California biofouling rules bring new scrutiny, extra documentation


Biofouling regulations stricter than U.S. standards took effect in California in January, affecting the thousands of vessels that call on the state’s ports each year and adding to the paperwork required by mariners.

Beginning Jan. 1, after a vessel’s first regularly scheduled dry-docking or upon delivery, a vessel-specific biofouling management plan and biofouling record book — consistent with 2011 International Maritime Organization (IMO) guidelines — must be carried on board, and the vessel’s wetted surfaces must be managed in accordance with the plan. More specific requirements apply to vessels that undergo extended residency or idle periods, such as remaining in the same location for 45 days or more.

Requiring that a vessel maintain a biofouling plan and biofouling record book goes beyond U.S. Coast Guard standards, as does a provision requiring that details on a vessel’s biofouling coating be submitted to the California State Lands Commission. The new regulations state that the coating should not be aged beyond its effective life span, and if it is past its life span, a management plan should be documented, said Nicole Dobroski, assistant chief of California’s Marine Environmental Protection Division.

The jurisdiction of the lands commission, which administers the state’s Marine Invasive Species Program (MISP), extends to vessels of 300 gross tons and above that are capable of carrying ballast water. In 2017, the MISP arrival fee rose to $1,000 per vessel voyage, up from $850, with the proceeds funding the program.

For vessel operators, additional costs may arise “when in-water inspection and/or cleaning is required, but these risks lessen with the appropriate coatings,” said Maria Polakis, senior engineer with the American Bureau of Shipping.

Invasive species are a serious concern worldwide, with commercial shipping exacerbating the problem. Of 171 invasive species introduced in the United States due to shipping, more are linked to hull fouling than ballast water. Vessels with more than 800 million square meters of wetted hull surface enter North American ports per day.

Invasive species are considered the second-greatest threat to biodiversity after habitat destruction, Dobroski said, and many non-native species are capable of causing significant ecological, economic and human health impacts.

The new MISP initiative against these invaders focuses primarily on biofouling coating maintenance.

“The regulations may also affect a vessel’s dry-docking schedule, although the impact is not direct. When a vessel is scheduled to trade in waters where biofouling regulations are in force, its maintenance cycle determines the coatings-selection process,” Polakis said. “A vessel with 90 months between scheduled dry-dockings will have greater exposure to fouling compared to those with shorter maintenance cycles.”

There is a 60-day grace period to develop a biofouling management plan and record book upon a vessel’s first arrival at a California port. The vessel remains in compliance if it makes additional calls during the period, but it must produce a plan after the period expires.

By Professional Mariner Staff