American Coatings Association

IPPIC Submits Paper to IMO Subcommittee


The International Paint and Printing Ink Council’s (IPPIC) Antifouling Coatings Committee has submitted a paper for consideration at the International Maritime Organization’s (IMO) Subcommittee on Pollution Prevention and Response (PPR) February 2018 meeting. The IPPIC paper asks the subcommittee to include IPPIC and its members in discussion of a proposal submitted by a number of states of the European Union to amend the IMO’s International Convention on the Control of Harmful Antifouling Systems on Ships (AFS) to include controls for cybutryne.

The global marine coatings industry has strongly supported the AFS in its role of ending the adverse environmental effects of TBT (thantributyltin) biocides and is committed to avoiding the use of compounds that, like TBT, are demonstrated to have potential long term adverse effects. The current proposal to amend the AFS convention to include controls on cybutryne will be the first time the IMO has considered expanding the AFS convention, and will potentially result in expanded comprehensive global regulation of potentially harmful anti-fouling systems.

With respect to cybutryne, the IPPIC submission noted that restrictions on the use of that biocide, particularly in coatings for pleasure craft, are already in force in many EU and non-EU countries and that, as a result, cybutryne is not as widely used in the industry as other active substances used in anti-fouling coatings. In its paper, IPPIC underscored that Annex 1 of the AFS has not previously been amended to prohibit or control anti-fouling systems other TBT biocides, and as a result, the procedures set forth in Article 6 of the AFS have not heretofore been utilized.

Article 7 of the AFS provides for the establishment of Technical Groups and provides that parties not only may participate in deliberations under the auspices of such a Technical Group, but also that they “should draw on the relevant expertise available to that Party.” While the proposal to add cybutryne to Annex 1 of the AFS was based on regulatory activity carried out in a group of member states, the AFS provides guidance for the independent review of a comprehensive proposal by the Technical Group, which permits consideration of additional data submitted by any interested entity.  IPPIC, as the key repository of relevant technical expertise, can assist any technical group or groups that may be established to study this issue.

In its submission, IPPIC stressed to the IMO that it is important to recognize the critical role organic biocides play in ensuring the production of effective biocidal anti-fouling systems. Such anti-fouling systems support the shipping industry in meeting its obligations to prevent the translocation of invasive species and support crucial IMO goals by furthering the reduction of carbon emissions through improved ship fuel efficiency.

IPPIC believes that the development of appropriate risk assessment approaches that are relevant for all Parties to the Convention will be critical to establishing a robust assessment framework that prohibits the use of compounds that demonstrate unreasonable risk of adverse effects on non-target organisms or human health such as to warrant amending Annex 1. IPPIC believes that this process should avoid the unnecessary inclusion of effective compounds that support IMO objectives established to reduce ship emissions and the translocation of invasive species.

IPPIC, through its Antifouling Coatings Committee, actively follows and contributes to the development of rules and regulations regarding anti-fouling coatings in many jurisdictions throughout the world. The marine coatings manufacturing industry’s objective is to support and comply with the AFS Convention to ensure that the benefits of using these coatings can be realized while avoiding harmful impacts on human health and the environment. Notably, ACA serves as IPPIC Secretariat.

Contact ACA’s Allen Irish for more information.