NYMPP: Section 2 - Painting & Fiberglass Repair
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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.

Best Management Practices:

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.

Stay informed 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.

Discourage use of antifouling paint on boats kept in fresh water, except where invasive species like zebra mussels are a problem.

Recommend 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.

Use dust-collecting vacuum sanders when sanding anti-fouling paint. For manufacturers of dustless vacuum sander equipment, click here.

Sandblasting is not recommended for removal of antifouling paint. If sandblasting is necessary, see "Abrasive Blasting" fact sheet, click here.

Sweep and collect paint chips (don't hose) immediately after scraping or sanding.

Mix paints 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.

Save excess or unused antifouling paint for future uses.

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

Prohibit in-water 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 boat bottom.

If in-water 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.

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's Pesticide Management Regulations, click here.

The use of anti-fouling tributyltin (TBT) containing paints with a release rate greater than 4.0 micrograms per square centimeter per day is prohibited.

The owner 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.

A hazardous 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 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.

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 here.