Antifouling review by EPA

[grant 40]

Dear Madam/Sir,

 

The EPA is conducting a reassessment of all approved antifouling paints in New Zealand.

http://www.epa.govt.nz/publications-res ... aints.aspx

 

A preliminary human health and environmental risk assessment has been performed for all biocides used as active ingredients in approved antifouling paints in New Zealand:

http://www.epa.govt.nz/Publications/Ant ... ssment.pdf

 

At this stage we are seeking further information on:

the benefits of specific biocides that seem to pose a high risk to human health or the environment,

feedback on the risk management options we are considering,

technical data that could help us refine our risk assessment

any other feedback that would be helpful in performing a comprehensive reassessment of the antifouling paints

For more details on all of the above, please refer to the Call for Information document: http://www.epa.govt.nz/Publications/Ant ... mation.pdf

 

If you wish to provide feedback please use this feedback form: http://www.epa.govt.nz/Publications/Ant ... 20Form.doc

 

If you have any questions or for further information please feel free to:

 

Send us an email at reassessments@epa.govt.nz, or contact Jo Armstrong joanne.armstrong@epa.govt.nz (DDI: +0064 4 918 4822).

 

Kind Regards

 

 

Jo Armstrong

Advisor

Applications and assessment

Environmental Protection Authority · BP House · 20 Customhouse Quay

PO Box 131 · Wellington 6140 · New Zealand · www.epa.govt.nz

Tel +64 4 916 2426 · Fax +64 4 914 0433 · DDI +64 4 918 4822

[Fogg 427]

Jeez, here we go again....

 

So on the one hand we're wasting a ton of money on a review of antifouling paints - instead of tapping into what other countries have learnt and do.... but on the other hand we're one of only developed countries left in the world where you can still buy and operate a 2 stroke outboard.

[Steve Pope 243]

Any contamination from a 2 stroke outboard on a 100 to 1 mix is miniscule, the oil is doing its job lubricating the engine with bugger all escaping with the exhaust.

I hope these folk who are going to do the studies will (if they can !) show what deleterious effects (if any) the active ingredients in our existing antifoul are supposedly having. Although maybe they just might be going to say that TBT in a real use situation ain't so harmful as previously thought.

I have heard (anecdotaly) that France is reviewing the ban there.

[wheels 543]

TBT was bad stuff. i can remember when the Marina was a barren wasteland. Marinas tend to be quite a little eco system these days.

I would suggest that the Solvents are the far more nasty substances, rather than the additivesin the paint. For instance, the Zinc that many companies are adding these days is the stuff used in antidandruff shampoo. Cuprous thiocyanate is also found in toothpaste as a anti plaque coating.

[Fogg 427]

Any contamination from a 2 stroke outboard on a 100 to 1 mix is miniscule, the oil is doing its job lubricating the engine with bugger all escaping with the exhaust.

 

So why has the rest of the world banned them then?

[wheels 543]

So why has the rest of the world banned them then?

Not completley true. There was much hype made about this.I think much of it came from those selling outboards and those making 4 stroke.

In the US, it got to the extent of where some officials were banning 2stroke from certain waterways. Although in reality, that was not actually legal, but in the US, you don't always get to argue.

The EU ruling was made in 2006. But!!!

There is nothing either in the EPA, CARB or EU outboard emissions legislation that will ban the use of any outboard motor on any waterway. EPA, CARB and EU do set limits for engines to be sold by the effected date of legislation. The legislation enacted by the U.S. Environmental Protection Agency (EPA) and The California Air Resource Board (CARB) as well as EU Recreational craft directive REGULATE EMISSIONS AND NOT TECHNOLOGIES.

However since that time, manufacturers have made significant advancments in 2stroke technology and there are now engines that are direct injected and comply with the requirements.

Pre 2006 engines that did not come up to the new EU emmision regs, put a lot of oil smoke into the environment. A lot of smoke when in comparison to a new 4 stroke engine. But what is not concidered is what happens to the old engine oil when the 4 stroke sump lot needs changing. It is considered the old oil is far more detrimental to the environment that the burn't 2 stroke oil was in the air.

[Steve Pope 243]

I think wheels that the only places that were studdied re antifoul contamination were marinas. A perfect environment that really has nothing to do with a boat that is being used, any discharge of poisons being miniscule and never in a situation where they can build up compared to a marina where boats are stored and not used, hence the over representation of marine growth inhibitors in the mud and whelks etc.

I've not come across any studies done in a commercial port.

Boaties are an easy target, bit like bikies, small group, individualists, knot given to cohesive protest.

Selective data being used, rather like that being used re the Maui and Hectors dolphins, relying on emotion rather than good science.

[Bogan 8]

The punch line:

 

According to our risk assessment there is a distinct group of biocides that may pose very high risks to the

aquatic environment (chlorothalonil, diuron and Irgarol) compared to all other biocides used in antifouling

paints in New Zealand. These biocides pose significantly high environmental risks for all exposure scenarios

and some of them trigger additional concerns due to their persistence, ecotoxic metabolites, and

bioaccumulation potential. For Irgarol there are also concerns regarding its endocrine disruption potential.

According to our modeling the presence of octhilinone, Sea Nine and thiram in marinas poses very high risks

to the aquatic environment and therefore may need to be reduced. This prevention can possibly be achieved

through the prohibition of application of paints containing these actives on small vessels (

other biocides (except for chlorothalonil, diuron, and Irgarol) it is noted that at least their use on large

vessels (>25 m) can be continued as the calculated risks in the harbour aquatic environment are at relatively

low levels.

[wheels 543]

Whats the english version?

The big arsed boats get to use the good stuff (bad for environment) due to having no power to stop the big boys. The little boats (us) are banned from using anything of any notible affect because we are the only ones the organisation can flex it's muscle's at and thus justify their jobs and budget.

 

Soon we are going to be reduced to nothing more than periodicaly dipping our heads in the water and shouting Boo to scare off the growth.

[rigger 47]

Whats the english version?

The big arsed boats get to use the good stuff (bad for environment) due to having no power to stop the big boys. The little boats (us) are banned from using anything of any notible affect because we are the only ones the organisation can flex it's muscle's at and thus justify their jobs and budget.

 

Soon we are going to be reduced to nothing more than periodicaly dipping our heads in the water and shouting Boo to scare off the growth.

 

Big ships have to be certified free of TBT antifoul to comply with international convention. Wheels I have been thru this before on these forums. The commercial shipping has to comply with the TBT free rules. If you worked in the industry I work in you would see that the big arsed boats have problems with fouling, especially when they spend a lot of time at low speeds / at anchor. The big difference between most of the big arsed boats and the small recreational boats is that most of the big arsed boats are moving 50-80% (depending upon type) of the time at speeds above 10knots, not many small recreational boats spend that much time on the move.

[wheels 543]

It really was a toungue in cheek reply to motorbikes toungue in cheek cry of "in English please"

[Bogan 8]

Actually there are some somewhat promising indications in the report that the authors at least slightly understand the problem.

 

For example: of copper they find that it exceeds their preferred impact levels in at least one marina, but it is used on nearly all the boats (leading to the bigger impact) and the alternatives appear to be worse. I think their suggestion is that copper is unlikely to be banned.

 

One thing that troubles me is that the report seems entirely based on modeling not measurement. Some measurement could surely be used to validate the modeling (or not)?

[Steve Pope 243]

Also tongue in cheek, perhaps they could do their tests at all the sewerage outfalls and measure the contaminents that are coming out there, I understand that there is a very high level of estrogen recorded in the US coming from outfalls there.