New York Sea Grant's
Marina Pollution Prevention Web Site

Section 2: Painting & Fiberglass Repair - Paint Spraying

Potential Environmental Impacts:

Paint spraying has potential air and water quality impacts. Most paints contain volatile organic compounds (VOCs) which evaporate quickly and are ignitable. Many paints are also toxic. When released to the atmosphere, VOCs combine with combustion emissions of nitrogen oxides (NOx) to form ground level ozone, which damages lungs and degrades many materials. Marine paint may be toxic to aquatic and marine life.

Best Management Practices:

Avoid unprotected paint spraying. Paint spraying may be conducted:

• inside designated structures with ventilation and filter systems;
  
• at designated shore-side areas away from open water, with temporary structures or plastic sheeting provided to minimize the spreading of overspray; or
  
• in covered slips, with tarps and sheeting installed with a tight seal between the vessel being worked on and the floats or walkway surface. Prohibit paint spraying on the water without protective sheeting. Be sure to remove the protective sheeting with care to prevent loss of accumulated waste material into the water.

If spraying outdoors with protective sheeting, avoid working on windy days when controlling the protective covering and the paint spray is difficult.

Consider using spray equipment with high transfer efficiency. Paint guns used in spray booths should be either High Volume Low Pressure (HVLP) or High Efficiency Low Pressure (HELP) which are rated at 65% efficient paint transfer. HVLP guns can reduce overspray by 25% to 50%. For more information on HVLP painting systems click on the Related Resources and Information on this Topic button at the bottom of this page. For examples of HVLP spray painting equipment, click here.

Electrostatic spraying also requires less pressure, produces little overspray, and uses relatively little paint. However, it does require an electrically conductive surface which may limit its use in marina applications..

Encourage the use of non-toxic, high bonding, and easily cleaned hull coatings. For more information on nontoxic paints, click here.

Limit the amount of leftover paint and decrease solvent use by using a smaller paint spray gun cup.

Reuse solvents and thinners by draining the clean product off the top once solids settle out.

Whenever possible, use brushes and rollers instead of paint sprayers since paint spraying is potentially more wasteful and more harmful to the environment than applying paint by hand.

Regulatory Issues:

In New York, most boat bottom paints are considered pesticides. Marinas that sell or apply these paints must follow the state's pesticide management rules which require a business license and certification requirements for those who apply the paint. For more information on New York' Pesticide Management Regulations, click here.

The use of spray guns for painting may require an air emission permit depending on the amount of painting done and the location of the facility. For more information about air emission permits, your state environmental agency should be contacted. For more information regarding air regulations related to marinas in New York, click here.

You must determine if your painting wastes (including leftover paints, spray gun solvents, and rags) or any materials used to clean a spill, are hazardous by having the materials tested or by utilizing reliable "knowledge of process" information for the waste (if available) [40 CFR 262.11, click here]. Such information could include testing by haulers, or studies by industry trade groups. For more information on New York hazardous waste testing requirements, click here. If they are hazardous, they must be managed as a hazardous waste. For more information on New York's Hazardous Waste Regulations and storage requirements, click here.

If there is a stormwater discharge from your facility and materials associated with spray painting may come into contact with precipitation, you may have to register for a General Permit for the Discharge of Storm Water Associated with Industrial Activity ("Storm Water General Permit"). For more information on stormwater permitting in New York, click here.

Paint cans and other containers that have residues of hazardous (e.g., oilbased) paints must be handled as hazardous waste unless they have been "emptied," which means the container has been cleaned following directions given on the label. In some cases this means the container is drained of all material that can be removed from them by normal methods (e.g., pouring or pumping), AND no more than one inch (or 3% by weight) of residue remains in the container [40 CFR 261.7, click here]. "Emptied" containers of hazardous paints and those that have dried out residues of non-hazardous (e.g., latex) paints may be recycled as scrap metal, or disposed of in the regular trash.