maintenance of the anti-fouling system used.
• Safety procedures for the ship and crew.
• Record-keeping requirements.