Report from IPPIC AFWG
Global Marine Coatings Forum
November 7-8, 2012
Marie Hobson
Counsel, IPPIC
Overview

Background

• NGO Status and
Membership


• AFS Treaty
• Transfer of Invasive
Species
• Polar Code
Position Papers
• Zinc Oxide
• Data Protection and
Confidentiality
• Efficacy
Sub-Workgroups
• (1) Efficacy
• (2) Assessment
• (3) Performance
Standards
IMO


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ISO Standards
Chinese Green Label
California
• Biofouling Regulations
• SB 623
• Underwater Hull
Cleaning Study
Background

The International Paint and Printing Ink Council
(IPPIC) Antifouling Working Group (AFWG) was
formed to:
• Monitor activity which will, or is likely to, impact on the
regulations governing the use of antifouling products, whether such
activity is undertaken by National Governments, International
Organizations, NGOs or research institutions.
• Exchange information about such activity.
• Arrive at common positions regarding the acceptability or
otherwise of such activity, and document and distribute common
positions.
• Lobby appropriate bodies to modify regulations or proposals to be
in accordance with the Group's positions.
NGO Status and
Membership


In 2007 the IPPIC obtained NGO status at the
International Maritime Organization (IMO).
Currently the AFWG sends delegations to several
IMO committees which meet in London, England.
Membership of the IPPIC AFWG is open to all
paint companies which manufacture antifoulings
and related raw materials that are members of
their national paint maker associations, which,
either directly or via regional associations are
members of IPPIC.
AFWG Membership

FORMULATORS
• Akzo Nobel /
International Paint
• CMP
• Hempel
• Jotun
• Nippon
• NKM
• PPG
• Sherwin-Williams

SUPPLIERS
•
•
•
•
•
•
•
•
American Chemet
Bardyke
Dow
Janssen
Lanxess
Lonza
Nordox
Speiss-Urania
Position Papers available at
www.ippic.org
Position Papers on Zinc Oxide

Function of Zinc Oxide in AF Paints
• Document outlines how zinc oxide is used in AF
paints - explains the function of zinc oxide in AF
paints.
• Zinc oxide is added to AF paints to fulfill a nonbiocidal function.
• Most countries with existing registration schemes
for AF paints do not consider zinc oxide a biocide.
Regulatory Status of Zinc Oxide in
Antifouling Products


In the US, Australia, EU - zinc oxide used in nonbiocidal and biocidal coatings applied to prevent
fouling on the underwater hull of commercial vessels
and pleasure crafts.
The reasons to formulate with zinc oxide include:
• To control the paint film polishing rate
• To stabilize the wet paint in the can (prolong storage stability)
• To protect the coating film from degrading due to exposure by
ultra violet (U.V.) light
• To control the color shade (hide darker compounds and
produce lighter shades)
The Need for Data Protection and
Confidentiality



National regulatory authorities require companies to
submit data demonstrating safety, quality and efficacy
of products.
Toxicological information, eco-toxicological and
environmental fate information, physico-chemical
data, analytical techniques, efficacy demonstrations.
Rules in US and EU allow for a data protection period
- data and information supplied to authorities used
only for the benefit of those companies which have
rights to the data.
AFWG Recommendation



Data protection key to
maintain innovation in the
chemical industry - essential
if safer and sustainable
biocides and biocidal products
are to be brought to market.
Regulations in all regions
recognize the need for
investment and impose data
protection measures similar
to those in the US and EU, in
order to respect the
ownership of data.
Efficacy Data



This document provides a baseline
methodology for evaluating and reporting
the efficacy of antifouling coatings.
Efficacy is assessed by static raft testing
relative to a negative control and, if used,
a positive control coating.
Efficacy may be indicative of, but has no
direct one-to-one relationship with actual
performance of a product under real life
conditions.
Sub-WG’s to Address Efficacy,
Assessment, and Performance Standards


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(1) Guidance for generation of efficacy data for
approval under pesticide/biocidal product rules
(2) Assessment “standards” for immersed areas
of ship
(3) Performance Standards for Antifouling Paints
• GHGs
• Invasive Species
Assessment and Performance
Standards

‘Assessment Standard’
• Developing possible IPPIC position paper to describe what the
best available antifouling technology can achieve in terms of
surface condition related to fouling.

Performance Standard
• Invasive Species: A performance standard for the purpose
of assessing the risk of transferring invasive species will have
to focus primarily on fouling prevention in niche areas.
• GHG: A performance standard for the purpose of assessing
the effect of fouling on green-house gas emissions (energy
efficiency) will have to focus on the remaining parts for the
submerged outer hull.

AFWG
•AFS
•Transfer of
Invasive
Species
•Polar Code
Antifouling Systems Treaty


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The AFS, eliminated TBT (organotin) use globally,
adopted by the IMO 2001, with the United States as a
signatory.
AFS entered into force on Sept. 17, 2008.
Some 61 signatories representing 80.22 percent of
the world’s tonnage have ratified the AFS Treaty
ACA and its Marine Coatings Committee and
Antifouling Workgroup have been lobbying Congress
and the Obama Administration to ratify the treaty
since 2008, finally entered into force for the United
States on November 21, 2012.
Transfer of Invasive Species



Adopted by MEPC-62 July 2011
Coatings Industry actively encouraging the
voluntary guidelines
Guidelines to evaluate the implementation of the
guidelines - BLG 17
Polar Code - Background



Global Warming is
occurring more
rapidly at the poles
Summer Arctic sea
ice all time low
Singapore to
Hamburg via the
NE Passage will be
faster and cheaper
Polar Code


Proposed ban on all biocides in polar regions,
originally discussed at IMO DE-56
IPPIC working with Finnish delegation to define
three classes of polar vessels and AF paints that
would be prohibited/allowed
• (1) Ice Breakers
• (2) Vessels that periodically come into contact with ice
• (3) Vessels that never come into contact with ice


IPPIC position: (2) and (3) need AFs
IPPIC to participate in negotiations – BLG 17
February 2013
ISO

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Risk assessments for biocides in paint, the
paint itself containing biocides, and human
health exposure.
ISO 13073 Part-1: Published August 2012
ISO 13073 Part-2: Final Draft be send to
Secretariat December 2012
ISO13073-Part 3
Chinese Green Label



Ministry of Environmental
Protection in China
Alternatives to DDT usage in the
production of Antifouling Paint
Encourage eco-design and
promote compliance of
antifouling paint products with
relevant technical and
environmental requirements
Chinese Green Label


Despite AFWG
efforts, China
finalized (January
2012) Green Label
with problematic
levels (Pb, Tin)
final standard
released October
1, 2012
Test have to be
conducted in
Qingdao – errors
detected to date
Indicators
Limit value
VOC (g/L)
≤400 g/L
Toluene + xylene + ethylbenzene
≤25%
Benzene
≤ 0.05%
Soluble heavy metals :
Pb
≤ 90 mg/Kg
Cd
≤ 75 mg/Kg
Cr
≤ 60 mg/ Kg
Hg
≤ 60 mg/Kg
As
≤ 5 mg/Kg
Tin (total tin in dry film)
≤ 1500 mg Sn / Kg dry paint
Copper release rate
≤ 20 µg/cm²/day
DDT
≤ 1 mg/Kg
Copper Issues in California



CSLC Biofouling
Proposal
SB 623
DPR Reregistration of
Copper:
Underwater Hull
Cleaning Study
CSLC Biofouling Proposal



Rulemaking process began with
Technical Advisory Group (TAG)
meetings in 2010.
Released proposal to establish
Biofouling Regulations (Summer
2011) – aims to reduce invasive
species entering CA waters.
Proposed regulations originally
included mandatory
“performance standards” which
required all ships entering CA
waters have no more than 1%
fouling on the hull (5% niche
areas)
CSLC Biofouling Proposal



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ACA and Industry Coalition have advocated for
BATEA analysis, removal of numeric performance
standards, and alignment with IMO Guidelines.
“Presumed compliance” added to latest draft –
maintained numeric performance standard.
Lt. Governor met with CSLC staff and industry
stakeholders – advised CSLC to remove numeric
performance standards.
California law requires regulations be
promulgated within the allotted time (Dec. 31,
2012).
SB623 – California Bill Banning Copper In
AF Paint For Pleasure Craft


Introduced to develop
strategies to allow
marinas with Total
Maximum Daily Loads
(TMDLs) for copper to
meet TMDLs by 2023
ACA lobbied to eliminate
a straight ban on copper
- “trial period” use of low
leach rate AF paints
Shelter Island Yacht Basin
SB623


Bill has been deferred/dropped by
sponsor, Senator Christine Kehoe (D)
ACA submitted letter pointing out new
evidence about to come to light which
could change how copper impaired waters
are defined:
• EPA adoption of the BLM for marine waters.
• Diver study protocol requirement for re-registration of
copper in CA.

Bill will be picked back up in 2013
Underwater Hull Cleaning Study



Requirement from DPR to
re-register copper as an
approved biocide
Study seeks to improve
upon available scientific
evidence
Study to quantify the
input of copper into the
water column from inwater cleaning/scrubbing.
San Diego Harbor
Under Water Hull Cleaning Study

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Funded by copper suppliers and formulators
with registered AF products in CA.
Two types of paint: (1) epoxy-ester (2) low
leach rate ablative.
3 types of cleaning tools - Dome Method
8 test panels, 120 day field season, contracted
with US Navy in San Diego, started Aug. 13th
Results will be peer reviewed.
Questions?
mhobson@paint.org