New York Sea Grant's
Marina Pollution Prevention Web Site
Section 2: Painting
& Fiberglass Repair
- Prepping & Painting Boat Bottom
Potential Environmental Impacts:
Most antifouling paint contains elemental copper, cuprous oxide
(a copper compound), or tinoxide compounds (tributyl tinoxide)
which kill organisms attempting to attach to a painted surface.
By design, antifouling paints are toxic to marine life and can
be absorbed by edible fish and shellfish. Some forms of copper
and tin can be hazardous to some marine organisms in concentrations
of parts per billion. (A part per billion is equivalent to one
drop in 21,000 gallons.) The toxins in antifouling paints enter
the environment through spillage, sanding, sand blasting, or scraping.
Antifouling paint chips left on the ground or driveway can be
transported into the water by stormwater runoff. The toxicants
in antifouling paint can be passed up the food chain from mussels
and worms to fish, birds and humans.
Try to switch to long-lasting, low-toxicity antifouling paint.
Recommend antifouling paints containing the minimum amount of
copper necessary for the expected conditions to your customers.
Stock only those in the ship store.
about antifouling products, like Teflon, silicone, polyurethane,
and wax that have limited negative impacts. (For more information
on non toxic paint alternatives click on Related Resources and
Information on this Topic Button at bottom of this page.) Recommend
alternatives to your customers when appropriate.
use of antifouling paint on boats kept in fresh water, except
where invasive species like zebra mussels are a problem.
that boats that are rack stored or trailered use alternatives
to antifouling paint such as polyurethane, bottom wax, or non-metallic
epoxies, since antifouling paint is not necessary for boats that
are not continuously in the water.
vacuum sanders when sanding anti-fouling
paint. For manufacturers of dustless vacuum sander equipment,
is not recommended for removal of antifouling paint. If sandblasting
is necessary, see "Abrasive Blasting" fact sheet,
collect paint chips (don't hose) immediately after scraping or
and solvents away from the water and prevent dripping into the
water. Avoid mixing paint or cleaning brushes on open floats or
other structures over the water.
Use drip pans,
tarps and sheeting to contain droppings and spilled materials.
Drip pans should be used for all paint mixing, solvent transfer,
or equipment clean up operations unless the operations are conducted
in controlled areas away from storm drains, surface waters, shorelines,
piers, docks or floats. Weight the bottom edges of tarps and plastic
sheeting to keep them in place.
Mix only enough
paint necessary for a job.
or unused antifouling paint for future uses.
and thinners by draining the clean product off the top once solids
bottom cleaning, hull scraping, or any process which occurs underwater
that could remove antifouling paint from the boat hull. Although
this is a popular practice for racing boats prior to a race to
reduce drag, it is impossible to treat what's cleaned from the
bottom cleaning is allowed, require that customers or contractors
use only soft sponges to clean marine growth, and to use stainless
steel pads or brushes only on unpainted metal areas (never on
bottom paint). Colored plumes of paint in the water near underwater
cleaning activity should not occur.
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's Pesticide Management Regulations, click
The use of
anti-fouling tributyltin (TBT) containing paints with a release
rate greater than 4.0 micrograms per square centimeter per day
or agent of a commercial boatyard may possess and apply TBT-containing
antifouling paint if the paint is applied only within a commercial
boatyard and (i) is applied to vessels exceeding 25 meters in
length, or (ii) is applied to aluminum hulls.
waste determination must be conducted on paint wastes and any
materials used to clean up spilled paint to establish whether
or not their disposal is subject to hazardous waste regulations.
To determine if they are hazardous, the generator must either
have waste materials tested or utilize 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
in accordance with hazardous waste storage requirements [40
CFR 262.11, click
here]. For more information on New York's Hazardous
Waste Regulations and storage requirements, click
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.
Paint or varnish
that is accidentally discharged to the ground or waters of the
state must be reported to the state (In New York call the NYSDEC
Oil Spill Hotline at (800) 457 7362).
If paint or
varnish that is discharged into navigable waters causes a visible
sheen, it may also be necessary to report the discharge to the
National Response Center at (800) 424-8802.
If there is
a storm water discharge from your facility and any paint, varnish,
thinners, etc. 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 storm water permitting
in New York, click