World Coatings Council Marine Coatings Update

Antifouling Coatings Committee (AFCC)

The World Coatings Council’s AFCC monitors regulatory activities affecting antifouling coatings and active substances in countries and regions throughout the world, including the United States, Canada, Europe, Japan, Australia, New Zealand, and countries in South America, Central America, and Asia. AFCC is also tracking activities related to the IMO’s AFS Convention, Biofouling Guidelines, and Marine Plastic Litter.

IMO Biofouling Guidelines & In-Water Cleaning Standards

From 2021-2023, the World Coatings Council assisted in the review and revision of the IMO’s Biofouling Guidelines. The council submitted comments and input related to the effectiveness of the guidelines and best practices, available technologies, and techniques. Several of the council’s recommendations were included in the updated guidelines that were approved at MEPC 80 in July 2023.

During the review, a controversial issue was identified with one important aspect of the biofouling guidelines: in-water cleaning. MEPC recommended that an additional correspondence group should be established to develop associated guidelines for in-water cleaning systems. At PPR 11, the World Coatings Council participated in a drafting group that developed the terms of reference for the correspondence group. The World Coatings Council will participate in this new correspondence group to ensure that industry’s input is fully considered.

World Coatings Council AFS Convention Decision Criteria Paper & Advocacy

In addition to its active involvement in IMO working groups, the World Coatings Council also submitted a working paper to the IMO in 2021 (MEPC 76/13). This paper outlines a set of recommendations and specific risk assessment criteria to support the decision-making process for adding an anti-fouling system to Annex 1 to the AFS Convention. For context, the AFS Convention allows substances to be banned through an amendment to Annex 1. For this decision to be reached, WCC believes that a comprehensive risk assessment should be conducted. This should be achieved by using scientific techniques to analyze the hazards, potential for exposure, and adverse effects caused by specific contaminants. Although the AFS Convention contains all necessary elements to allow for a risk assessment to be conducted, specific methodology or criteria are not provided.

In MEPC 76/13, WCC describes various elements that industry believes the IMO should take into consideration before a decision is made to add a substance to Annex 1 of the AFS Convention. These elements include (but are not limited to):

• Data gathering, quality, and relevance
• Protection levels and goals
• Diffuse sources
• Hazard identification and relevant (eco)toxicological endpoints
• Exposure modelling, monitoring, and estimation
• Risk/benefit analysis

Recognizing that new output proposals need to be submitted by a member state, WCC is hoping to work with interested delegations on a submission to MEPC 82 in September/October 2024 to begin the process for a new output. WCC’s goal is to use the information in MEPC 76/13 as a basis for a collaborative effort with IMO, NGOs, and member states to develop a fundamental list of specific risk assessment criteria to be addressed under the AFS Convention.

Regional Updates

The World Coatings Council is also monitoring the following regulatory activities affecting marine coatings and active substances throughout the world:
• EU Biocidal Products Regulation (BPR) registration and approval process
• Washington State’s review of copper-based antifouling coatings, non-copper biocidal antifouling coatings, and biocide free marine coatings
• Korea toxic classification of biocides under K-REACH
• Lead paint restrictions in Australia, New Zealand, and Brazil (AFS exemption)
• Malaysia antifouling paint registration process

GloFouling Partnerships Project

The World Coatings Council continues to be a strategic partner to the GloFouling Partnerships project. The project is a collaboration between the Global Environment Facility (GEF), the United Nations Development Program (UNDP), and IMO. The project is intended to help protect marine ecosystems from the negative effects of invasive aquatic species — or biofouling — via ship hulls. The GloFouling Partnerships project focuses on preventing the transfer of aquatic species through biofouling.

In its strategic partnership role, WCC will continue to support this important initiative to help advance its goals. Notably, the council plans to get involved in the GloFouling Project’s training courses in lead partnering countries and participate in the 3rd GloFouling R&D Forum and Exhibition on Biofouling Prevention and Management in November 2024. The revised work plan and timeline to achieve the project’s objectives is May 1, 2025.

Marine Coatings Technical Committee (MCTC)

MCTC continues to engage at the IMO, primarily on matters related to ballast tank coatings and the Performance Standard for Protective Coatings (PSPC). In particular, the IMO’s International Convention for the Control and Management of Ships Ballast Water and Sediments (Ballast Water Convention) has triggered the requirement that vessels install compliant ballast water treatment systems. These new ballast water treatment systems pose challenges to ballast tank coatings due to more aggressive active substances that are employed in these systems (e.g., chlorine).

As a result of this regulatory change, the committee has closely evaluated existing test method criteria for coatings performance in conjunction with NACE International (now AMPP) and the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), which is an advisory body to the United Nations system on marine environmental protection.

MCTC Ballast Tank Coatings Testing Project

To support its evaluation of the impact of the new ballast water regulations, MCTC conducted an extensive program of laboratory testing intended to determine whether these more aggressive ballast water management treatment systems increase the potential for coatings adhesion failure in ballast water tank coatings approved under the PSPC. The goal was to determine whether those substances have a deleterious effect on coatings that are applied to ballast tanks.

To ascertain whether there are any adverse effects, MCTC developed a test protocol and set of “pass/fail” criteria and decided to conduct more extensive testing on ballast water tank coatings. The General Society of Surveillance (SGS) conducted this testing on treated and non-treated ballast water tanks that contain shop primer. After SGS issued the final reports for Systems 1, 2, 3, and 4, MCTC analyzed the results and various data points. The committee determined that the current test method criteria is fit for purpose and should not be modified based on its findings. However, MCTC will continue to evaluate the current test method criteria in NACE TM0112. The possibility of petitioning the Association for Materials Protection and Performance (AMPP, formerly NACE) to modify its test method criteria is still an option.

MCTC will continue to monitor activity surrounding IMO’s PSPC for ballast water tanks, as well as the development and adoption of performance standards around the world and their potential impact on marine and protective coatings. MCTC will also track the IMO’s potential re-evaluation effort of the PSPC.