ACA Responds to Washington State Antifouling Boat Paint Alternatives Report
September 26, 2017•
On Sept. 18, ACA sent a letter to Northwest Green Chemistry (NGC), a non-profit contracted by Washington State to prepare a Washington State Antifouling Boat Paint Alternatives Assessment Report. NGC released its draft report on Aug. 29, in which it concludes that “alternatives assessment suggest that cost effective copper-free antifouling alternatives are currently available on the market and that several of them meet or are likely to meet performance expectations with reduced impacts to human and marine health and reduced human and environmental exposure to hazardous chemicals.”
ACA’s letter took issue with the study’s findings and the methodology that NGC used.
Washington State is requiring that copper used as a biocide in anti-fouling boat paint be phased out for recreational use (vessels under 65 ft.) by 2020. NGC is supposed to finalize its report and submit it to the Washington Department of Ecology by Sept. 30.
NGC’s assessment indicates that products were evaluated and compared on several parameters, including hazard, exposure, performance, and cost and availability, and reported outcomes for each module are provided in the Assessment; and that the products that were evaluated are available in the State of Washington. However, in looking more closely at the underlying data and analysis supporting this conclusion, ACA found the Assessment provides a table showing the company and product evaluated, the manufacturers’ longevity claim, and the assessment results. These products were evaluated by a variety of means, including a review of the “San Diego (SD) report,” panel test results compiled by a trade magazine, Practical Sailor, and a variety of customer reviews. It appears from review of Table 14 that the Assessment evaluated 16 non-copper general purpose antifouling paints. From those 16, it appears that only two of the products were evaluated as “meets expectations,” with several other products characterized as “likely to meet expectations.” ACA strongly questions whether the more detailed results support NGC’s overall conclusion that “cost effective copper-free antifouling alternatives are currently available on the market.”
ACA also underscored other impacts like higher application costs, particularly for Silicone-based coatings, which require the removal of traditional antifouling paints and re-priming prior to application. These products are for professional application only and will cost more to apply due to extensive surface preparation, containment costs, and application costs. ACA highlighted that the pleasure craft market traditionally sees a significant amount of owner-applied coatings (DIY), and the significantly higher cost of professional application is not accounted for in the study.
ACA also raised concerns about the methodology employed by NGC in the study. ACA reiterated that there is little technical consensus about how to evaluate the efficacy of antifouling coating systems. As noted by one expert in this area:
Presently, the evaluation of new [antifouling] paints is conducted by paint manufacturers according to their respective protocols. The results of their evaluation are classified hence there are no objective data on the efficiency of antifouling paints. The controlled laboratory conditions during tests of AF paints do not accurately reflect those in the natural environment where biofouling occurs on ship hulls.
ACA pointed to the Efficacy Assessment Guideline of the European Chemical Agency (ECHA), which clearly states that field experiments are necessary to evaluate efficiency under natural conditions where biofouling occurs. “In fact, there is a very recent proposal to develop an antifouling efficacy test method that was recently presented to the International Standards Organization (ISO). The proposal is in the beginning stages of starting the evaluation process that would eventually lead to an ISO standard in this area.” Considering the lack of scientific consensus on efficacy evaluation, along with the anecdotal nature of on-line “customer reviews” and the lack of scientific rigor of a trade magazine’s evaluation of coatings products, ACA has significant concerns about the Assessment’s methodology and the resulting conclusion, that reasonable alternatives are available, particularly since this somewhat problematic evaluation process only identified two alternative products as meeting expectations.
ACA stated strongly that it does not concur with the overall finding of the Assessment, that there are reasonably available alternatives to coatings containing copper and, hence, no impediments to full implementation of the Washington state ban of copper biocides in 2020.