FEEDBACK FORM
Antifouling paints reassessment
Send completed form to us by Friday, 20 July 2012 by post to: Environmental Protection Authority, Private Bag 63002,
Wellington 6140 OR email to: reassessments@epa.govt.nz; OR fax to Reassessments on 04 914 0433
To carry out a comprehensive reassessment of biocides used in antifouling paints, we need to evaluate the risks
and benefits, including the availability of alternative products.
Our preliminary risk assessment has:

identified the risks posed to human health and the aquatic environment by biocides used in antifouling paints

identified some of the main benefits provided by antifouling paints

shown that some biocides may require additional controls on their use to manage the risks. Other biocides may
pose a sufficiently high risk to human health and/or the aquatic environment to warrant a phasing out their use
from the New Zealand market.
The results of our assessment and our possible risk management options are preliminary. Amendments may be
made to them in the formal reassessment application as a result of information we receive from stakeholders.
Feedback about the benefits of antifouling paints is crucial, particularly those that have been shown to
pose the highest risks to human health and/or the aquatic environment. We also need information about
the practicality and costs of the possible risk management options.
We are also seeking technical feedback on the assumptions and methodology we have used.
This feedback form contains questions that are divided into three stakeholder groups – users, manufacturers and
importers, and government agencies. Please complete the section most relevant to you as comprehensively as
possible. We encourage you to provide additional comments and supporting information, as well as answering
questions in any of the other sections.
Confidential information
Information provided as part of this questionnaire is collected by the EPA for the purpose of ascertaining risks and
benefits of antifouling paints use. The information will be aggregated and it is not our intention to publicly release
the information provided to us. However, information you provide in this questionnaire is subject to potential
disclosure under the Official Information Act 1982 (OIA). Commercially sensitive information should be marked as
such and may be withheld in the event of an OIA request.
www.epa.govt.nz
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Antifouling paints reassessment Feedback Form
The EPA may withhold information under the OIA if there is “good reason” to withhold it, such as commercial
sensitivity, privacy or protection of trade secrets, provided that the withholding of the information is not outweighed
by other considerations which render it desirable, in the public interest, to make the information available. Grounds
that are considered a “good reason” to withhold information can be found in sections 6, 9 and 18 of the OIA.
To answer these questions fully, you will need to refer to the Call for Information document and the
Preliminary Risk Assessment document that can be downloaded from our website at:
http://www.epa.govt.nz/publications-resources/topics/Pages/Antifouling-paints.aspx.
You can complete this feedback form by downloading it to your PC, typing your responses directly into it and
attaching it to an email. Or, you can print it and post or fax it to us.
Please insert additional pages where necessary.
You can email us at reassessments@epa.govt.nz or call Jo on 04 918 4822 if you have any questions or need
further information.
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Antifouling paints reassessment Feedback Form
Stakeholder group 1: Boat owners, marina operators, professional
applicators and other users
1. Please identify which antifouling paints from Table 1 (refer to Call for Information document,
pages 5-6) you use and why you use them.
Product trade name
Reason for use
2. The main benefits of preventing biofouling are listed on page 14 of the Call for Information
document are common to all antifouling paints. What other specific benefits do you receive from
the active ingredient/ antifouling paint that you use?
Active ingredient/antifouling paint
Benefit
3. For each possible risk management option listed in Table 3 (Call for Information document, page
13) please tell us what impact they would have on your use of antifouling paints e.g. are they
practical, feasible, enforceable? Will they lead to an increase/decrease in your costs?
Proposed risk management option
Impact
4. If you use antifouling paints that contain any of the biocides chlorothalonil, diuron, Irgarol or
ziram, (Call for Information document, page 11), and a phase out is indicated, what alternative
products would you use and why?
Alternative product
Reason
5. For the products you have listed in question 4 above, how effective are they compared to the
antifouling paints that you currently use? Consider differences in cost, efficacy, application etc.
Product
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Effectiveness of alternative
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Antifouling paints reassessment Feedback Form
Stakeholder group 2: Importers and manufacturers
6. Please identify which of the antifouling paints listed in Table 1 (Call for Information document,
pages 5-6) you import/manufacture, and explain what commercial benefits they provide to you
and what efficacy benefits they provide to your customers.
Product trade name
Benefits to you
Benefits to customers
7. If the biocides chlorothalonil, diuron, Irgarol and ziram were no longer available for use in
antifouling paints, what would the impact on your business be?
Area of business
Impact on business
8. What product/s would you market to replace those containing any of the biocides mentioned in
question 7 above? What would be the overall difference in cost to your business to do this? How
long would it take to implement this change?
Current
biocide/paint
Replacement biocide/paint
Cost difference
Implementation
chlorothalonil
diuron
ziram
Irgarol
9. Please provide detailed information about how each possible risk management option in Table 3
(Call for Information document, page 13) would impact your business. Consider their
effectiveness, practicality, enforceability and any compliance costs you would incur.
Control
Impact
10. If you have any further comments about any aspect of our risk assessment and possible risk
management options that are not covered by these questions, please provide them below (refer
to both the Call for Information and Preliminary Risk Assessment documents).
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Antifouling paints reassessment Feedback Form
Stakeholder group 3: Government agencies
11. Would any of the possible risk management options listed in Table 3 (Call for Information
document, page 13) create regulatory duplications with controls already covered by other
agencies/legislation? Please provide details.
12. Do you think the possible risk management options are practical and enforceable? Please
provide evidence to support your response.
13. Would any of the possible risk management options create any additional costs for government
agencies to ensure compliance? Please specify what the costs would be and who they would
affect.
14. Please provide further comments about any aspect of our risk assessment and possible risk
management options that are not covered by your responses to the questions above.
Technical feedback
We are also seeking technical feedback on the scenario assumptions, risk assessment methodology and data gaps in our risk
assessments.
Importers and manufacturers
15. Our risk assessment has based some assumptions solely on dermal absorption values for the
individual biocide, not the formulated paint (Preliminary Risk Assessment document, Sections
2.4 and 3.1.8). Please provide any information/results you have about dermal absorption values
for the paints you manufacture/import.
Formulated paint
Dermal absorption results
16. To calculate the risks posed to human health, we used specific concentrations of each biocide in
each formulated paint (Preliminary Risk Assessment document, Section 3.1). Do you
agree/disagree with the concentrations? Please provide information to support your comment.
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Antifouling paints reassessment Feedback Form
17. To accurately predict the concentrations of biocides in the environment, we need realistic
information about the market share values for all antifouling paints you manufacture/import.
Where possible, please provide this information.
Users
18. We have assumed that when antifouling paints are applied by spraying, there are two tasks
performed by two different operators involved in the process: Mixing and loading performed by
an ancillary operator, and spraying by another operator (Preliminary Risk Assessment document,
Section 2.1). Is this assumption correct for New Zealand conditions? If not, please provide more
details regarding this type of paint application, explaining in detail the roles of the operator(s).
19. We have assumed that a user is exposed to antifouling paint for the following durations during
different stages of the application process (Preliminary Risk Assessment document, Section 2.4):
 180 minutes/day for brush and roller, and mixing/loading activities
 300 minutes/day for high-pressure spraying
Do these exposure times accurately reflect your use? If not, please provide any additional
information about how they differ.
20. Please provide any further comments about any technical aspect of our risk assessment that is
not covered by your responses to the questions above or any further information that could help
us refine our risk assessment.
Contact details
We may need to get in touch with you to talk about your feedback. Please provide your contact details below.
Name:
Stakeholder Group:
Organisation:
Position held (where application):
Email:
Phone no:
June 2012