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
- Sanding & Scraping

Potential Environmental Impacts:

Hull paints can contain hazardous materials including heavy metals (copper, tin and zinc) and volatile organic compounds (VOCs). Sanding chips and dust that fall onto the ground can enter a marina basin through stormwater runoff. Paint chips and sanding debris can be particularly dangerous when shellfish ingest them, and the shellfish are ingested by other animals.

Best Management Practices:

Conduct sanding and scraping away from the water's edge. Designate an upland area for debris-producing maintenance such as scraping, sanding, and sandblasting. The boat maintenance area can be a temporary structure or plastic sheeting provided to minimize the spreading of dust and windblown material. The work area should be well marked with signs.

Place drop cloths or tarps under vessels when sanding or scraping. Weight the bottom edges of tarps and drop clothes to keep them in place.

Consider installing an impervious pad for conducting debris-producing maintenance.

Clean up all debris, trash, sanding dust, and paint chips immediately following any maintenance or repair activity. When sanding or grinding hulls over a paved surface, vacuuming or sweeping loose paint particles is the preferred cleanup method. Do not hose the debris away.

Avoid scraping or sanding on windy days, unless conducting activity in an enclosed maintenance structure.

Use dustless or vacuum sanders when sanding. These tools can collect over 98% of dust generated instead of releasing it into the air. Workers can use this equipment without full suits or respirators and have less cleanup when the job is done saving time and money. For manufacturers of dustless vacuum sander equipment, click here.

Require customers and contractors to use dustless or vacuum sanders when working in the marina. Rent or loan the equipment to them.

Post signs indicating the availability of the dustless or vacuum sanders.

Provide a collection drum for the dust from vacuum sanders and other scraping debris.

Restrict or prohibit sanding and scraping boats which are in the water, to the greatest extent practicable.

If sanding, scraping or grinding must take place while the boat is in the water, use tarps and sheeting installed between the vessel being worked on and the floats or walking surface to prevent dust, paint chips, debris, or other materials from falling or being blown into the water. The sheeting should have a tight seal to the vessel and adjacent surfaces to prevent leakage of particulates outside the work area. Remove the sheeting carefully to prevent the loss of accumulated waste material into the water.

Regulatory Issues:

A hazardous waste determination must be conducted on paint sandings, dust and chips 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.

If there is a storm water discharge from your facility and you scrape or sand hulls outdoors 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.