RESOLUTION MEPC.357(78)
(adopted on 10 June 2022)
2022 GUIDELINES FOR INSPECTION OF ANTI-FOULING SYSTEMS ON SHIPS
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 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,
RECALLING FURTHER 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,
NOTING that article 3(3) of the AFS Convention prescribes that
Parties to this Convention shall apply the requirements of this Convention as
may be necessary to ensure that no more favourable treatment is given to ships
of non-Parties to this Convention,
NOTING ALSO resolution MEPC.208(62) by which the Committee adopted
the 2011 Guidelines for Inspection of Anti-fouling Systems on Ships,
RECALLING FURTHER that at its seventy-sixth session it adopted amendments
to the AFS Convention to introduce controls on cybutryne through resolution MEPC.331(76),
RECOGNIZING the need for a consequential revision of the
guidelines associated with the AFS Convention due to the aforementioned
amendments,
NOTING FURTHER that through resolutions MEPC.358(78) and MEPC.356(78) the Organization adopted 2022
Guidelines for survey and certification of anti-fouling systems on ships
and 2022 Guidelines for brief sampling of anti-fouling systems on ships,
respectively, and
HAVING CONSIDERED a revised text of the Guidelines for
inspection of anti-fouling systems on ships prepared by the Sub-Committee
on Pollution Prevention and Response at its ninth session,
1 ADOPTS the 2022
Guidelines for inspection of anti-fouling systems on ships (2022
Guidelines), the text of which is set out in the annex to this resolution;
2 INVITES
Governments to apply the 2022 Guidelines when exercising port State control
inspections;
3 RECOMMENDS that
the 2022 Guidelines incorporated in the future revision of resolution A.1155(32) on Procedures
for port State control, 2021;
4 RECOMMENDS that
the Guidelines be reviewed on a regular basis;
5 REVOKES resolution
MEPC.208(62).
ANNEX
2022 GUIDELINES FOR INSPECTION OF ANTI-FOULING SYSTEMS ON SHIPS
1 INTRODUCTION
1.1 The right of the
port State to conduct inspections of anti-fouling systems on ships is laid down
in article 11 of the AFS Convention. The guidelines for conducting these
inspections are described below.
1.2 Ships of 400 gross
tonnage and above engaged in international voyages (excluding fixed or floating
platforms, FSUs and FPSOs) will be required to undergo an initial survey before
the ship is put into service or before the International Anti-fouling System
Certificate (IAFS) is issued for the first time; and a survey should be carried
out when the anti-fouling systems are changed or replaced.
1.3 Ships of 24 metres
in length or more but less than 400 gross tonnage engaged in international
voyages (excluding fixed or floating platforms, FSUs and FPSOs) will have to
carry a Declaration on Anti-fouling Systems signed by the owner or authorized
agent. Such declaration shall be accompanied by appropriate documentation (such
as a paint receipt or a contractor invoice) or contain appropriate endorsement.
2 INITIAL INSPECTION
2.1 Ships required to
carry an IAFS Certificate or Declaration on Anti-Fouling Systems (Parties of
the AFS Convention)
2.1.1 The PSCO should
check the validity of the IAFS Certificate or Declaration on Anti-Fouling
Systems, and the attached Record of Anti-Fouling Systems, if appropriate.
2.1.2 The only practical
way to apply paint to the ship's bottom (underwater part) is in a dry dock.
This means that the date of application of paint on the IAFS Certificate should
be checked by comparing the period of dry-docking with the date on the
certificate.
2.1.3 If the paint has
been applied during a scheduled dry-dock period, it has to be registered in the
ship's logbook. Furthermore, this scheduled dry-docking can be verified by the
endorsement date on the (statutory) Cargo Ship Safety Construction Certificate
or the Cargo Ship Safety Certificate (SOLAS, regulation I/12(a)(v)) and
Passenger Ship Safety Certificate (SOLAS, regulation I/7).
2.1.4 In case of an
unscheduled dry-dock period, it could be verified by the registration in the
ship's logbook.
2.1.5 It can be
additionally verified by the endorsement date on the (Class) Hull Certificate,
the dates on the Manufacturer's Declaration or by confirmation of the shipyard.
2.1.6 The IAFS Certificate
includes a series of tick boxes indicating for each of the anti-fouling
systems, describing the following situations:
.1 if an anti-fouling system controlled under
Annex 1 to the AFS Convention has not been applied during or after construction
of this ship;
.2 if an anti-fouling system controlled under
Annex 1 to the AFS Convention has been applied on this ship previously, but has
been removed;
.3 if an anti-fouling system controlled under
Annex 1 to the AFS Convention has been applied on this ship previously, but has
been covered with a sealer coat;
.4 if an anti-fouling system controlled under
Annex 1 of the AFS Convention has been applied on this ship previously, but is
not in the external coating layer of the hull or external parts or surfaces on
1 January 2023 (not applicable for organotin); and
.5 if an anti-fouling system controlled under
Annex 1 of the AFS Convention was applied on this ship prior to 1 January 2023,
but must be removed or covered with a sealer coat no later than 60 months
following the last application to the ship of an anti-fouling systems
containing cybutryne (not applicable for organotin).
2.1.7 Particular attention
should be given to verifying that the survey for issuance of the current IAFS
Certificate matches the dry-dock period listed in the ship's log(s)1
and that only one tick box is marked for each of the substances controlled
under Annex 1.
_______________
1 This provision,
regarding the matching of the survey with the dry-dock period, is not
applicable for the survey referred to in operative paragraph 4 of resolution MEPC.331(76).
2.1.8 The Record of
Anti-Fouling Systems should be attached to the IAFS Certificate and be up to
date. The most recent record should agree with the tick box on the front of the
IAFS Certificate. The issuing of the IAFS Certificate should be in accordance
with regulation 2(3) of Annex 4 of the AFS Convention.
2.2 Ships of
non-Parties to the AFS Convention
2.2.1 Ships of non-Parties
to the AFS Convention are not entitled to be issued with an IAFS Certificate.
Therefore, the PSCO should ask for documentation that contains the same
information as in an IAFS Certificate and take this into account in determining
compliance with the requirements.
2.2.2 If the existing anti-fouling
system is declared not to be controlled under Annex 1 to the Convention,
without being documented by an International Anti-Fouling System Certificate,
verification should be carried out to confirm that the anti-fouling system
complies with the requirements of the Convention. This verification may be
based on sampling and/or testing and/or reliable documentation, as deemed
necessary, based on experience gained and the existing circumstances.
Documentation for verification could be, for example, MSDS (Material Safety
Data Sheets), or similar, a declaration of compliance from the anti-fouling
system manufacturer, invoices from the shipyard and/or the anti-fouling system
manufacturer.
2.2.3 Ships of non-Parties
may have Statements of Compliance issued in order to comply with regional
requirements, for example, Regulation (EC) 782/2003 as amended by Regulation
(EC) 536/2008, which could be considered as providing sufficient evidence of
compliance for organotin compounds.
2.2.4 In all other aspects
the PSCO should be guided by the procedures for ships required to carry an IAFS
Certificate.
2.2.5 The PSCO should
ensure that no more favourable treatment is applied to ships of non-Parties to
the AFS Convention.
3 MORE DETAILED
INSPECTION
3.1 Clear grounds
3.1.1 A more detailed
inspection may be carried out when there have been clear grounds to believe
that the ship does not substantially meet the requirements of the AFS
Convention. Clear grounds for a more detailed inspection may be when:
.1 the ship is from a flag of a non-Party to
the Convention and there is no AFS documentation;
.2 the ship is from a flag of a Party to the
Convention but there is no valid IAFS Certificate;
.3 the painting date shown on the IAFS
Certificate does not match the dry-dock period of the ship;
.4 the ship's hull shows excessive patches of
different paints; and
.5 the IAFS Certificate is not properly
completed.
3.1.2 If the IAFS
Certificate is not properly completed, the following questions may be
pertinent:
.1 "When was the ship's anti-fouling
system last applied?";
.2 "If the anti-fouling system is
controlled under Annex 1 to the AFS Convention and was removed, what was the
name of the facility and date of the work performed?";
.3 "If the anti-fouling system is
controlled under Annex 1 to the AFS Convention and has been covered by a sealer
coat, what was the name of the facility and date applied?";
.4 "What is the name of the
anti-fouling/sealer products and the manufacturer or distributor for the
existing anti-fouling system?"; and
.5 "If the current anti-fouling system
was changed from the previous system, what was the type of anti-fouling system
and name of the previous manufacturer or distributor?".
3.2 Sampling
3.2.1 A more detailed
inspection may include sampling and analysis of the ship's anti-fouling system,
if necessary, to establish whether or not the ship complies with the AFS
Convention. Such sampling and analysis may involve the use of laboratories and
detailed scientific testing procedures.
3.2.2 If sampling is
carried out, the time to process the samples cannot be used as a reason to
delay the ship.
3.2.3 Any decision to
carry out sampling should be subject to practical feasibility or to constraints
relating to the safety of persons, the ship or the port (see appendix 1 for
sampling procedures; an AFS Inspection Report template for sampling and
analysis is attached to the Guidelines).
3.3 Action taken under
the AFS Convention
Detention
3.3.1 The port State could
decide to detain the ship following detection of deficiencies during an
inspection on board.
3.3.2 Detention could be
appropriate in any of the following cases:
.1 certification is invalid or missing;
.2 the ship admits it does not comply
(thereby removing the need to prove by sampling); and
.3 sampling proves it is non-compliant within
the port's jurisdiction.
3.3.3 Further action would
depend on whether the problem is with the certification or the anti-fouling
system itself.
3.3.4 If there are no
facilities in the port of detention to bring the ship into compliance, the port
State could allow the ship to sail to another port to bring the anti-fouling
system into compliance. This would require an agreement of that port.
Dismissal
3.3.5 The port State could
dismiss the ship, meaning that the port State demands that the ship leave port
- for example if the ship chooses not to bring the AFS into compliance but the
port State is concerned that the ship is leaching tributyltin (TBTs) or
cybutryne into its waters.
3.3.6 Dismissal could be
appropriate if the ship admits it does not comply or sampling proves it is
non-compliant while the ship is still in port. Since this would also be a
detainable deficiency the PSCO can detain first and require rectification
before release. However, there may not be available facilities for
rectification in the port of detention. In this case the port State could allow
the ship to sail to another port to bring the anti-fouling system into compliance.
This could require the agreement of that port.
3.3.7 Dismissal could be
appropriate in any of the following cases:
.1 certification is invalid or missing;
.2 the ship admits it does not comply
(thereby removing the need to collect proof by sampling); and
.3 sampling proves that the ship is
non-compliant within the port's jurisdiction.
3.3.8 In these cases the
ship will probably already have been detained. However, detention does not
force the ship to bring the AFS into compliance (only if it wants to depart).
In such a situation the port State may be concerned that the ship is leaching
TBTs or cybutryne while it remains in its waters.
Exclusion
3.3.9 The port State could
decide to exclude the ship to prevent it entering its waters. Exclusion could
be appropriate if sampling proves that the ship is non-compliant but the
results have been obtained after it has sailed or after it has been dismissed.
3.3.10 Exclusion could be
appropriate if sampling proves that the ship is non-compliant but the results
have been obtained after it has sailed or after it has been dismissed. Article
11(3) of the AFS Convention only mentions that the "party carrying out the
inspection" may take such steps. This means that, if a port State excludes
a ship, the exclusion cannot be automatically applied by other port States.
3.3.11 In accordance with
the Procedures for Port State Control (resolution A.1155(32), as amended), where deficiencies
cannot be remedied at the port of inspection, the PSCO may allow the ship to
proceed to another port, subject to any appropriate conditions determined. In
such circumstances, the PSCO should ensure that the competent authority of the
next port of call and the flag State are notified.
Reporting to the flag State
3.3.12 Article 11(3) of the
AFS Convention requires that, when a ship is detained, dismissed or excluded
from a port for violation of the Convention, the Party taking such action shall
immediately inform the flag Administration of the ship and any recognized
organization which has issued a relevant certificate.
4 AFS REPORT TO FLAG
STATE IN RESPONSE TO ALLEGED CONTRAVENTIONS
4.1 Article 11(4) of
the AFS Convention allows Parties to inspect ships at the request of another
Party, if sufficient evidence that the ship is operating or has operated in
violation of the Convention is provided. Article 12(2) permits port States
conducting the inspection to send the Administration (flag State) of the ship
concerned any information and evidence it has that a violation has occurred.
Information sent to the flag State is often inadequate for a prosecution. The
following paragraphs detail the sort of information needed.
4.2 The report to the
authorities of the port or coastal State should include as much as possible the
information listed in section 3. The information in the report should be
supported by facts which, when considered as a whole, would lead the port or
coastal State to believe a contravention had occurred.
4.3 The report should
be supplemented by documents such as:
.1 the port State report on deficiencies;
.2 a statement by the PSCO, including their
rank and organization, about the suspected non-conforming anti-fouling system.
In addition to the information required in section 3, the statement should
include the grounds the PSCO had for carrying out a more detailed inspection;
.3 a statement about any sampling of the
anti-fouling system including:
.1 the ship's location;
.2 where the sample was taken from the hull,
including the vertical distance from the boot topping;
.3 the time of sampling;
.4 person(s) taking the samples; and
.5 receipts identifying the persons having
custody and receiving transfer of the samples;
.4 reports of the analyses of any samples
including:
.1 the results of the analyses;
.2 the method employed;
.3 reference to or copies of scientific
documentation attesting the accuracy and validity of the method employed;
.4 the names of persons performing the
analyses and their experience; and
.5 a description of the quality assurance
measures of the analyses;
.5 statements of persons questioned;
.6 statements of witnesses;
.7 photographs of the hull and sample areas;
and
.8 a copy of the IAFS Certificate, including
copies of relevant pages of the Record of Anti-fouling Systems, logbooks, MSDS
or similar, declaration of compliance from the anti-fouling system
manufacturer, invoices from the shipyard and other dry dock records pertaining
to the anti-fouling system.
4.4 All observations,
photographs and documentation should be supported by a signed verification of
their authenticity. All certifications, authentications or verifications should
be in accordance with the laws of the State preparing them. All statements
should be signed and dated by the person making them, with their name printed
clearly above or below the signature.
4.5 The reports
referred to under paragraphs 2 and 3 of this section should be sent to the flag
State. If the coastal State observing the contravention and the port State
carrying out the investigation on board are not the same, the port State
carrying out the investigation should also send a copy of its findings to the
coastal State.
APPENDIX 1
SAMPLING
Considerations related to brief sampling may be found in section
2.1 of the Guidelines for brief sampling of anti-fouling systems on ships
(resolution MEPC.356(78)).
Any obligation to take a sample should be subject to practical
feasibility or to constraints relating to the safety of persons, the ship or
the port.
The PSCO should consider the following:
- liaise with the ship on the location and time
needed to take samples; the PSCO should verify that the time required will not
unduly prevent the loading/unloading, movement or departure of the ship;
- do not expect the ship to arrange safe access
but liaise with the ship over the arrangements that the port State competent
authority has made, for example boat, cherry picker, staging;
- select sampling points covering representative
areas;
- take photographs of the hull, sample areas and
sampling process;
- avoid making judgements on the quality of the
paint (e.g. surface, condition, thickness, application);
- the need of inviting the ship representative's
presence during brief sampling to ensure that the evidence is legally obtained;
- complete and sign the inspection report form
together with the included sampling record sheets (to be filled in by the
sampler), as far as possible, and leave a copy with the ship as a proof of
inspection/sampling;
- inform the next port State where the inspected
ship is to call;
- agree with or advise the ship on to whom the
ship's copy of the finalized inspection report will be sent in cases when it
cannot be completed in the course of the inspection; and
- ensure that receipts identifying the persons
having custody and receiving transfer of the samples accompany the samples are
filled in to reflect the transfer chain of the samples. PSCOs are reminded that
the procedures set in national legislation regarding custody of evidence are
not affected by the regulation. These guidelines therefore do not address this
issue in detail.
1 Sampling
methodologies
It is at the discretion of the port State to choose the sampling
methodology. The Guidelines for brief sampling of anti-fouling systems on
ships adopted by resolution MEPC.356(78) allow that any other
scientifically recognized method of sampling and analysis of AFS controlled
under the Convention than those described in the appendix to the Guidelines may
be used (subject to the satisfaction of the Administration or the port State).
The sampling methodology will depend, inter alia, on the surface hardness of
the paint, which may vary considerably. The amount of paint mass removed may
vary correspondingly.
Based on the onboard International Anti-fouling System Certificate
or a Declaration on Anti-fouling System, the port State competent authority
would decide if the brief sampling analysis should focus on only organotin,
cybutryne or both and apply the appropriate methodology including the number of
samples, analysis, and definition of compliance.
Sampling procedures, based on the removal of paint material from
the hull, require the determination of paint mass. It is important that
procedures used are validated, produce unambiguous results and contain an
adequate control.
The competent port State authority can decide to contract
specialist companies to carry out sampling. In this case the PSCO should attend
the ship during the sampling procedure to ensure the liaison and arrangements
mentioned above are in place.
If a specialist company is not used, the port State competent
authority should provide appropriate training to the PSCO in the available
sampling methods and procedures and ensure that agreed procedures are followed.
The following general terms should be observed:
- the PSCO should choose a number of sample
points preferably covering all the representative areas of the hull, but it is
desirable to have at least eight (8) sample points equally spaced down and over
the length of the hull, if possible divided over PS and SB (keeping in mind
that different parts of the hull may be treated with different anti-fouling
systems);
- 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);
- contamination of the samples should be
avoided, which normally includes the wearing of non-sterilized non-powdered
disposable gloves of suitable impervious material - e.g. nitrile rubber;
- the samples should be collected and stored in
an inert container (e.g. containers should not consist of materials containing
organotins and cybutryne or have the capacity to absorb organotins and
cybutryne);
- samples should be taken from an area where the
surface of the anti-fouling system is intact, clean and free of fouling;
- loose paint chips coming from detached, peeled
or blistered hull areas should not be used for sampling;
- samples should not be taken from a heated or
area where the paint is otherwise softened (e.g. heavy fuel tanks);
- the underlying layers (primers, sealers, TBT
containing AFS) should not be sampled if there is no clear evidence of exposure
of extended areas; and
- ships bearing an anti-fouling system that does
not contain cybutryne in the external coating layer are not required to be
controlled under Annex 1 of the Convention. Such ships carrying an IAFS
Certificate indicating the situation described in paragraph 2.1.6.4 of these
Guidelines should be deemed compliant with the Convention except if there is a
doubt on the validity of the IAFS Certificate.
2 Validity of the
sampling
In order to safeguard the validity of the sampling as evidence of
non-compliance, the following should be considered:
- only samples taken directly from the hull and
free of possible contamination should be used;
- all samples should be stored in containers,
marked and annotated on the record sheet. This record sheet should be submitted
to the Administration;
- the receipts identifying the persons having
custody and receiving transfer of the samples should be filled in and accompany
the samples to reflect the transfer chain of the samples;
- the PSCO should verify the validity of the
instrument's calibration validity date (according to the manufacturer
instruction);
- in cases when a contracted specialist company
is used for carrying out sampling, the PSCO should accompany its representative
to verify sampling; and
- photographs of the hull, sample areas and
sampling process could serve as additional proof.
It is also the case that sampling companies and/or procedures can
be certified.
3 Health and safety
when sampling
Any obligation to take a sample should be subject to practical
feasibility or any constraints relating to the safety of persons, the ship or
the port.
The PSCO is advised to ensure their safety taking the following
points into account:
- general requirements enforced by the terminal
or port authority and national health, safety and environmental policy;
- condition of the ship (ballast condition,
ship's operations, mooring, anchorage, etc.);
- surroundings (position of ship, traffic, ships
movement, quay operations, barges or other floating vessels alongside);
- safety measures for the use of access
equipment (platforms, cherry picker, staging, ladders, railings, climbing
harness, etc.), e.g. ISO 18001;
- weather (sea state, wind, rain, temperature,
etc.); and
- precautions to avoid falling into the water
between the quay and the ship. If in doubt, a lifejacket and if possible a
safety line should be worn when sampling.
Any adverse situation encountered during sampling that could
endanger the safety of personnel shall be reported to the safety coordinator.
Care should be taken to avoid contact of the removed paint with
the skin and the eyes, and no particles should be swallowed or come into
contact with foodstuffs. Eating or drinking during sampling is prohibited and
hands should be cleaned afterwards. Persons carrying out sampling should be
aware that the AFS and solvents or other materials used for sampling may be
harmful and appropriate precautions should be taken. Personal protection should
be considered by using long sleeve solvent-resistant gloves, dust mask, safety
glasses, etc.
Standard (and specific, if applicable) laboratory safety
procedures should be followed at all times when undertaking the sampling
procedures and subsequent analysis.
4 Conducting
analyses
The Guidelines for brief sampling of anti-fouling systems on
ships envisage a two-stage analysis for organotin analysis for both
methods presented in the appendix to the Guidelines. The first stage is a basic
test, which can be carried out on site as in the case of Method 2. The second
stage is carried out when the first stage results are positive. It is noted
that in the IMO Guidelines these stages are referred to as Steps 1 and 2 as in
the case of Method 1. It is at the discretion of the port State competent
authorities to choose which analysis methods are used.
The method for cybutryne determination is based on a one-step
analysis.
The following points are presented for port State consideration:
- approval procedure for the recognition of
laboratories meeting ISO 17025 standards or other appropriate facilities should
be set up by the port State competent authorities. These procedures should
define the recognition criteria. Exchange of information between port States on
these procedures, criteria and laboratories/facilities would be beneficial,
i.e. for the purposes of exchange of best practices and possible cross-border
recognition and provision of services;
- the company that undertakes the analysis
and/or samples should comply with national regulations and be independent from
paint manufacturers;
- the PSCO carrying out the AFS inspection of a
ship should verify the validity of the ISO 17025 certificate and/or the
recognition of the laboratory;
- if more time is needed for analysis than
available considering the ship's scheduled time of departure, the PSCO shall
inform the ship and report the situation to the port State competent authority.
However, the time needed for analysis does not warrant undue delay of the ship;
and
- PSCOs should ensure completion of the record
sheets for the sampling procedure as proof of analysis. In cases when the
laboratory procedures prescribe presentation of the analyses' results in a
different format, this technical report could be added to the record sheets.
5 The first-stage
analysis for organotin
The first-stage analysis serves to detect the total amount of tin
in the AFS applied.
It is at the discretion of the port State competent authority to
choose the first-stage analysis methodology. However, the use of a portable
X-ray fluorescence analyser (mentioned under Method 2) or any other
scientifically justified method allowing the conduction of first-stage analyses
on site could be considered best practice.
The port State competent authority has to decide whether the
first-stage analysis should be carried out by PSCOs or by contracted companies.
The port State competent authority could provide PSCOs with this
equipment (e.g. portable X-ray fluorescence analyser) and provide the
appropriate training.
6 The second-stage
analysis for organotin
The second-stage (final) analysis is used to verify whether or not
the AFS system complies with the Convention requirements, i.e. whether
organotin compounds are present in the AFS at a level which would act as a
biocide.
The port State could consider implementing only a second-stage
analysis.
It is at the discretion of the Authority to choose the
second-stage analysis methodology. In this respect it is hereby noted that the
second-stage analysis methodology for sampling Method 2 provided in the
Guidelines is only tentative and "should be thoroughly reviewed by experts
based on scientific evidence" (section 5.1 of Method 2).
7 One-stage analysis
for cybutryne
For cybutryne a one-stage analysis is described in both Method 1
and Method 2 of the brief sampling guidelines. The specimens are to be analysed
in a GC-MS analysis. The procedure is the same for both methods.
8 One-stage analysis
for cybutryne and organotin
For cybutryne and organotin a one-stage analysis is described in
both Method 1 and Method 2 of the brief sampling guidelines. The specimens are
to be analysed in a GC-MS analysis.
9 Conclusions on
compliance
The Authority should only make conclusions on compliance based on
the second-stage analysis of the sample (organotin). In case the results
indicate non-compliance at that stage, there are clear grounds to take further
steps.
For cybutryne the authority could make conclusions on compliance
based on the one-stage analysis.
If considered necessary, more thorough sampling can be also
carried out in addition or instead of brief sampling.
Sampling results should be communicated as soon as possible to the
ship (as part of the inspection report) and in the case of non-compliance also
to the flag State and recognized organization acting on behalf of the flag
State if relevant.
Authorities should, in accordance with section 5.2 of the Guidelines
for brief sampling of anti-fouling systems on ships, develop and adopt
procedures to be followed for those cases where compliance with acceptable
limits or lack thereof is unclear, considering additional sampling or other
methodologies for sampling.
FORM S/1
REPORT OF INSPECTION OF A SHIP'S ANTI-FOULING SYSTEM (AFS)
SHIP PARTICULARS
1.
Name of ship: 2.
IMO number:
3.
Type of ship: 4.
Call sign:
5.
Flag of ship: ___________________________ 6.
Gross tonnage:
7.
Date keel laid / major conversion commenced: _____________________________
INSPECTION
PARTICULARS
8. Date & time: _______________________________________________
9. Name
of facility: _______________________________________________
(dry dock, quay, location)
Place & country: _______________________________________________
10. Areas inspected ☐Ship's
logbook ☐Certificates ☐Ship's
hull
11. Relevant certificate(s)
(a)
title (b) issuing
authority (c)
dates of issue
1.
_______IAFS Certificate ______________________________________________
2.
_______Record of AFS_______________________________________________
3.
_______Declaration of AFS____________________________________________
4.
___________________________________________________________________
12. Dry-dock
period AFS applied: ___________________________________________
13. Name
of facility AFS applied: ___________________________________________
14. Place
& country AFS applied: ___________________________________________
15. AFS
samples taken ☐No ☐Yes Nature of sampling: ☐Brief
☐Extent
16. Reason
for sampling of AFS:
17. Record sheet attached:
__________________________________________________
(country-code
/ IMO
number / dd-mm-yy)
18. Copy to: ☐ PSCO ☐ Flag
State ☐ Recognized organization
☐ Head office ☐ Master
☐ Other:
______________________
PORT STATE PARTICULARS
Reporting authority: __________________
District office
__________________
Address: ___________________________________________________________
___________________________________________________________
Telephone/Fax/Mobile:
____________________________________________________
E-mail: ___________________________________________________________
Name:
(duly authorized
inspector of reporting
authority) ___________________________________________________________
Date: _______________
Signature: _____________________________
FORM S/2
RECORD SHEET FOR THE SAMPLING PROCEDURE FOR COMPLIANCE WITH THE
CONVENTION IN TERMS OF THE PRESENCE OF ORGANOTIN AND/OR CYBUTRYNE ACTING AS A
BIOCIDE IN ANTI-FOULING SYSTEMS ON SHIP HULLS
|
RECORD NUMBER |
|
(country-code / IMO
number / dd-mm-yy)
Name of ship ________________________
IMO number:
______________________
SAMPLING
PARTICULARS
1.
Date & time initiated: 2.
Date & time completed
3.
Name of paint manufacturer:
4.
AFS product name & colour:
5. Reason for ☐ Port State ☐
Survey & ☐ Other flag State
sampling: control
certification compliance inspection
6.
Sampling method ______________________________________________________
7.
Hull areas sampled: ☐
Port side ☐ Starboard side ☐ Bottom
Number
of sampling ______________ ________________ ___________________
points:
8. Back-up samples' storage location:
(e.g. port State inspection office)
9. ☐ Photos taken of the sample points Comments: _________________________
10. ☐ Paint
samples (wet) Comments: _________________________
11. Case A - Analysis of organotin only
☐
First-stage analysis for organotin Comments:
_________________________
☐
Second-stage analysis for organotin Comments:
_________________________
12.
Case B - Analysis of cybutryne only Comments:
_________________________
One-stage analysis for cybutryne _________________________
13. Case C - Simplified approach to detect
organotin and cybutryne _________________________
One-stage analysis for organotin and
cybutryne _________________________
14.
Comments concerning sampling procedure
15.
Sampling company Name
Date
Signature
PORT STATE PARTICULARS
Reporting authority: _________________ District office: _______________________
Address: ______________________________________________________
Telephone/Fax/Mobile: ______________________________________________________
E-mail: ______________________________________________________
Name:
(duly authorized inspector
of reporting authority) _____________________________________________________
Date: ______________ Signature:
________________
FORM S/3
|
RECORD NUMBER |
|
Name of ship ___________________
IMO number: _______________________
METHOD 1 ANALYSIS
Case A - Analysis of organotin only
|
1.
|
Instrument
I.D.: |
|
Calibration
expire date: |
|
||||
|
2.
|
Specimens
'A' results |
Total
number of specimens 'A' analysed: |
|
|||||
|
3.
|
No. |
Sample location (frame & distance from boot topping) |
mg Sn/kg |
No. |
Sample location (frame & distance from boot topping) |
mg Sn/kg |
||
|
|
1 |
|
|
9 |
|
|
||
|
|
2 |
|
|
10 |
|
|
||
|
|
3 |
|
|
11 |
|
|
||
|
|
4 |
|
|
12 |
|
|
||
|
|
5 |
|
|
13 |
|
|
||
|
|
6 |
|
|
14 |
|
|
||
|
|
7 |
|
|
15 |
|
|
||
|
|
8 |
|
|
16 |
|
|
||
|
4.
|
Results Number
of specimens exceeding 2,500 mg/kg: |
☐ Step 2 required |
||||||
|
|
1 or more specimens exceeding 3,000 mg/kg ☐ Yes ☐ No |
☐
Compliance, no further analysis |
||||||
|
5.
|
Additional comments concerning analysis of results from
Specimens 'A' |
|||||||
|
6.
|
Company
|
Name:
Date:
Signature:
|
||||||
|
7. |
Instrument
I.D.: |
|
Calibration
expire date: |
|
||||||
|
8. |
Specimens
'B' results |
Total
number of specimens "B" analysed: |
|
|||||||
|
9. |
No. |
organotin (mg Sn/kg) as Sn |
No. |
organotin (mg Sn/kg) as Sn |
No. |
organotin (mg Sn/kg) as Sn |
No. |
organotin (mg Sn/kg) as Sn |
||
|
|
1 |
|
5 |
|
9 |
|
13 |
|
||
|
|
2 |
|
6 |
|
10 |
|
14 |
|
||
|
|
3 |
|
7 |
|
11 |
|
15 |
|
||
|
|
4 |
|
8 |
|
12 |
|
16 |
|
||
|
10. |
Results Number of specimens exceeding 2,500 mg/kg: |
☐ Non-compliance assumed |
||||||||
|
|
1 or more specimens exceeding 3,000 mg/kg ☐
Yes ☐ No |
☐ Compliance assumed |
||||||||
|
11. |
Additional comments concerning analysis of results from
Specimens 'B' |
|||||||||
|
12. |
Company |
Name: Date: Signature: |
||||||||
Case B - Analysis of cybutryne only
Gas chromatography/mass spectrophotometry (GC/MS) analysis
|
1. |
Instrument
I.D.:
|
|
Calibration
expire date: |
|
|
2. |
Specimens
'C' results |
|||
|
|
Total
number of specimens 'C' analysed by GC-MS: |
|
||
|
|
Average
concentration of cybutryne (mg of cybutryne per kg of dry paint): |
|
||
|
3. |
Conclusions
The
average concentration of cybutryne exceeds the threshold of 1,250 mg of
cybutryne per kg of dry paint |
☐ Yes ☐ No. Compliance assumed. |
||
|
4. |
Additional
comments concerning analysis of results from Specimens 'C' |
|||
|
5. |
Company
|
Name:
Date:
Signature:
|
||
Case C - Simplified approach to detect organotin and cybutryne
Gas chromatography/mass spectrophotometry (GC/MS) analysis
|
1. |
Instrument
I.D.:
|
|
Calibration
expire date: |
|
|
2. |
Specimens
'C' results |
|||
|
|
Total
number of specimens 'C' analysed by GC-MS: |
|
||
|
|
Average
concentration of organotin (mg Sn/kg of dry paint) |
|
||
|
|
Average
concentration of cybutryne (mg of cybutryne per kg of dry paint): |
|
||
|
3. |
Conclusions
|
|||
|
The
average concentration of organotin exceeds the threshold of 3,000 mg Sn per
kg of dry paint |
☐ Yes ☐ No. Compliance assumed. |
|||
|
The
average concentration of cybutryne exceeds the threshold of 1,250 mg of
cybutryne per kg of dry paint |
☐ Yes ☐ No. Compliance assumed. |
|||
|
4. |
Additional
comments concerning analysis of results from Specimens 'C' |
|||
|
5. |
Company
|
Name:
Date:
Signature:
|
||
FORM S/4
|
RECORD NUMBER |
|
Name of ship __________________________
IMO number:
_________________________
METHOD 2 ANALYSIS
Case A - Analysis of organotin only
First stage
|
1. |
Instrument I.D.: |
Calibration expire date: |
|
2. |
Sample location (frame & distance from boot topping) |
Specimen I.D. |
Sample disc |
Content of tin (mg/ kg) |
max |
min |
Average |
|
A |
|
A1 |
☐ abrasive |
|
|
|
|
|
|
|
A2 |
☐ metal |
|
|
|
|
|
|
|
A3 |
☐
others |
|
|
|
Average |
|
|
|
A4 |
☐
abrasive |
|
|
|
|
|
|
|
A5 |
☐
metal |
|
|
|
mg/kg |
|
|
|
A6 |
☐
others |
|
|
|
☐ >2,500 mg/kg |
|
|
|
A7 |
☐
abrasive |
|
|
|
☐ >3,000 mg/kg |
|
|
|
A8 |
☐
metal |
|
|
|
|
|
|
|
A9 |
☐
others |
|
|
|
|
|
B |
|
B1 |
☐
abrasive |
|
|
|
|
|
|
|
B2 |
☐
metal |
|
|
|
|
|
|
|
B3 |
☐
others |
|
|
|
Average |
|
|
|
B4 |
☐
abrasive |
|
|
|
|
|
|
|
B5 |
☐
metal |
|
|
|
mg/kg |
|
|
|
B6 |
☐
others |
|
|
|
☐ >2,500 mg/kg |
|
|
|
B7 |
☐
abrasive |
|
|
|
☐ >3,000 mg/kg |
|
|
|
B8 |
☐
metal |
|
|
|
|