Ship coating and anti-fouling systems

Regulation:
• External hull: IAFS - International Convention on the Control of
Harmful Anti-Fouling Systems on Ships
• Hull and WBT/COT coatings: IMO PSPC - Performance Standard for
Protective Coatings
• Others
ANTIFOULING SYSTEMS
• Ships travel faster through water and consume less fuel when their
hulls are clean and smooth – free from fouling organisms, such as
barnacles, algae or mollusks.
• In the early days of sailing ships, lime and later arsenical and
mercurial compounds and pesticides were used to coat ships' hulls to
act as anti-fouling systems.
• These compounds slowly "leach" into the seawater, killing barnacles
and other marine life that have attached to the ship.
ANTIFOULING SYSTEMS
• Fouling is an unwanted growth of biological material - such as barnacles and algae - on a
surface immersed in water.
• Vessel bottoms not protected by anti-fouling systems may gather 150 kg of fouling per
m2 in less than six months of being at sea. On a Very Large Crude Carrier with 40 000
m2 underwater areas, this would add up to 6 000 tons of fouling.
• Just a small amount of fouling can lead to an increase in fuel consumption of up to 40 %,
and possibly as much as 50 % since the resistance to movement will be increased. A
clean ship can sail faster and with less energy.
• An effective anti-fouling system can save money to the shipowner in a number of ways:
- Direct fuel savings by keeping the hull free of fouling organisms;
- Extended dry-docking interval, when the anti-fouling system provides several years of
use;
- Increased vessel availability - since it does not have to spend so much time in dry dock.
ANTIFOULING SYSTEMS
ANTIFOULING SYSTEMS
• During the 1960s the chemical industry developed efficacious and cost-
effective anti-fouling paints using metallic compounds, in particular, the
organotin compound tributyltin (TBT).
• By the 1970s, most seagoing vessels had TBT painted on their hulls.
However, it soon became clear there was a price to pay for the efficient
anti-fouling paints containing TBT.
• Environmental studies provided evidence that organotin compounds
persist in the water and in sediments, killing sea life other than that
attached to the hulls of ships and possibly entering the food chain.
Specifically, it was found that TBT causes shell deformations in oysters; sex
changes (imposex) in whelks; and immune response, neurotoxic and
genetic defects in other marine species.
ANTIFOULING SYSTEMS
• Tributyltin (TBT) is an umbrella term for a
class of organotin compounds which contain
the (C4H9)3Sn group, with a prominent
example being tributyltin oxide.
• Tributyltin oxide (TBTO) is an organotin
compound mainly used as a biocide
(fungicide and molluscicide), especially a
wood preservative.
The AFS Convention and Regulations
• The International Convention on the Control of Harmful Anti-Fouling
Systems on Ships (AFS Convention) was adopted on the 5th of October
2001 by the IMO, and the terms for its entry into force (ratification by
25 States representing 25 % of the world's merchant shipping
tonnage) were reached in 2007.
• The International Convention banning the use of organotin and other
harmful substances in anti-fouling paints applied on ships' hulls
entered into force on the 17th of September 2008.
• The Convention has, to date, been ratified by 76 States, with a
combined 93.7 % of the world merchant shipping tonnage.
The IAFS Convention: Requirements
• Under the Convention, ships are not permitted to apply or re-apply organotin
compounds, which act as biocides in their anti-fouling systems;
• Ships either shall not carry such compounds on their hulls or external parts or
surface or, in the case of ships that already carried such compounds on their
hulls, they had to apply a coating that forms a barrier to prevent them leaching
from the underlying non-compliant anti-fouling systems.
• The Convention also establishes a mechanism to evaluate and assess other anti-
fouling systems and prevent the potential future use of other harmful
substances in these systems.
The IAFS Convention: Application
• AFS Convention, 2001 – “International Convention on the Control of
Harmful Anti-Fouling Systems on Ships”
• Implementation of AFS Convention - in force since 17 September 2008.
• Apply to:
- Ships entitled to fly the flag of a Party;
- Ships not entitled to fly the flag of a Party, but which operate under the authority of a
Party; and
- Ships that enter a port, shipyard, or offshore terminal of a Party, but do not fall within
subparagraph a) or b).
• Annex 1 refers to: “Controls on Anti-Fouling systems”.
• Annex 4 refers to: “Surveys and Certification requirements for Anti-Fouling
systems”.
Regulation (EC) No. 782/2003
• The AFS Convention has been transposed into EU legislation through
Regulation (EC) No. 782/2003 on the prohibition of organotin compo
• Regulation (EC) No 782/2003 of the European Parliament and of the
Council, implementing the provisions of the AFS Convention - in force since
1 July 2003:
• Apply to:
• Ships flying the flag of a Member State;
• Ships not flying the flag of a Member State but operating under the authority of a
Member State; and
• Ships that enter a port or offshore terminal of a Member State but do not fall within
points a) or b).
• Shall not apply to any warship, naval auxiliary or other ship owned or
operated by a State and used, for the time being, only on government non-
commercial service.
AFS Convention: Regulation 1 of Annex 4
• Ships of 400 gross tonnage and above engaged in international voyages have to undergo:
• An initial survey before the ship is put into service – for new buildings.
• An initial survey before the first International Anti-Fouling System Certificate – for
existing ships.
• A renewal survey when the Anti-fouling systems are changed or replaced – for all ships.
• As regards the enforcement of the Convention, surveys of ships shall be carried out by:
• Officers duly authorized by the Administration.
• Surveyors nominated by the Administration.
• Recognized Organizations (RO).
• Authorized officers of another Party.
 AFS Convention: Regulation 2 and 3 of Annex 4
• Regulation 2 of Annex 4 → Issuance/Endorsement of an International
AFS Certificate:
• The Administration requires that a ship to which Regulation 1 applies is
issued with a Certificate after successful completion of a survey in
accordance with Regulation 1.
• Regulation 3 of Annex 4 → Issuance/Endorsement of an International
AFS Certificate by another Party:
• At the request of the Administration, another Party may cause a ship to
be surveyed and, if satisfied that this Convention has been complied
with, it shall issue or authorize the issue of a Certificate to the ship.
AFS Convention: Regulation 5 of Annex 4
Ships of 24 meters or more in length, but less than 400 gross tonnage
engaged in international voyages, are required:
• To carry a “Declaration on Anti-fouling System”.
• Declaration to be signed by the Owner, Owner's authorized agent or
Master.
• To be accompanied by appropriate documentation such as a paint
receipt or a Contractor invoice or contain appropriate endorsement.
AFS Convention: Future
- Ban of use of anti-fouling paints that contains cybutryne (AFS)
- Starting 1 January 2023
- MEPC.331(76) 2023/01/01
- Application: all new and existing ships
Coating
Coating
Coating: Shop primers
Shop primers shall be distinguished from coating:
• Shop primer provide temporary protection against corrosion compare
to coating.
• Steel plate shop primed can be welded, not the coated steel plates.
Coating
Finish coat Surface aspect, gloss, color, functionality.

Intermediate coat Barrier effect, build-up thickness, compatibility.

Primer coat Adhesion and/or active corrosion protection.

Steel substrate •Total number of coats.

•Chemical nature, color definition / coat.
•Individual coat and total dry film thickness
(DFT).
Coating System vs. Ship Areas: Hull
Coating System vs. Ship Areas: Cargo & grey
water tanks
Applicable regulation
• Specification & Testing requirements to be studied related to the
Performance Standard for Protective Coating (PSPC):
• IMO MSC.215 (82) – PSPC WBT for dedicated seawater ballast tank
• IMO MSC.288(87) – PSPC COT for cargo oil tanks of crude oil tankers
• IMO MSC.244(83) – PSPC VSP for void spaces on bulk carriers and oil
tankers
• IACS UI SC 223 for PSPC WBT
• IACS UI SC 259 for PSPC COT
• IACS UR Z 17 Procedural requirements for service suppliers
• Bureau Veritas NR 530 Coating performance standard
SURFACE PREPARATION: surfaces condition
Prior to commencement of grit blasting or water jetting it is essential that the
surfaces are clean, dry, and in a condition suitable for surface preparation and
application of the paint. The following briefly outlines the minimum
requirements:

• All grease and oil must be removed from all surfaces.

• All hot work in way of surfaces/tanks to be painted should be complete.

• After final tank testing, tanks should be fresh water washed and dried,
especially if they have been in contact with sea water.

• Defective steelwork, prior to contract commencement, should be repaired

SURFACE PREPARATION: steelwork condition
• Preparation grades of welds, cut edges and surface imperfections are described in ISO 8501-3. IMO
PSPC requires preparation to P2 grade but for optimum coating performance edges should be
treated to P3. International Paint recommend the following methods and minimum levels of
preparation on any new steelwork:
SURFACE PREPARATION: Block stage
• Where necessary, remove weld spatter, smooth weld seams and remove sharp edges by
rounding to a minimum radius of 2mm or subjecting to a “three pass” grinding technique.

• All surfaces must be clean, dry and free from contamination. High pressure fresh water
wash or fresh water wash, as appropriate and remove all oil, grease, soluble contaminants
and other foreign matter in accordance with SSPC-SP1 : solvent cleaning.

• Intact approved shop primer must be cleaned by sweep abrasive blasting or high pressure
fresh water washing. Block construction welds, areas of corrosion and damages to the shop
primer must be abrasive blasted to Sa21/2 (ISO 8501-1:2007)

• Shop primers which have not passed the IMO PSPC MSC.215(82) pre-qualification testing
and are not certified for use with paint layer must be removed by abrasive blasting to Sa2
(ISO 8501-1:2007), removing at least 70% of the intact primer. However, where this applies,
block construction welds, areas of corrosion and shop primer damage must be abrasive
blasted to Sa21/2 (ISO 8501-1:2007).

• Stripe coats should be applied

SURFACE PREPARATION: Block stage
• Upon completion of the blasting, and after inspection by the Contractor Quality Control Department, the
International Paint Technical Service Representative will also inspect the whole area and mark up any substandard
areas.
- All marked areas shall be brought up to the specified standard of preparation. The whole blasted area is to be vacuum
cleaned to remove dust and contamination.
- Levels of substrate salt contamination should be determined as outlined in section 3.4 of this procedure.
- Residual dust levels should be determined prior to paint application and must not exceed rating “1” for dust size classes
“3”, “4” or “5”. (ISO 8502-3:1993). Lower dust class sizes to be removed if visible on the surface to be coated without
magnification.
- Apply the coating scheme as specified in section 2.2 of this procedure. Observe the specified, maximum and minimum
dry film thickness.

• When hard dry, each full coat and each stripe coat is to be inspected by the International Paint Technical Service
Representative.

• Prior to application of subsequent coats, ensure surfaces are clean and dry after stripe coating and inspection
procedures.

• Once the full system has been applied, and has been accepted by the Contractor Quality Control Department, the
International Paint Technical Service Representative will check the dry film thickness.
• Any areas of under thickness are to be brought up to the minimum thickness specified. International Paint must be
consulted when other than a small number of film thickness readings are above the max allowable.
SURFACE PREPARATION: After erection
• Ensure the surfaces to be painted are clean, dry and free of all contamination.
• Erection joint welds and adjacent areas must be abrasive blasted to Sa21/2 (ISO
8501-1:2007) or power tooled to St3 (ISO 850-1:2007). Where power tool
preparation is used, and in order to ensure satisfactory adhesion of the
Intershield 300 system, care should be taken to avoid “polishing” the welds and
surrounding areas.
• Small damages, up to 2% of the total area, may be prepared by power tooling to
St3 (ISO 8501-1/2:1988).
• Areas of neighbouring damages over 25m2, or damages which constitute an area
of over 2% of the total tank surface area must be abrasive blasted to Sa21/2 (ISO
8501-1:2007).
• Ensure surfaces are clean and free from debris.
• To these areas, apply the coating scheme feathering on overlap areas. Observe
the specified, maximum and minimum dry film thickness.
SURFACE PREPARATION: After erection
• Stripe coats should be applied.
• When hard dry, each full coat and each stripe coat is to be inspected by the
International Paint Technical Service Representative.
• Prior to application of subsequent coats, ensure surfaces are clean and dry after
stripe coating and inspection procedures.
• Once the full system has been applied, and has been accepted by the Contractor
Quality Control Department, the International Paint Technical Service
Representative will check the dry film thickness.
• Any areas of under thickness are to be brought up to the minimum thickness
specified. This must be carried out within the overcoating limits specified for the
product. International Paint must be consulted when other than a small number of
film thickness readings are above the max allowable - see Section 2.3.
• It is recommended that completed tanks are “water tested” to highlight any
pinholes or mechanical damages in the tank coating that are difficult to detect by
normal visual inspection. Any defective areas identified are to be repaired
Scaffolding
• Tubular scaffolding must not mask surfaces to be coated. Where contact is necessary then spade ends should
be used.

• Staging should afford easy and safe access to all surfaces to be coated and should be between 15cm and 30cm
(6 and 12 inches) from vertical surfaces which are to be coated.

• Tubular scaffolding must be plugged or capped prior to grit blasting to prevent the ingress of grit and dirt.

• Staging should be designed to allow thorough cleaning. It is recommended that staging be of the ‘turn over’
type, when local safety regulations permit.
• Distance between staging levels should not exceed two metres (6 feet).

• If fixed staging lugs are fitted, these should be stainless steel.

• Staging layout should be such that ventilation is not rendered ineffective.

• Care must be taken when removing scaffolding in order to keep damages to a minimum. Any damages must be
repaired in accordance with the recommendations of the International Paint representative on site.
Ventilation
• Ventilation is necessary during abrasive blasting operations to ensure adequate visibility. Flexible trunking should be used to
allow the point of extraction to be reasonably close to the personnel carrying out the blasting.

• During and after coating application the ventilation system and trunking must be so arranged such that “dead spaces” do not
exist. As solvent vapours are heavier than air, and will tend to accumulate in the lower areas of tanks, it is important that they
are extracted from those areas. This must be balanced with fresh air being introduced into the tank.

• Equipment used must not re-introduce abrasive dust, solvent vapour etc. into the tank. For this reason a positive pressure,
above normal atmospheric pressure, should be maintained inside the tank. As a “rule of thumb” fresh air supply/extraction
should be in the approximate ratio of 4:3.

• Ventilation must be maintained during application and continue whilst solvent is released from the paint film during drying.
Failure to do this may result in solvent retention within the coating system that will adversely affect it’s long term
performance. It must be maintained for a minimum period of 48 hours after coating application has been completed unless
otherwise agreed with International Paint.

• The level of ventilation employed must take account of the Lower Explosive Limit (LEL) of the product being applied and
comply with local legislative requirements. (The LEL is the minimum concentration of vapour in air, expressed as a
percentage, that will ignite). International Paint recommend that this is such that vapour concentrations do not exceed 10%
of the LEL. This figure is in line with general industry standards and the requirements of the United Kingdom Health & Safety
Executive (Information Document HSE 703/13 “Application of Surface Coatings to Ship’s Tanks”) and the United States
Department of Labor Occupational Safety and Health Administration (OSHA) regulation 1915.36(a)(2).
Ventilation
• The ventilation requirement can be calculated from the required air quantity (RAQ) to 10% of the LEL figures quoted on the
appropriate Material Safety Data Sheet (MSDS) and the product application rate. A typical paint application rate by airless
spray is 75-100 litres (19.7-26.3 U.S. Gallons) per hour per sprayer.

• Venting to 10% of the LEL is considered to provide a reasonable margin of safety to allow for possible higher local
concentrations due to the complex geometry of ballast tanks. Nevertheless, care should be taken when setting up
ventilation/extraction systems, to ensure that 10% figure is not exceeded.

• If the level of ventilation is reduced during coating application, in order to minimise possible dry spray, the paint application
rate must also be reduced to ensure that solvent vapour levels remain below 10% of the LEL.

• Responsibility rests with the shipyard/contractor to ensure that the requisite equipment is available and operated in such a
way that these requirements are met. International Paint will provide all of the information needed to allow the
shipyard/contractor to calculate ventilation requirements. However, International Paint does not accept responsibility for the
equipment, it’s operation, or the monitoring necessary to ensure that the requisite ventilation requirements are met.

• All equipment used after the commencement of paint application must be electrically safe in operation.

• Provision must be made by the contractor/shipyard for continuous, round the clock, surveillance of ventilation equipment.
Dehumidification
• Dehumidification equipment, when required, must be of adequate capacity to maintain the condition of
blasted steelwork to the required standard. Additionally, in order to prevent condensation, the steel
temperature must always be at least 3°C (5F) above the dew point.

• Coatings may only be applied to surfaces which have been maintained in a dry condition with the steel
temperature at least 3°C (5F) above the dew point for more than one hour. The surfaces must be visibly dry
and clean at the time of application. This condition must be maintained until the coating is cured.

• Tank Coating must only be undertaken under acceptable atmospheric conditions, otherwise adverse effects
may occur.

• As a guide, relative humidity levels of 40-60% give optimum results. Application should not take place if the
relative humidity is greater than 85%.

• Provision should be made for 24 hour surveillance of equipment.

Dehumidification
 Heating
• If heating is necessary to satisfy the painting specification, it should be by means of a heat exchange system, i.e. air admitted
to the tank should not pass directly through a combustion chamber.
• Temperatures should be maintained for the duration of the contract from application to cure and provision should be made
for 24 hour surveillance of equipment by the contractor/shipyard.

Lighting
• Lighting during painting must be electrically safe and provide suitable illumination for all work. As a guide, lighting may be
considered suitable if this text can be read at a distance of 30 centimetres (12 inches) from the eye.
• Ideally, the lighting should be powerful mains supplied spotlight with background lighting on at all times in the interests of
safety.
• Powerful mains spotlighting must be provided when inspection work is being carried out.

Storage
• The paint must be stored out of direct sunlight so that the temperature of the material will not exceed 35°C (95F) for
prolonged periods of time.
• In winter months, when temperatures can be expected to fall below 5°C (41F), base and curing agent must be stored in
premises, (storeroom, hut, etc), which are heated to a temperature in excess of 5°C (41F) for a period of not less than 48
hours immediately prior to use (unless stated otherwise on the product technical data sheet).
Grit blasting
• The universal standards of surface preparation that are normally specified for ballast tank coatings are - ISO Standard ISO
8501-1 (2007) – Sa2, Sa2½ and Sa3.

• In general, the following comments apply to these standards.

- Sa2 - the resulting steel surface should be free from most of the rust, old coating and foreign matter. Any residual old
coating should be firmly adhering

- Sa2½ - in practice, this is considered to be the best standard a skilled blasting operative can consistently achieve.

- Sa3 - the possibility of achieving a uniform standard of Sa3 throughout the tanks is remote and a more realistic achievement
would be somewhere between Sa2½ and Sa3.
 Grit blasting
• Air used for blasting must be clean, oil free and dry. The pressure should be at least 7kg/cm² (100lb/sq inch) at the nozzle.

• Abrasives used for blasting must be dry and free from dirt, oil, grease and suitable for producing the standard of cleanliness and
profile specified. The abrasive must therefore be in accordance with the specifications given in ISO 11126 - Parts 1 to 8 and each
delivery should carry a certificate of conformity to this specification.

- If blasting abrasive is supplied on site without a certificate of conformity, the material should be tested by the yard or contractor in
accordance with the methods given in ISO 11127 - Parts 1 to 7.
- Particular attention should be given to ISO 11127 - Part 6, where the level of water soluble contaminants must not give a
conductivity value greater than 25mS/m, and ISO 11127 - Part 7, where the level of water soluble chlorides must not exceed 0.0025%
by weight.
- Iron or steel abrasives can be used for in-situ open blasting. Specifications for metallic abrasives are given in ISO 11124 - Parts 1 to
4 and the corresponding test methods in ISO 11125 - Parts 1 to 7. If used, careful and thorough cleaning must be carried out at all
stages of the operation to ensure that no abrasive remains in the tank as this may subsequently corrode.
- Although not recommended, recycled grit may be used providing it is dry, has been shown to be free from contamination by dirt,
oil, grease, and has been tested in accordance with the above ISO standards.
 Water jetting
• All GRP ballast pipes and vulnerable fittings are to be suitably protected with masking prior to water jetting.

• Only fresh water is to be used for water jetting. Salt water is unacceptable for substrate preparation. Chemical corrosion
inhibitors must not be added to blasting water. See note 5.6 of the International Paint Hydroblasting Standards.

• All areas are to be prepared by water jetting to a minimum standard of HB2 'Thorough Hydroblast Cleaning' from the
International Paint Hydroblasting Standards. This states:

• "When viewed without magnification, the surface shall be free from visible oil, grease, dirt and from most of the rust,
paint coatings and foreign matter. Any remaining contamination and staining shall be firmly adhered. See notes 5.9 and
5.10".

• A test area will be blasted before the main tank, and inspected before flash rusting has occurred. See note 5.3 of the
International Paint Hydroblasting Standards. Agreement will be reached by the Owner's representative, the International
Paint representative (if present) and the Contractor's representative on the agreed standard before the main tank area is
prepared by water jetting.

• Areas such as the edges of 'mouse holes' and scallops will be very difficult to water jet. It is advisable to mechanically
clean these areas to ISO 8501-1-1988 - St3 after water jetting.
 Water jetting
• Areas of difficult access such as the backs of bulbous bars may also be difficult to blast with water jet lances. At the discretion of the Owner
and the International Paint representative (if present), these areas may also be mechanically cleaned to ISO 8501-1-1988 - St3.

• Islands of intact paint will only be allowed to remain by agreement with all parties, Owners, International Paint (if present) and Contractor.
The surface of intact paint will be scoured by water jetting to produce a 'keyed' surface suitable for overcoating, and edges will be feathered
back from a firm edge.

• Rust, scale and old paint debris must be removed from the tank prior to inspection and mark-up by the Contractor's Quality Control
Department. The International Paint representative (if present) will then inspect the whole area and mark up any substandard areas.

• All marked areas shall be reblasted and brought up to the required standard. This standard is International Paint Hydroblasting Standard
HB2M 'Moderate Flash Rusting', which states:

• "When viewed without magnification, a layer of light tan-brown rust will obscure the original metallic surface. This layer may be evenly
distributed or patchy in appearance, but it will be heavy enough to mark objects brushed against it".

• If flash rusting is too heavy, it can be removed by high pressure washing. Upon drying, the surface must have an acceptable level of flash
rusting for overcoating. See note 5.7 from the International Paint Hydroblasting Standards.

• Surface salt contamination should be measured (See section 3.4). The maximum permissible level is 50mg/m².
Cleaning
• Prior to initial blasting inspection, the bulk of spent grit (and old paint debris if water jettting) must be removed.

• Any substandard areas should be identified and must be brought up to the specified standard.

• All marking paint, chalk, etc, used to identify substandard areas must be removed after substandard areas are rectified. If
marking pens are used which cannot be removed then they must be technically approved by the International Paint
Worldwide Marine Laboratories prior to any overcoating taking place.

• Following provisional approval of the blast standard, all remaining traces of grit and dust must be removed from all areas
including scaffolding, using industrial vacuum cleaners fitted with brushes, or by other suitable methods agreed by
International Paint.

• Final approval of a substrate for coating application must be confirmed after final cleaning.

• Mats for wiping feet, (or overshoes), should be placed at the entrance of tanks, and the area immediately surrounding
them kept in a clean condition.
Paint application
• Efficient mechanical stirrers for the correct mixing of paint must be used.

• Available air pressure and capacity for spray equipment should be at least 5.5kg/cm2 and 1.4m3/min (80 psi
and 50 cfm).

• All spray equipment must be in good working order and be capable of performing to the output
requirements defined in International Paint product technical data sheets.

• It is recommended that airless spray pump ratios of 40:1 or greater should be used.

• Tips should be the size stipulated on the product technical data sheet, or as agreed with the International
Paint representative on site. Tips must not be in a worn condition.

• Both during and following application of paint, all operatives entering the confines of coated tanks must
wear soft-soled shoes or overshoes.
Stripe coats
• Stripe coating is an essential part of good painting practice. Typical areas where stripe coats must be applied include:
- behind bars
- plate edges
- cut outs i.e. scallops, manholes etc
- welds
- areas of difficult access
- ladders and handrails
- small fitments of difficult configuration
- areas of pitting
Note: The above list is not comprehensive, all areas must be included. The diagrams following indicate key areas requiring stripe
coating:

• In general, stripe coats should be applied by brush or roller, depending upon items concerned.

• In exceptional circumstances it may be acceptable to apply a stripe coat to the backs of angle bars by narrow angle spray. The use
of spray applied stripe coats however, must be discussed and agreed with the International Paint representative on site.
 Regulation (EC) No. 782/2003-Art. 6(a)
Ships of 400 gross tonnage and above, excluding fixed or floating
platforms, FSUs and FPSOs, shall be surveyed and certified:
• An initial survey before the ship is put into service – for new
buildings.
• An initial survey when the ship is for the first time in a dry-dock
for the application of anti-fouling systems – for existing ships.
• A renewal survey when the Anti-fouling systems are changed or
replaced – for all ships.
Regulation (EC) No. 782/2003-Art. 6(b)
• Ships of 24 metres or more in length, but less than 400 gross tonnage,
excluding fixed or floating platforms, FSUs and FPSOs shall carry an
AFS Declaration.
• Member States may establish appropriate measures for ships not
covered by points (a) and (b) in order to ensure compliance with the
Regulation.
• Annex 1: Survey and certification requirements.
• Annex 2: Forms of the Certificate and Record for anti-fouling systems.
• Annex 3: Declaration on AFS for ships of 24 meters or more in length,
but less than 400 gross tonnage.