Measurers Corner

Measurer’s Interpretations and Recommendations

Topic:Hull
Question:Can a paint designed to prevent growth be used even though it is not called "anti-fouling".
ID Number:000031
Date:2009-10-21
Short Answer:No 
Answer:The Rules state:
"Anti-fouling paint shall be used on the bottom at all times."

The newer environmentally friendly bottom paints don't call themselves "anti-fouling" but are designed "to prevent growth" by other means. This should be allowed. 
Section:§IV-1.10 
Status:In Process
Action Date: 
Fri Nov 15 05:45:38 2019
DateNameComment
2009-10-21Richard RobbinsQ - What is the difference between an "antifouling" and a "release" coating?

A - An antifouling coating must contain one or more approved EPA registered biocides and make a biological/antifouling claim. The Federal EPA under the FIFRA legislation as well as most states regulates antifouling coatings. A "release" coating does not contain a biocide and does not make a biological claim to control biofouling. Release coatings rely on other mechanisms besides toxicity to deter biofouling, such as a slick surface or soft ablative composition; biofouling will occur on a release coating but it should be readily removed with some maintenance scrubbing or the vessels fast motion through the water.

See http://www.epaint.com/questions/
2009-10-21Kristian MartincicThere are several bottom paints on the market (and more to come) that perform like antifoul, but like you said, don't truly have a biocide. I think the "spirit of the class" view is that we want to avoid bottoms like many raceboats have, which are just primer or gelcoat and require weekly diving. What are your views on something like VC Underwater Epoxy? This is used on J24 bottoms and the like. It gives a great finish, but in my eyes is a little too far away from antifouling for a Shields, although some will argue that it's slickness aids in antifouling. I think Epaint, Seahawk etc are fine, but really not crazy about Shields with VCU bottoms.
2009-10-21Andy BurtonSlippery slope, Richard. If you allow a "release coating", you'll then have to narrowly define what constitutes a release coating. For instance, I could make the case that wet-sanded Awl Grip 545 Primer such as is used on dry-sailed J/24s, is a release coating because it's so slick. And it's way better than anti-fouling paint because it sands up so well. You'd never find VC Offshore or Baltoplate on a dry-sailed boat. Where Shields are sailed, legal antifouling is readily available, even in California. If you want to be really "green" there are antifouling paints designed for that purpose. This request is simply another sailor attempting to get around the established class rules in order to obtain an advantage over the other class members. I suggest that the request be rejected out of hand as it has been every other time it's come before the technical committee. The ultimate result, should this request go through, is to allow our boats to be dry-sailed by those who take their racing seriously, which would cut the fun of owning the boats way down. I think it's very important for the Technical Committee to remember that we aren't aiming these rules at the Bill Berrys, and John Burnhams of the class. Rather, the constituancy is the guy who is at the bottom or in the middle of the fleet but who nevertheless always shows up to go racing, simply for the joy of it. The bottom line is that there is no reason to change the rule, so leave it as it is!
2009-10-22Andy BurtonThere are two green products on the market that are antifoulings: Pettit Vivid Free and Interlux Pacifica Plus with Econea. Both are approved for California, which has the greenest laws in the country. Let the green person go with one of those, rather than trying to gain an advantage by asking for the rule to be changed.
2009-11-09Andrea Van InwegenI brought this topic up because the Marion Harbor Master is starting to enforce the Clean Water Act (CWA) as mandated by the Environmental Protection Agency (EPA). The CWA is the reason why marinas have had to install pressure washing systems. Very briefly, the CWA was developed to restore & maintain the Nations water ways by reducing direct pollutants into waterways. It was initially designed to stop heavy pollution from large factories but as those areas have come into compliance they are looking at smaller areas of pollution. There is nothing specific in this act that say's anti-fouling bottom paints are illegal or harmful to the environment rather it's very broad in saying that it is unlawful for any person to discharge any pollutant into navigable waters without a permit. One can interpret that traditional copper based anti-fouling paints will soon be a thing of the past.

Harbormasters are facing a challenge to decide how best to enforce the CWA. In Marion they are indicating that scrubbing a boat bottom while afloat that is coated with traditional anti-fouling bottom paint using an abrasive pad or brush and/or seeing a cloud of traditional antifouling bottom paint billowing from boat are indicators that bottom paint is being removed from the boat and pollutants released into the harbor therefore violating the CWA. Anyone with Baltoplate on their bottom knows that they can't go a season without cleaning the bottom so we are starting to look at our options.

There are more environmentally friendly antifouling paints available today but they still contain a biocide to kill growth, which in turn (depending upon your interpretation) violate the CWA. Foul Release Coatings are the only true non-toxic coatings that don't violate the CWA. Foul Release coatings range from an ePaint EP-21 which is described as a bar of soap with an ablative finish to the Interlux Intersleek system where the finish coat is a fluoropolymer amphillic coating. The later would require regular sponging on a Shields bottom because the boat doesn't get to speeds fast enough to remove any growth. Both coatings add weight and serve the purpose of the anti-fouling rule in the Shields Class they are simply classified differently because they don't contain a biocide.

2009-11-13Andy BurtonAndrea, That's tough. The harbormaster seems to be going after the rich yachtsmen because they're (we're?) an easy target. He must be a pain to deal with. I'm sure there are many other targets that would be more effective but less popular. Just got off the phone with him and he's not completely unreasonable, though. Hard antifoulings are acceptable. It's the ablatives that, as you say, leave a cloud when they're scrubbed, that he's going after. So if you change to an antifouling like Baltoplate, or VC, you'll be fine and there's no need to change the rule.
2009-11-16Bam MillerI agree with Andy. Baltoplate and the VC line of products don't leave clouds of paint in the water, and while they have to be regularly cleaned, they do basically prevent the growth of barnacles which is what I think the intent of antifouling is. Even copper based paints will let slime and shrimp attach to the surface. I am strictly opposed to using something that is waterproof, like 545, Interprotect 2000, or Awlgrip LP as "antifouling". As a barrier coat, fine, but not as the final surface.
2009-11-18Andrea Van InwegenThis is actually quite a big issue on the rise. We are working to get more clarification on the bottom scrubbing subject and bottom paints in general. As I have more details from the EPA, I will be happy to share them. If you sort through the Clean Water Act it seems that all bottom paints with copper may be a violation. We are trying to be forward thinking and proactive. I would hate to change my bottom paint for this season and then have to change it again for the following season when the environmental regulations change again. The Marion harbormaster is trying to do his job, I don't fault him in the least. His enforcement has been changing as this dialogue continues and I would guess it will continue to change. For example there are ablative bottom paints which don't contain persistent biocides so there should be no harm caused by those paints or scrubbing those bottoms even though there may be visual bottom paint coming off the boat. My guess is that when the Shields Class Association rules were written there were no such things as foul release coatings. The class should move with the times & consider this technology. Lets be clear that foul release coatings are an actual category of bottom protection from growth. Awlgrip 545 and Interprotect 2000 are PRIMERS and in no way could be confused with foul release coatings. Please do some research on available foul release coatings before immediately dismissing them.
2009-11-19Andy burtonOK, Andrea. Let's do the research. How about we address this over the next few years? If, as you say, the dialogue is changing, let's wait until we're not trying to hit a moving target. This isn't a rule that urgently needs to be changed. The rule is there for a reason, and no, the Class does not need to keep up with the times. Quite the opposite. I spoke with the Marion Harbormaster at length on the subject and he says that non ablative paints are in compliance with the Clean Water Act in that they don't release poison into the water. Ablative paints do.
2010-12-17Michael GoodwinI know some of you have been interested in the copper-free bottom paint testing happening in San Diego. These studies are taking place to help boatyard and boat owners identify viable environmentally preferred bottom paint alternatives and is the largest independent study of its kind to date. Attached is the presentation discussed at yesterdays Stakeholders meeting.

For background, this study was broken up into two phases. Phase I dealt with short term viability testing of 46 bottom paints on panels. Phase II involved actually painting boat bottoms and evaluating performance over a period of over 20 months. The final report will be released to the public by the end of January 2012.

Regarding ePaint and the Phase I study, all 6 ePaint formulas submitted passed the first round of antifouling efficacy testing. Only 19 coatings made this cut out of 46 paints tested.

Regarding Phase II study, the SD Port could only find a dozen volunteer boats for bottom paint evaluation so not all of the successful candidates from Phase I were evaluated. ePaint EP-2000, ZO, and SN-1 have been used successfully used by boat owners for over a decade and there was no need to include them in this study when many new and experimental coatings were of interest. ePaint ECOMINDER (water-based antifoulant) and EP-21 (foul release coating) were included in Phase II study. One non-ePaint foul release needed to be removed and it was replaced with ePaint SUNWAVE (foul release coating) several months into the study. All ePaints performed as expected at 20 months; EP-21 and SUNWAVE are marketed as single season paints while ECOMINDER is less ablative and lasts longer.

Black ECOMINDER stood out as a strong Phase II finalist which is fantastic as this coating is compatible over existing bottom paints, zero-VOC, cleans up with water, and is economically priced.

Thanks to Southern CA ePaint rep Troy Trombly for attending yesterdays meeting and forwarding the info.

Cheers,

Mike

--
Michael Goodwin
Senior Staff Scientist
Technical Sales & Service Manager
NACE Coating Inspector Level 2 Marine-Certified
Cert. No. 15813
ePaint Company
The Environmental Paint Company
25 Research Road
East Falmouth, MA 02536
800-258-5998
508-495-3210 (fax)
2010-12-17Andy BurtonI'm a bit leery of this whole discussion. We have established that the only place where bottom piant type is a current problem is Marion. And that products currently in use, namely Baltoplate and VC are acceptable to the local authorities. Now we have someone who stands to benefit financially weighing in on the matter. Could this be why we are still talking about the matter? My cynical/sarcastic side wants to know if next we are going to be levying a fee to compensate for our respective carbon footprints!
2010-12-19Kristian MartincicNot sure we're looking at a conspiracy to promote a product for big financial gain the Shields class (is this possible?) but still don't see how a foul release coating as described qualifies as a bottom paint. And as Andy says, I'm not sure theres a problem that needs solviing if current paints are acceptable. The bottom paint rule seems like one of the important ones, in that it keeps the character of the class by taking away much of the incentive to drysail.