Biofouling: Countries getting tough on clean hull requirements

New requirements for managing biofouling on international vessels arriving in Australia will begin on 15 June 2022. This follows the implementation of the New Zealand Craft Risk Management Standard (CRMS) in 2018.

Biofouling

The transfer of invasive aquatic species – typically microorganisms, plants, algae and animals – to new environments via ships has been identified by the International Maritime organization (IMO) as a major threat to the world’s oceans and to the conservation of biodiversity.

The main routes for these invasive species are through ballast water transfer and biofouling. Ballast water management is now subject to international legislation through the IMO Ballast Water Management Convention, which requires most vessels to treat their ballast water.

Biofouling, which is the accumulation of unwanted biological material on submerged surfaces (e.g. the ship’s hull, sea chests, appendages etc.) is not currently subject to international legislation. This leads to some countries introducing their own domestic legislation to prevent this method of transfer and make ‘clean hulls’ a requirement for entry into their waters.

New Zealand

The Craft Risk Management Standard (CRMS) came into force on 18 May 2018. This mandatory ‘clean hull’ requirement applies to vessels entering NZ territorial waters and non-compliance can lead to expulsion.

Before entering NZ territorial waters, the operator must submit the following:

• Advanced Notice of Arrival.
• Biofouling and Ballast Water Declaration.
• Master’s Declaration.
• Verifiable evidence that one of the three management options to meet the biofouling standard have been completed:

1. Carry out hull cleaning within 30 days of arrival
2. Provide evidence of continual hull maintenance in accordance with best practice (e.g. antifouling certificate, biofouling management plan, biofouling record book, report from last hull cleaning)
3. Book an appointment to haul out a vessel at an approved facility with 24 hours of arrival

• Details about the vessel’s antifouling coating (AFC) such as date of last renewal, certificate of treatment and service life.
• Intended length of stay within NZT and the places the vessel intends to visit.
• Whether a Biofouling Management Plan (BFMP) and Biofouling Record Book (BFRB) (or any other forms of records) are kept.
• Whether the vessel has spent extensive time idle or extended periods mainly stationary in a single location.

This information is used by the Ministry for Primary Industries (MPI) to carry out a biofouling risk assessment, the rating of which determines the level of verification that MPI Quarantine Officers will carry out.

Australia

From 15 June 2022, vessel operators must provide information on the vessel’s biofouling management prior to entering Australian territorial seas. This information will need to be reported through the Maritime Arrivals Reporting System (MARS).

The information will then be used to target vessel interventions. Vessel operators will receive less intervention for biofouling if they comply with one of the following three accepted biofouling management practices:

• Implementation of an effective biofouling management plan; or
• Cleaning of all biofouling within 30 days prior to arriving in Australian territory; or
• Implementation of an alternative biofouling management method pre-approved by the Australian Government’s Department of Agriculture, Water and the Environment.

A vessel operator that has not applied one of the three accepted biofouling management practices will be subject to further questions and assessment of the biosecurity risk associated with biofouling on the vessel.

The new requirements will be phased in. From 15 June 2022 to 15 December 2023 an ‘education first’ approach will be taken. However, powers under the Biosecurity Act 2015 will be used to manage unacceptable biosecurity risks associated with biofouling.

California

The California State Lands Commission (SLC) Marine Invasive Species Program (MISP) applies to vessels 300 GT and above and are capable of carrying ballast water.

Funded through a $1,000 fee on qualifying vessel voyage arrivals, the biofouling regulations require:

• Developing and maintaining a Biofouling Management Plan
• Developing and maintaining a Biofouling Record Book
• Mandatory biofouling management of the vessel’s wetted surfaces
• Mandatory biofouling management for vessels that undergo an extended stay in the same location (45 or more days)

An Annual Vessel Reporting Form (AVRF) must be submitted once per calendar year and at least 24 hours prior to a vessel’s first arrival at a California port. The AVRF must be submitted through the web-based platform https://www.MISP.IO.

International Guidelines

The above domestic biofouling regulations are largely aligned with the IMO’s 2011 Guidelines for the Control and Management of Ships’ biofouling to Minimize the Transfer of Invasive Aquatic Species.

The guidelines provide practical guidance on measures to minimize the risk of transferring invasive aquatic species from ships’ biofouling through the implementation of biofouling management practices, including the use of anti-fouling systems and other operational management practices.

Central to this, is the ship-specific Biofouling Management Plan. This includes details of the anti-fouling systems, hull locations susceptible to biofouling, schedule of planned inspections, repairs, maintenance and renewal of anti-fouling systems, and the recommended operating conditions suitable for the chosen anti-fouling systems.

The plan should be accompanied by a Biofouling Record Book, showing details of all inspections and biofouling management measures carried out.

Find out more

The IMO guidance on biofouling

California Marine Invasive Species Program (MISP)

Australian Biofouling Regulations

New Zealand CRMS

Template for Biofouling Management Plan from the Institute of Marine Engineering, Science and Technology (IMarEST)