Revoked
by MEPC.356(78)
Resolution
MEPC.104(49)
GUIDELINES FOR BRIEF SAMPLING OF ANTI-FOULING SYSTEMS ON SHIPS
(Adopted on 18 July 2003)
THE
MARINE ENVIRONMENT PROTECTION COMMITTEE,
RECALLING
Article 38(a) of the Convention on the International Maritime Organization
concerning the functions of the Marine Environment Protection Committee
conferred upon it by the international conventions for the prevention and
control of marine pollution,
RECALLING
ALSO that the International Conference on the Control of Harmful Anti-fouling
Systems for Ships, 2001, held in October 2001, adopted the International
Convention on the Control of Harmful Anti-fouling Systems on Ships, 2001 (the
AFS Convention) together with four Conference resolutions,
NOTING
that article 11(1) of the AFS Convention prescribes that ships to which this
Convention applies may, in any port, shipyard, or offshore terminal of a Party,
be inspected by officers authorized by that Party for the purpose of
determining whether the ship is in compliance with this Convention, and that
such inspection includes brief sampling of the ship's anti-fouling system,
NOTING
ALSO that article 11(1) of the AFS Convention refers to the guidelines to be
developed by the Organization and Conference resolution 2 urges the
Organization to develop these guidelines as a matter of urgency for them to be
adopted before the entry into force of the Convention,
NOTING
FURTHER that through resolutions MEPC.102(48) and MEPC.105(49) the Organization
has developed "Guidelines for Survey and Certification of Anti-fouling
Systems on Ships" and "Guidelines for Inspection of Anti-fouling
Systems on Ships", respectively, and
HAVING
CONSIDERED the recommendation made by the Sub-Committee on Flag State Implementation
at its eleventh session,
1.
ADOPTS the Guidelines for brief sampling of anti-fouling systems on ships, the
text of which is set out in the Annex to this resolution;
2.
INVITES Governments to apply the Guidelines as soon as possible, or when the
Convention becomes applicable to them; and
3.
RECOMMENDS that the Guidelines be reviewed on a regular basis.
Annex.
GUIDELINES FOR BRIEF SAMPLING OF ANTI-FOULING SYSTEMS ON SHIPS
1.1
Article 11 of the International Convention on the Control of Harmful
Anti-fouling Systems on Ships, 2001, hereinafter referred to as "the
Convention", and resolution MEPC.102(48) Guidelines for Survey and
Certification of Anti-Fouling Systems on Ships refer to sampling as a method of
verification of compliance of a ships anti fouling system with the Convention
for inspection and survey.
1.2
The "Guidelines for Brief Sampling of Anti-Fouling Systems on Ships",
hereinafter referred to as "the Guidelines", provide procedures for
sampling to support the effectiveness of survey and inspection to ensure that a
ship's anti-fouling system complies with the Convention and thus assists:
.1
Administrations and recognized organizations (ROs) in the uniform application
of the provisions of the Convention;
.2 port State
control officers with guidance on methods and handling of brief sampling in
accordance with Article 11(1)(b) of the Convention; and
.3 companies,
shipbuilders, manufacturers of anti-fouling systems, as well as any other
interested parties in understanding the process of sampling as required in
terms of the Convention.
1.3
However, inspections or surveys do not necessarily always need to include
sampling of anti-fouling system.
1.4
These Guidelines apply to surveys and inspections of ships subject to the
Convention.
1.5
The sole purpose of the sampling activities described in the Guidelines is to
verify compliance with the provisions of the Convention. Consequently, such
activities do not relate to any aspect not regulated by the Convention, (even
if such aspects relate to the performance of an anti-fouling system on the hull
of a ship, including the quality of workmanship).
1.6
These Guidelines contain:
.1 a main body
covering aspects of general nature common to "sampling" procedures
related to the regulation of anti-fouling systems controlled by the Convention;
and
.2 appendices
describing the unique procedures associated with the sampling and analysis of
anti-fouling systems controlled by the Convention. These appendices only serve
as examples of sampling and analytical methods and other sampling methods not
described in an appendix may be used subject to the satisfaction of the
Administration or the port State, as appropriate.
1.7
For reasons including the event of other anti-fouling systems becoming
controlled under the Convention, or in the light of new experience acquired,
these Guidelines may need to be reviewed or amended in the future.
For
the purposes of these Guidelines:
2.1
"Administration" means the Government of the State under whose
authority the ship is operating. With respect to a ship entitled to fly a flag
of a State, the Administration is the Government of that State. With respect to
fixed or floating platforms engaged in exploration and exploitation of the
sea-bed and subsoil thereof adjacent to the coast over which the coastal State
exercises sovereign rights for the purposes of exploration and exploitation of
their natural resources, the Administration is the Government of the coastal
State concerned.
2.2
"Anti-fouling system" means a coating, paint, surface treatment,
surface or device that is used on a ship in order to control or prevent
attachment of unwanted organisms.
2.3
"Threshold value" means the concentration limit of the chemical under
investigation below which compliance with the relevant provisions of the
Convention may be assumed.
2.4
"Company" means the owner of the ship or any other organization or
person such as the manager or the bareboat charterer, who has assumed the
responsibility for the operation of the ship from the owner of the ship and
who, on assuming such responsibility, has agreed to take over all duties and
responsibilities imposed by the International Safety Management (ISM) Code.
2.5
"Length" means the length as defined in the International Convention
on Load Lines, 1966, as modified by the Protocol of 1988 relating thereto, or
any successor Convention.
2.6
"Tolerance range" means the numerical range added to the threshold
value indicating the range where detected concentrations above the threshold
value are acceptable due to recognised analytical inaccuracy and thus do not
compromise the assumption of compliance.
3. Personnel safety
when sampling
3.1
Persons carrying out sampling should be aware that solvents or other materials
used for sampling may be harmful. Wet paint which is sampled may also be
harmful. In these cases the material safety data sheet (MSDS) for the solvent
or paint should be read and appropriate precautions should be taken. This will
normally include the wearing of long sleeve solvent resistant gloves of
suitable impervious material - e.g. nitrile rubber.
3.2
Quantities of dry anti-fouling paint removed during sampling from ships' hulls
will normally be too small to cause significant health effects.
3.3
Access to ships to carry out sampling safely may be difficult. If a ship is
moored alongside persons carrying out sampling must ensure they have safe
access to reach the hull from e.g. platforms, crane baskets, cherry-pickers,
gangways. They must ensure that they are protected by railings or a climbing
harness or take other precautions so that they cannot fall into the water
between the quay and the ship. If in doubt a lifejacket and possibly a safety
line, should be worn when sampling.
3.4
Access to ships in dry-dock should be made by secure means. Scaffolding should
be securely constructed and cherry-pickers or dock-arms should be properly
constructed and maintained if they are to be used to gain access. There should
be a system to record the presence of the inspector in the dock area, and he
should preferably be accompanied. Safety harnesses should be worn in
cherry-picker baskets, if used.
4.1
During sampling, care should be taken not to affect the integrity or operation
of the anti-fouling system.
4.2
Sampling where the anti-fouling coating is visibly damaged* or on block mark
areas on the flat bottom of the ship (where the intact anti-fouling system is
not applied) should be avoided. Sampling adjacent to or below areas where the
anti-fouling system is damaged should also be avoided. When a sample point on
the hull has been selected, any fouling present should be removed with water
and a soft sponge/cloth before taking a specimen of the anti-fouling system (to
avoid contamination of sample). Where possible, if carried out in dry-dock,
sampling should be carried out after the hull has been water-washed.
_________________
* During
in-service periods, anti-fouling coatings on ships' hulls often become damaged.
The extent of damage varies between ships and damaged areas can be visually
recognised. Typically damage can be restricted to localised areas e.g. anchor
chain damage (bow region), fender damage (vertical sides of hull), "rust
through areas" (underlying rust causing coating failure) or in some cases
be in smaller areas scattered over larger areas of the hull (usually older
ships where over-coating of original system has taken place many times).
4.3
The materials required for brief sampling methodologies should ideally be
inexpensive, widely available and therefore readily accessible, irrespective of
sampling conditions and/or location.
4.4
The sampling procedure should ideally be easily and reliably undertaken. Persons
conducting sampling should receive appropriate training in sampling methods.
4.5
The sampling method should take into account the type of anti-fouling system
used on the ship.
4.6
Specimens of paint for analysis during survey and certification can be taken
either as wet paint* from product containers, or dry paint film sampled from
the hull.
________________________
* In order to
prevent contamination, wet paint samples should be taken from a newly opened
container. Paint should be stirred to ensure even consistency before sampling
and all equipment used should be cleaned prior to use. Liquid paint samples
should be stored in appropriate sealed packaging which will not react with or
contaminate the sample. In the case of multi-component coatings (where on-site
mixing of several components is required prior to application), samples of each
component should be taken and the required mixing ratio recorded. When a sample
of wet paint is taken from a container, details of the paint should be recorded
e.g. details required for the IAFS Certificate along with a batch number for
the product.
Sampling strategy and number
of samples
4.7
The sampling strategy is dependent on the precision of the sampling method, the
analytical requirements, costs and required time and the purpose of the
sampling. The number of paint specimens taken of each sample should allow for a
retention quantity for back-up/storage in the event of a dispute. For dry
samples, triplicate specimens of paint at each sampling point should be taken
in close proximity to each other on the hull (e.g. within 10 cm of each other).
4.8
In cases where it is recognized that more than one type of anti-fouling system
is present on the hull, where access can be gained, samples should be taken
from each type of system:
.1 for survey
purposes or for more thorough inspections pursuant to article 11(2) of the
Convention, in order to verify the compliance of an anti-fouling system, the
number of sample points should reflect representative areas of the ship's hull;
and
.2 for
inspection purposes pursuant to article 11(1) of the Convention sample points
on the hull should be selected covering representative areas where the
anti-fouling system is intact. Depending on the size of the vessel and accessibility
to the hull, at least four sample points should be equally spaced down the
length of the hull. If sampling is undertaken in dry-dock, flat bottom areas of
the hull should be sampled in addition to vertical sides as different
anti-fouling systems can be present on these different areas.
4.9
The analysis of the anti-fouling system should ideally involve minimal
analytical effort and economic cost.
4.10
The analysis should be conducted by a recognized laboratory meeting the ISO
17025 standard or another appropriate facility at the discretion of the
Administration or the port State.
4.11
The analytical process should be expeditious, such that results are rapidly
communicated to the officers authorized to enforce the Convention.
4.12
The analysis should produce unambiguous results expressed in units consistent
with the Convention and its associated Guidelines. For example, for organotin,
results should be expressed as: mg tin (Sn) per kg of dry paint.
NOTE:
Compound-specific
sampling and analytical methodologies are described in the appendices to these
Guidelines.
5. Thresholds and
tolerance limits
5.1
The analysis should be quantitative to the point of being able to accurately
verify the threshold limits within the given tolerance.
5.2
In cases where compliance with acceptable limits, or lack thereof, is unclear,
additional sampling or other methodologies for sampling should be considered.
5.3
Statistical reliability for each (compound-specific) brief sampling procedure
should be documented. The analysis should be quantitative to the point of being
able to accurately verify the threshold limits within the given tolerance. On
the basis of these data a compound-specific tolerance range should be derived and
stated compound-specific in the method description. In general, the tolerance
range should not be higher than the standard deviation under typical conditions
for testing and should under no circumstances go beyond 30 %.
6.1
Compliance with Annex 1 of the Convention is assumed if the anti-fouling system
contains organotin at a level which does not provide a biocidal effect . In
practice organotin compounds should not be present above 2,500 mg organotin
(measured as Sn) per kg of dry paint.
6.2
Compliance is largely dependent on the results of sampling and subsequent
analysis. As every method of sampling and analysis has its specific accuracy, a
compound-specific tolerance level may be applied in borderline cases with
concentrations very close to the threshold level.
6.3
In general, compliance is assumed when the samples yield results below the
threshold value.
7. Documentation and
recording of information
7.1
The results of the sampling procedure should be fully documented on a
method-specific record sheet. Examples are provided in the appendices to these
Guidelines.
7.2
Such record sheets should be completed by the sampler and should be submitted
to the competent authority of the Port State or Administration.
Appendix.
POSSIBLE METHODS FOR BRIEF SAMPLING AND ANALYSIS OF ANTI-FOULING SYSTEMS ON
SHIPS - ORGANOTIN -
1. Purpose of this method
concerning brief sampling and analysis of anti-fouling systems
1.1
This method has been developed in order to describe a rapid methodology
appropriate for the identification of anti-fouling systems on ship hulls
containing organotin compounds acting as biocide. This method has been designed
such that sealers should not be affected, and any underlying anti-fouling agent
(or primer) is not taken up in the sampling procedure. The method is not
recommended for silicon-based anti-fouling systems.
1.2
This method is based on a two-step analysis. The first step detects total tin
as an indicator for organotin; the second step, detecting specific organotin
compounds, is only necessary in the case of the first step proving positive.
2. Sampling device and
materials
2.1
The sampling device is constructed in a way that only the upper layer of paint
is removed, thereby and should leave any underlying paint (sealer, primer etc.)
intact. This result is achieved through the use of a moving disk, (eccentric
rotation) which is covered by an abrasive material like quartz or glass fibre
fabric. This abrasive material has to be suitable for its use as a supporting
material for the removed paint.
2.2
The device fulfils the following requirements:
.1 the device
has to work independently from any stationary power supply. The device may be
driven by an electrical motor (battery-driven) or may be mechanically driven by
a clockwork-like spring, provided it is able to sustain the movement over the
required time period;
.2 the applied
force has to be constant during the operation, and the area for paint removal
has to be defined;
.3 the abrasive
material has to be inert against chemical solvents and acids and must not
contain more than trace amounts of tin or tin compounds; and
.4 the amount of
paint removed after a regular operation of the device has to be shown to exceed
20 mg per sample.
2.3
The device as described in the following section has been shown to be suitable
for the brief sampling procedure. Any other device may be used however,
provided such a device has proven to meet all the above-mentioned requirements.
2.4
The sampling device described here consists of a polyethylene disk, on which
fibre glass fabric can be mounted by the use of an O-ring. The disk is moved on
an eccentrically rotating axis.
3.1
The sampling procedure should be performed in the following manner:
.1 control
samples should be taken through the entire sampling and analytical process to
account for possible contamination;
.2 the mass of
the fibre glass pads is weighed with a precision of at least 1 mg. The weight
should be documented for each sample;
.3 the fabric
should be moistened thoroughly with isopropanol (0.7ml per sample) immediately
before sampling;
.4 when a sample
point on the hull has been selected, any fouling present should be removed with
water and a soft sponge/cloth before taking a specimen of the anti-fouling
system (to avoid contamination of sample). Where possible, if carried out in
dry-dock, sampling should be carried out after the hull has been water-washed;
.5 the sampling
device is then held against the surface to be sampled for a period of 5
seconds, prior to the sampling device being switched on;
.6 the sampling
device is switched on, thereby removing paint by the circular motion of the
fibre glass fabric against the surface of the ship;
.7 the sampling
device should be applied to the surface of the hull for a suitable period of
time, such that at least 20 mg of paint is taken up by the pad. As a general
rule, if the pad colour after sampling matches the colour of the hull coating a
sufficient sample has been taken;
.8 the two-step
analysis procedure requires that every sample should be taken in triplicate.
Two of the specimens should be labelled Specimen "A" and Specimen
"B". In addition a third specimen for storage/back-up should be
taken. These specimens should be taken as close to each other as possible, but
without overlap; and
.9 upon
completion of the sampling, the fibre glass fabric pads should be left to dry,
and re-weighed.
3.2
Samples should be stored in appropriate sealed packaging, which will not react
with or contaminate the sample.