Environmental Protection Authority

Final Report 14 December 2012

Economic analysis to support the reassessment of antifouling paints

Prepared for

Disclaimer

Although every effort has been made to ensure the accuracy of the material and the integrity

of the analysis presented herein, Covec Ltd accepts no liability for any actions taken on the

basis of its contents.

Authorship

Tim Denne and Stephen Hoskins

tim.denne@covec.co.nz | (09) 916 1960

© Covec Ltd, 2013. All rights reserved.

Contents

Executive Summary i

1 Introduction 1

1.1 Background 1

1.2 Uses of Antifouling Paints 2

1.3 The Problem 3

2 Current use 4

2.1 The Requirements for antifouling paint 4

2.2 Numbers of Vessels 5

2.3 Current Use in New Zealand 6

3 Impacts of Regulations 8

3.1 Elements of the Regulations 8

3.2 Impact of Paint Bans 8

3.3 Improvements to the Location of Painting 13

3.4 Approved Handler Costs 16

3.5 PPE Costs 16

3.6 Summary of Costs 17

4 Response and Counter-Factual 19

4.1 Response 19

4.2 Counter-Factual 19

5 Benefits 22

5.1 Ban on products containing Chlorothalonil, Diuron and Irgarol 22

5.2 Marina and Dock Improvements 23

5.3 Approved Handler Qualification and Protective Equipment 23

6 Summary and Conclusions 25

6.1 Bans on Individual Paints 25

6.2 Improvements to the Location of Painting 25

6.3 Improvements to Paint Handling 25

Annex 1 Impacts of Ban on Copper Paints 27

i

Executive Summary

Proposed Regulations

The Environmental Protection Authority (EPA) is reassessing all biocides used as active

ingredients in antifouling paints imported to, manufactured and used in New Zealand.

Following a preliminary risk assessment it is considering a number of options for which

it has sought public comment. The options include:

a. Phasing out the use in New Zealand of antifouling paints containing:

a) chlorothalonil;

b) diuron;

c) irgarol; and

d) ziram;

and/or

b. introducing additional controls to reduce risks to:

a) operators;

b) bystanders; and

c) the environment.

Expected Effects

The overall costs of the regulations are summarised in Table ES1. The different impacts

are discussed below.

Table ES1 Summary of Impacts

Category Small boats Large boats Total

Paint bans Some increase in costs:

5-10% in short run for those using banned paints; negligible in long run

Some increase in costs:

5-10% in short run for those using banned paints; negligible in long run

Less than $0.2 million per annum(

Enclosed work areas Can be managed

through brush and roller painting.

Fence screening likely to be acceptable

Potentially high costs if

full encapsulation is required

Costs depend on

whether complete enclosure is required. High costs for large boats

Collection and disposal of waste

Filtration systems

equivalent to $120-170/marina berth

Mostly in place $1-1.5 million for filtration systems

Sealed hard stand 80-85% of marinas already have sealed hard stands

Not applicable $1.7-2.6 million up-front or $260-390,000 per annum.

Approved handler Some impact – cost for

DVD or on-line training (less than $100 per person)

Small impact Total of less than $0.5 million

PPE requirement Up-front costs of approximately $40

No impact –

professional painters likely to have equipment already

$0.3 million

Total <$5 million pa

ii

Bans on Individual Paints

Paints proposed to be banned are those that have high risk quotients for human health

or ecotoxicological risks.

The bans on paints will have little total impact on costs. There appear to be substitutes

available in all markets, allowing consumers to switch products. The impacts will fall

mainly on the producers and importers of the products proposed to be banned; this is

particularly Awlcraft currently. However, phasing in the ban over time would enable

new formulations to be developed allowing firms to maintain market share.

Improvements to the Location of Painting

Improvements to the location of painting include sealing hard stands, isolation of

painting via enclosure behind fences (or in full encapsulation) and collection and

disposal of wastes. All of these measures would be expected to yield benefits, although

many are being undertaken anyway as a result of requirements imposed by local

authorities and other government departments. This means that the costs directly

attributable to EPA regulations for antifouling paint may be limited; but it might also

suggest that the regulations are unnecessary.

Several industry members noted that introducing regulations specifically for antifouling

paint was somewhat inequitable; it might also be inefficient. Addressing issues more

generically through regulations that tackled all sources of pollution to air or water, and

all substances, in a consistent way would reduce the regulatory costs while addressing

these equity issues.

That said, the measures proposed appear to be accepted by most as inevitable and,

while in some cases resulting in significant costs, as being reasonable requirements to

protect the marine environment. It is likely that the level of costs will be too great for a

number of small boat yards and that there will be some consolidation of where boat

maintenance and painting takes place. This will limit choice for small boat owners.

Improvements to Paint Handling

Improvements to paint handling include requirements for approved handlers and PPE

requirements. The latter appears to be a relatively low cost measure, with DIY stores

selling equipment that could improve safety. The requirement for approved handlers

could have a significant impact on activity if it effectively stopped DIY painting. This

would result in small boat owners facing increases in costs of between 100% and 400%

of their current paint costs, although the perceived impacts will depend on how they

value their time.

There will be ways in which these costs might be minimised, including through

supervision by marinas, eg checking that people are using adequate PPE and using

spray equipment under the right weather conditions. These costs would need to be

covered via increases in haul-out charges.

1

1 Introduction

1.1 Background

The Environmental Protection Authority (EPA) is reassessing all biocides used as active

ingredients in antifouling paints imported to, manufactured and used in New Zealand.

Following a preliminary risk assessment it is considering a number of options for which

it has sought public comment. The options include:

c. Phasing out the use in New Zealand of antifouling paints containing:

e) chlorothalonil;

f) diuron;

g) irgarol; and

h) ziram;

and/or

d. introducing additional controls to reduce risks to:

a) operators;

b) bystanders; and

c) the environment.

The controls are set out in more detail in Box 1.

Box 1 Possible Controls for antifouling paints

To reduce risks to operators

Approved handler control:

For spraying, mixing and loading for all substances, and

For brushing and rolling of diuron, octhilinone and ziram.

Prescriptive personal protective equipment (PPE) control for all users. Label to also specify

what PPE is required.

Labelling control only. Label to state “Not recommended for non-professional use” for high

risk substances.

Phase out ziram.

Other methods to restrict use (to trained professionals).

To reduce risks to bystanders

Control added to approvals plus label statement to ensure the safety of bystanders during

higher risk removal and application activities. This could be achieved using exclusion zone

and/or signage limiting entry during paint application

To reduce risks to the environment

Phase out substances with high risks to the environment including diuron, irgarol 1051 and

chlorothalonil

Collect all waste generated from maintenance activities on all antifouling paints (for all

approvals in this application) and dispose of at an approved facility

2

1.2 Uses of Antifouling Paints

Antifouling paints are used to prevent or slow the build-up of microorganisms, plants

and algae (biofouling) on surfaces submerged in water, such as the hulls of vessels1 (see

Figure 1). Such growth will increase the friction on boats moving through the water,

slowing them down for a given level of power input.

Figure 1 Boat showing growth of organisms – the results of not using antifoul paint

Source: www.bridge-marina-travelift.co.nz

There are a number of different types of antifouling paints:2

Eroding Type Antifoulings are partially water-soluble so that, as water passes

across it, the thickness of the paint is reduced. As a result a layer of fresh

biocides is continually exposed.

Polishing and ablative antifouling products have a more controlled antifouling

action than the eroding types, but they are not always suitable for high speed

craft, as the action may reduce the thickness of the film too quickly leading to

premature fouling.

Self-polishing paints will, under equal conditions, show improved performance

compared to the ablative eroding or polishing types especially under difficult

fouling conditions. The reducing thickness of these antifouling types leads to a

minimal build up of the coating at the end of the season reducing the

maintenance and preparation needed when it is time to apply next season’s

antifouling.

Hard Antifoulings or ‘contact leaching’ products are those which dry to a hard,

burnishable surface that is porous. Biocides leach out on contact with water in a

process that is chemically designed for release in a controlled manner

throughout the season, until most of the biocide is exhausted and only a hard

1 www.epa.govt.nz/publications-resources/topics/Pages/Antifouling-paints.aspx 2 International Paints Painting & Production Guide

3

film remains. One of the main benefits of this type of antifouling is its resistance

to abrasion and rubbing. This is ideal for fast powerboats and vessels moored in

mud berths or areas of fast tidal water movement. They are also suitable for

fishing boats where nets are in contact with the hull and would rub off soft

paints

1.3 The Problem

The EPA’s assessment of a number of different antifoulings has identified that some of

the substances have high potential risks to human health or the environment. These can

be reduced by:

Restricting use to paints that have lower levels of impact on the environment

and health; and/or

Changing the ways in which the paints are applied to reduce the impacts on

people and the environment.

In this report we assess the extent to which proposed measures will have net benefits,

taking account of the costs and benefits.

4

2 Current use

2.1 The Requirements for antifouling paint

The quantities of antifouling paint required are sufficient to ensure an effective rate of

release of biocides.

2.1.1 Quantity Required per Vessel

Figure 2 shows estimates of the quantity of paint required per boat (assuming two

coats); these are taken from paint manufacturers. The lines are included to show the

range of estimates, with the extremes reflecting different hull shapes in particular.

Feedback received from professional painters was consistent with the higher end of

these estimates, eg a 12 metre boat would require approximately 14 litres of paint.

Figure 2 Paint requirement for different boat sizes

Source: International Paint. Boat Painting and Product Guide; www.wetandforget.co.nz/warpaint.htm

2.1.2 Frequency of Painting

Antifouling paints work by slow release of biocides, so they must be re-applied when

the rate of release has fallen to too low a level; this is typically after 2 years, although the

frequency varies with the quantity of paint applied, ie the number of layers.

NIWA surveyed owners of pleasure craft; the results are shown in Figure 3. Many apply

paints on a fixed schedule, either annually or every two years, with others estimating

that they do so at some intermediate frequency. Assuming that those repainting less

frequently than two-yearly do so every three years, the average repaint frequency is

every 21 months (or every 23 months if we assume that those with a longer frequency

do so every four years).

0

2

4

6

8

10

12

14

16

18

6 7 8 9 10 11 12 13 14 15 16

Litr

es

of

pai

nt

Length of boat (metres)

5

Figure 3 Frequency of Repainting

Source: Gadd J, Depree C and Hickey C (2011) Relevance to New Zealand of the OECD Emission

Scenario Document for Antifouling Products: Phase 2 Report. Prepared for the Environmental

Protection Authority (EPA). NIWA

Commercial boats will often be painted less frequently as a result of using more layers

of paint.

2.2 Numbers of Vessels

There is no record of the number of vessels using antifouling paint in New Zealand. For

small boats it is some proportion of the total as those that are regularly taken out of the

water do not require antifouling; this is limited to those that are moored. For large

vessels, those that spend most of their time in New Zealand will be painted here, but

this might include vessels that are registered elsewhere. Conversely, not all vessels

registered in New Zealand will be painted here.

2.2.1 Small Boats

Marina berths in the 40 marinas in New Zealand total 11,586,3 although occupancy rates

are less than 100%. The recent NIWA survey suggests occupancy rates of approximately

95% as an average across 13 marinas (Table 1), suggesting a total of approximately

11,000 moored boats in marinas. However, there are many other locations for moored

boats outside of marinas, close to private and public ramps and jetties. Estimates of the

total number of moored boats in New Zealand are approximately double those

currently in marinas, ie approximately 22,000 small boats.

3 New Zealand Marina Operators Association. Guide to New Zealand Marinas. In: The Boaties Book

New Zealand 2011/12

29%

21%

29%

17%

4%

0%

5%

10%

15%

20%

25%

30%

35%

Yearly 18-monthly 2-yearly > 2 yearly Never

6

Table 1 Boats in NZ marinas by size category, plus capacity utilisation

Size (metres)

5 - 11 11 - 20 21 - 30 31 - 40 Total Berths Utilisation

Westpark 22% 77% 1% 0% 560 592 95%

Westhaven 40% 58% 2% 0% 1,491 1,432 104%

Bayswater 9% 84% 6% 1% 353 413 85%

Half Moon Bay 50% 49% 1% 0% 500 500 100%

Pine Harbour 39% 58% 0% 0% 485 555 87%

Tauranga 15% 68% 1% 0% 494 561 88%

Taupo 50% 50% 0% 0% 124 174 71%

Kinloch 100% 0% 0% 0% 142 142 100%

Napier 34% 66% 0% 0% 188 185 102%

Mana 14% 86% 1% 0% 305 305 100%

Seaview 18% 82% 0% 0% 269 267 101%

Picton 23% 67% 8% 3% 197 232 85%

Total 32% 64% 2.4% 0.3% 6,084 6,391 95%

Source: Size percentages (calculated) and total numbers from Gadd J, Depree C and Hickey C (2011)

Relevance to New Zealand of the OECD Emission Scenario Document for Antifouling Products: Phase

2 Report. Prepared for the Environmental Protection Authority (EPA). NIWA; Berths from New

Zealand Marina Operators Association. Guide to New Zealand Marinas. In: The Boaties Book New

Zealand 2011/12

2.2.2 Commercial Vessels

Commercial ships include fishing boats, ferries and ships used for commercial freight.

According to Maritime NZ there are 3,711 commercial ships operating in New Zealand

in 2012. These included 1,181 fishing vessels, 1,316 passenger vessels and 744 non-

passenger vessels.

Table 2 Ships registered in New Zealand (2012)

Small

Vessels

(0-5.99m)

Medium

Vessels

(6-11.99m)

Large

Vessels

(12-23.99m)

Super Large

Vessels

(24m+)

Total All

Lengths

Passenger 145 587 387 42 1,316

Non-Passenger 337 269 217 76 744

Pleasure Craft 334 60 - - 394

Fishing 322 377 409 73 1,181

Other 25 9 13 29 76

Total 1,163 1,302 1,026 220 3,711

Source: Maritime NZ

2.3 Current Use in New Zealand

2.3.1 Total Paint

Total annual consumption of antifouling paint in New Zealand is approximately 150,000

litres. By assigning paints to commercial and retail categories, based on what types are

available for sale on retail websites, we estimate that approximately 40% (or 60,000

7

litres) are used by small boat owners, with the remainder (90,000 litres) used by

commercial vessels.

2.3.2 Paint Types

There is a wide range of paints applied. The small number of companies selling

antifouling paints in New Zealand, and the concentration of total sales between two

companies, means that we cannot present information on sales by product, or even by

active ingredient. However, the products proposed for bans represent between

approximately 17% of sales in New Zealand.

8

3 Impacts of Regulations

3.1 Elements of the Regulations

The elements of regulations being considered are listed in Box 1 on page 1. In this

section we set out how the regulations might affect current users of antifouling paint.

We discuss the effects of:

Paint bans;

Controls at the locations of painting activity;

Requirements for personal protective equipment.

3.2 Impact of Paint Bans

3.2.1 Impact on Market

Removing active ingredients from the market place will reduce consumer choice, at least

until replacements are developed. To explore this, Table 3 Cumulative Effects of Paint

Bans indicates the cumulative effects of banning paints in order of risk quotient (ie

banning the most hazardous paints first), indicating the options remaining before each

ingredient is banned. for example, if irgarol, chlorothalonil, ziram and diuron are

banned immediately, the environment and/or users would be exposed to a maximum

risk quotient of 11, with 9 retail and 16 commercial paints remaining available,

compared to the current market of 13 and 21 respectively. We have assumed for this

analysis that copper would not be banned, as this would result in no paints remaining

(the only paint that does not list copper as an ingredient, includes diuron). As such, the

improvements in maximum risk are capped at copper’s RQ of 11; to illustrate this,

Annex 1 presents this table with copper included in the bans.

Table 3 Cumulative Effects of Paint Bans (shaded paints not currently available on NZ market)

Ingredient

banned Max RQ

Paints Avail.

Paints Avail. Al compatible Paint Types(1)

Retail Comm. Retail Comm. A SP R H

Nothing banned 240 34 13 21 4 3 4 19 3 3

Irgarol 102 34 13 21 4 3 4 19 3 3

Chlorothalonil 63 34 13 21 4 3 4 19 3 3

Ziram 16 33 13 20 4 3 3 19 3 3

Diuron 11 25 9 16 4 2 3 14 2 2

DCOIT/Sea Nine 11 22 9 13 4 1 3 12 2 2

Octhilinone 11 20 8 12 4 1 1 12 2 2

Thiram 11 17 7 10 4 1 1 9 2 2

Mancozeb 11 17 7 10 4 1 1 9 2 2

Tolylfluanid 11 17 7 10 4 1 1 9 2 2

Zinc Pyrithione 11 13 4 9 2 1 1 6 1 2

Copper Pyrithione 11 9 4 5 2 1 1 3 1 2

Dichlofluanid 11 7 2 5 1 1 1 3 1 0

Zineb 11 4 2 2 1 0 1 2 1 0

Copper 0 0 0 0 0 0 0 0 0 0

(1) A = Ablative, SP = Self-Polishing, R = Resin, H = Hard

Source: EPA (including industry questionnaires); Material Safety Data Sheets; advertised information

from paint manufacturers.

9

If all paints as hazardous as Sea Nine (DCOIT) were banned, SeaSafe would be the only

commercial paint available for use with aluminium vessels. Similarly, if Octhilinone was

also banned, Pettit Hydrocoat would have a monopoly amongst ablative paints, as Sea

Barrier 4000, ABC #3, and Altex #10 would all be removed. The following section

examines changes in the quality of paints included in the bans.

3.2.2 Paint Qualities

In general terms all the paints appear to offer the same basic qualities, taking account of

the different requirements for hard or soft paints, as discussed in Section 1.2 above.

Some of the more expensive paints (eg Micron 66) may provide more years of control, ie

time before reapplication is required, but this can also be achieved by applying more

layers of lower-priced paint; paint prices are discussed below. For the most part the

paints can be assumed to be doing the same job such that reducing the number available

on the market will not, in itself, result in a reduction in the benefits of antifouling —

from discussions we have not identified any applications for which substitutes are not

available. However, reducing the number of paints available may result in a change in

costs of paint, with subsequent impacts on paint usage; we discuss this issue below.

A review of boating discussion forums suggest that consumer preferences differ widely.

Many marine painters stock a range of paints and will apply whichever brand the

customer prefers on their vessel. Commercial boat operators cite durability as a more

important factor than price, when selecting paints.

3.2.3 Paint Prices

To estimate the expected increase in costs we show retail prices in Table 4. The cheapest

variety currently on the market is the Diuron-based Awlcraft (also known as Coppercoat)

imported by International Paints (Akzo Nobel). This is the only retail paint identified

that would be affected by the ban. Alternatives to Awlcraft include the copper-based

Warpaint available from small local producer Wet & Forget (a 9% increase in price) and

thiram-based No.5 imported by Altex (a 19% increase in price). However, these price

differences are based on a simple snapshot of prices in November 2012; prices change

over time in absolute and relative terms. For example, a check on prices in 2011 from

Smart Marine showed that Altex No.5 was at that time slightly (5%) cheaper than

Awlcraft4 rather than the 19% more expensive that it is currently. Altex No. 5 is one of

the most commonly used paints currently, so it is unlikely that it would retain a

permanent price disadvantage.

We have also observed that commercial operators offering painting services will allow

purchasers the choice of either Altex or International Paint options, with no impact on

price; the implication is that the prices are broadly the same.

4 http://web.archive.org/web/20101018181455/http://www.smartmarine.co.nz/maintenance-paint-

antifouling-marine-paint-c-38_288.html

10

Table 4 Retail paint prices (including advertised discounts for card holders) – November 2012

Paint Ingredient Manufacturer/importer Price ($/l)(1) % above

Awlcraft Diuron International Paints 39.75

Warpaint MFI Copper Wet & Forget 43.50 9%

No 5 Thiram Altex 47.25 19%

Ultra Dichlofluanid International Paints 62.25 57%

Micron Extra Dichlofluanid International Paints 67.25 69%

Trilux Dichlofluanid International Paints 72.25 82%

Pettit Vivid Zinc pyrithione Altex 100 150%

Micron 66 Zinc pyrithione International Paints 121 203%

(1) GST inclusive

Source: Burnsco (www.burnsco.co.nz);Smart Marine (www.smartmarine.co.nz); Wet & Forget

(www.wetandforget.co.nz)

One paint manufacturer suggests that, for banned products, it is likely that they would

reformulate these using different active ingredients. This might take a few years to do,

but the end result is likely to be a paint that is sold at a price similar to current prices.

Any phasing-in of bans, in which they are pre-signalled to be introduced at some

specified future data, will reduce costs.

In terms of the factors affecting paint prices, the market is dominated by International

Paints and Altex. International Paints imports its paints, and the prices reflect

international paint prices. Altex is owned by Resene Paints and it manufactures in New

Zealand but using some imported chemicals. Thus prices will reflect underlying

commodity prices.

Looking at the history of paint prices would suggest that, in some years, those paints

proposed for banning would have been least cost and in other years they would not.

Over this historical period, if the paints had been banned, a ‚cost minimiser‛ (someone

always purchasing the lowest priced paints that would be acceptable) would have faced

an increase in total costs. The future impact on average paint prices will depend to some

extent on the development of new paint formulations, but in general we would expect

some overall increase in average prices. This would happen if the number of potential

paint varieties decreases and there would be fewer commodities setting the minimum

price path. On average we might assume that paint prices would increase by 5-10% until

new varieties were formulated. The price effects would be minimal if they were phased

in over time.

In total, paint consumption in New Zealand is estimated at approximately 150,000 litres

per annum. Using a price of $50/l, a 5-10% price increase for those currently purchasing

products that would be banned (assume 17%), would cost approximately $64-128,000

per annum.

We examine the paint requirements and the expected purchase approach for different

boat owners below.

The antifoul market is split between the large vessel market, for which a relatively small

number of ships use a large amount of paint, and the pleasure boat market, in which a

11

large number of boats use a relatively small amount of paint. We divide this into three

separate categories:

Painting of pleasure craft by boat owners (DIYers);

Painting of pleasure craft by commercial painters; and

Painting of large commercial ships, including fishing boats, by commercial

painters.

3.2.4 DIY Painters

A NIWA survey of private boat owners found that 31% use commercial painters, with

64% purchasing retail paints and applying antifoul themselves.5

DIY painters would face any increase in prices as noted above, ie for a ‚cost minimiser‛

these might result in a 5-10% increase in costs in the short run if using one of the banned

paints currently, unless the restrictions on specific paint varieties were phased in over

time.

Approximately 40% of the sales of antifouling paint (60,000 litres) are for use on small

boats, and thus a total of approximately 38,400 litres will be used by DIYers. At a price

of $50/litre this would represent a total cost of $16,320 - $32,640 for a 5-10% increase in

price for 17% of boat owners; this is an average price increase of $14 to $27 per boat for

users of the products to be banned (over 80% of people would face no increase in price).

As discussed above, these costs would be lower if regulations could be phased in over

time.6

The larger differences in costs for DIY painters are likely to be associated with any

requirements for protective equipment and/or painting by approved handlers (or under

their supervision).

3.2.5 Commercial Painters

A number of marinas publish prices for antifouling services. Those for two are shown in

Figure 4.

Using retail prices of paint (Table 4), the costs of paint are estimated to be 20-30% of the

costs of an antifouling service. One marina operator suggested to us that the paint cost is

closer to 50% of the costs of an antifouling service. This range would suggest that, with a

5-10% increase in paint prices, the increase in commercial painting price as a result of

shifting to paints that are not banned could be 0.2-0.9% in the costs of an antifouling

treatment on average (assuming 17% of current use is of banned products).

5 Gadd J, Depree C and Hickey C (2011) Relevance to New Zealand of the OECD Emission Scenario

Document for Antifouling Products: Phase 2 Report. Prepared for the Environmental Protection

Authority (EPA). NIWA 6 We have assumed here that there is no price response to the reduction in competition as there is still a

large variety of products on the market

12

Figure 4 Prices for Antifoul Painting

Source: www.pineharbourboatpainters.co.nz/specials.htm;

www.bridge-marina-travelift.co.nz/services/antifoul-package/package-rates.html

3.2.6 Commercial Ships

Commercial ships are also painted by commercial painters. This uses a significant

amount of paint and often painters will apply more layers than for pleasure craft

because of the high costs associated with putting ships into dry dock. Increasing paint

costs will increase total costs for this service, but the high costs of putting the boat into

dock is expected to mean that as a percentage increase, it will be lower than for pleasure

boats, despite the number of paint layers.

Feedback from those operating commercial ships suggests a wide variety of paints are

used, of which Diuron-based paints are one of many and substitutes appear to be

available in all markets.

Using the estimates of total paint sales for commercial vessels (approximately 90,000

litres), the costs of a 5-10% increase in paint prices for 17% of paints would cost $38,200-

76,500 per annum. Spread across the industry as a whole, these costs are insignificant.

To put into context, the NZ fishing industry alone spends an estimated $107 million per

annum on fuel.7 As noted for other categories, any costs associated with bans on

antifouling paints would be lower in the longer run.

7 Based on data in MED Energy Data File for 2011, including 1.69 PJ of diesel (26.07MJ/litre) and 2.41 PJ

of HFO (40.50MJ/kg). Prices assumed are $870/t for HFO and $1.18/litre for diesel.

-

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

8 9 10 11 12 13 14 15 16 17 18

Pri

ce f

or

An

tifo

ulin

g (E

xcl G

ST)

Boat length (metres)

Pine Harbour (Auckland)

Bridge Marina (Tauranga)

13

3.2.7 International Visitors

It has been suggested that a number of vessels coming to New Zealand will bring their

own paint with them or will want to paint their vessels with paints that are also

acceptable in other markets. For example, some painters in New Zealand provide a

certificate of compliance with IMO requirements.8 The products proposed for bans in

New Zealand includes those that are permitted for use under the IMO regulations, but

the bans will not lead to use of paints that are restricted by IMO; this does not appear to

be a problem.

There may be some introduction to New Zealand by foreign vessels of paints that are

banned for sale or use here. It would be difficult to police this, and it is unlikely to be a

significant problem.

3.3 Improvements to the Location of Painting

3.3.1 Requirements

The proposed regulations include a number of requirements for improvements to be

made at marinas or docks where painting occurs. The proposed improvements include:

Spraying to take place within an enclosed work area;

Collection and disposal of all waste; and

Asphalt sealing of all areas used for paint applications.

3.3.2 Enclosed Work Areas

Antifouling paints are applied either by roller and brush or by spray painting. The latter

provides many benefits in terms of the quality of finish and the speed at which painting

can be done, but when painting is done outside, wind conditions restrict the times when

spray painting can be used. Airless spray paint systems reduce the quantity of paint that

is lost to the environment,9 but all spray painting results in some paint being spread to

surrounding areas. There are incentives already for restricting the time and location of

spray paint activities because of the risks of damage to surrounding properties

(including vehicles), people and the environment. It means some marinas and boat

yards already have restrictions that include some combination of: limiting painting to

brush and roller application, limiting spray painting to certain weather conditions only

and/or limiting spray painting to airless systems only.

We spoke to a number of marinas and companies that would be required to operate to

the standards being proposed by the EPA and there are some differences in

interpretation.

8 IMO ASF/CONF 26 -18/10/2001 International Convention on the Control of Harmful Anti-Fouling

Systems on Ships 9 Conventional spray-based painting risks losses of as much as 40% of the paint

(www.altexboatpaint.com/ayb_technical_advice) but airless systems can reduce this to about 20%.

Brush and roller losses are approximately 10%.

14

One marina had installed high (4 metre) fences between every other cradle to provide

protection from winds. They estimated that the wind factor had reduced by 65% as a

result; they also noted that this had increased the times during which they could paint

by 20% (because of the extension of suitable times to periods that otherwise would be

too windy). Another marina had a fully enclosed building that it would intend to use for

painting; this was an existing building – costs would be higher for those that were

required to build something specifically to meet these requirements.

At the Devonport Dockyards painting is undertaken in the dry docks where the areas

being painted are below ground; boats that are painted away from the dry docks are

fully encapsulated; this is already a requirement of their air quality consent. At Ship

Repair NZ’s docks in Whangarei boats are screened with 6 metre high fencing; again

these controls are in place for air quality reasons as required by their consent.

Fishing industry boat owners, who operate with large boats (up to 80 metres in length),

noted the extreme difficulties of providing full coverage (wrapping) of these. They

suggested that the costs could be in the order of hundreds of thousands of dollars per

time and take several days to erect and break down. Permanent structures might be

used to deal with all but the largest of ships, but these could be visually intrusive and

would need to be managed carefully, taking account of location of facilities. They would

be expensive and difficult to obtain consent for.

The other point noted regarding maintenance of large vessels was that, because of the

scarcity of suitable sites, maintenance schedules had to be agreed with significant lead

times, sometimes more than a year in advance. This also meant that there was little

opportunity to shift the time of painting, eg because of windy days, as there was with

marinas for which painting schedules had more flexibility.

The costs of full enclosure could be high for large vessels, but we note that many of the

largest operators are already taking steps to control spray drift, consistent with their air

quality consents. The cost of enclosures depends very much on how this regulation is

specified. Full enclosure of all boat painting would result in very high costs, especially

for large boats, but costs would be reduced if regulations required steps that could

include some combination of fencing/screening and restrictions to less windy days.

3.3.3 Collection and Disposal of Waste

Commercial painters at large yards appear to be collecting and disposing of waste

routinely. The requirements for new investments will be more significant for marinas

and other small operators.

The requirements are as follows:

Collection of all wastewater from water-blasting boats prior to new painting;

Filtration of this wastewater to remove solid particles;

Treatment of wastewater to remove dissolved contaminants and small particles.

The cost impacts will differ depending on whether discharges can be made directly to

an existing wastewater system or if other arrangements need to be made. One marina at

least has constructed the equivalent of a wastewater treatment plant in the form of a

15

sand-based filtration system. Others collect wastewater in large holding tanks for later

pumping out and removal.

Costs for systems to trap and filter contaminants were estimated at approximately $30-

35,000 for a marina with approximately 250 berths and close to $100,000 for a marina

with approximately 600 berths. Some marinas have already installed these devices but

others will still face these costs. For grossing up we assume $120-170 per berth.

Costs for wastewater treatment depend on whether it can be discharged directly to

sewer, if storage and pumping systems are needed or if there is a need for a separate

treatment facility. At one marina the costs of a treatment facility were estimated to be

$250,000; another large boat yard estimated their costs at $300,000.

For collection and discharge to sewer the costs include commercial rates of pumping

and disposal. One boat yard quoted costs for a 70 metre boat that took approximately 12

hours to water blast; the water blasters were operating using 75 litres/minute (a total of

54,000 litres), with costs of disposal of approximately 15c/litre ($8,100 total) plus

pumping costs of $200/hr ($2,400), ie a total of $10,500 or $150/metre of boat length.

Constructing a $250-300,000 treatment plant makes sense given these costs.

Assuming similar costs would apply to smaller boats, we might assume that costs for

treatment will approximate $1500 for a 10 metre boat. Given these potentially very high

costs, most marinas are examining alternative ways to deal with these wastes, including

through constructing their own treatment plants.

Examining just the costs of the filtration system, at $120-170/berth, there would be a

total cost for NZ of $1.4 – 1.9 million if all marinas have to install filtration systems

(based on 11,586 marina berths). Assuming some have done so already, this might

reduce to $1-1.5 million. To put in context, marina charges vary in NZ, for example

Westhaven marina in Auckland charges between $434 and $1,968.50 per month ($5-

23,000 per annum). The costs of the filtration systems (spread over 10 years at 8% real)

would result in an increase of 0.1-0.5% in charges. In contrast, Nelson marina charges

$2,250 per annum for a 10 metre vessel; here the price increase would be approximately

1%.

3.3.4 Sealing Hard Stands

Discussions with marinas suggest that costs of sealing hard stands could be significant

in some locations. Costs for tar-sealing are estimated to be in the order of $50/m2; one

marina is facing costs estimated at $750,000 for tar seal. However, it is suggested that

only 10-15% of NZ marinas have unsealed hard stands.10

To gross-up to the industry as a whole, we might use the number of berths as a

multiplier and an average cost of approximately $1500/berth.11 If we convert these up-

front costs into an annualised cost, the number of years would be the expected life of the

asset: the tar seal, filter or marina. Conversations with marina operators suggest some

nervousness about the future life of marinas so we have used a conservative 10-year life

10 Personal communication, Philip Wardale, NZ Marina Operators Association 11 We use berths rather than hard stand berths as numbers are available for ‚grossing up‛ nationally

16

and assumed no residual value. At an 8% real discount rate, this would be equivalent to

$224/berth per annum. Assuming that 10-15% of marinas in NZ (equivalent to 1,159-

1,738 berths) require upgrading, this represents a total cost of $260,000 – $390,000 per

annum ($1.7-2.6 million as an up-front cost).

Extending this requirement to small boat yards, eg club and community owned

facilities, may lead to some reduction in the number of locations offering antifouling

facilities. The costs for these could be significant compared to the small number of boats

being maintained there.

3.4 Approved Handler Costs

Early indications by the NZ Marine Industry Training Organisation are that it would

cost around $60,000 to design, write and register an ‘Approved Handler’ qualification

with NZQA. In addition, publication of an E-Learning platform, supported by DVDs

and YouTube links, would cost around $20,000. All current professionals could become

competent to the ‘Bottom Paint Approved Handler’ certification within 3-5 months by

attending training workshops. New employees in this sector would take around 12

months to become fully competent, as verified by their employer and finally assessed by

NZ Marine ITO. In addition to the costs for producing the training materials, there

would be costs for attendees in the form of time. We assume 10 hours of training at an

opportunity cost of $40/hour or $400 each. If there are 100 professional painters (11,000

boats per year and each painter painting two per week) this would be a cost of $40,000

in time value.

Overall costs for a professional system for trainers would be under $200,000.

Enforcing certification requirements for DIY painters would be difficult. Under the

proposed regulations, all DIYers wishing to use products containing Octhilinone, Sea

Nine or Thiram, or for whom spraying is the preferred application method, would be

required to become certified under the above programme. Access to these paints could

be restricted to Approved Handlers at the point of sale, or regulations could work

through requirements (and liabilities) on marinas and others making space available for

DIY painting.

It is likely that these requirements, if enforced would lead to a significant shift from DIY

painting to using professional painters.

3.5 PPE Costs

International Paints (Akzo Nobel) recommends a number of Personal Protective

Equipment (PPE) items should be used when applying antifouling paint. We have

included an indicative price range from NZ Safety for each item (Table 5). The average

cost is approximately $538 (based on 1 litre of barrier cream) for a professional painter.

However, as professional painters are expected to own and use this equipment

currently, the cost of compliance would be minimal.

17

Table 5 Possible costs for Personal Protective Equipment

PPE Azko Nobel Recommendation NZ Safety Price Range

Face Mask “Spray application will require the use of full face masks and respiratory protection”

$316 - $414

Gloves “Chemical resistant gloves should be worn” $5 - $81

Overalls “A cotton overall (minimum 60% cotton) with full length sleeves and legs should be used”

$92 - $131

Barrier Cream “Barrier cream should be used on exposed skin” $13 - $24 (per litre)

Total $426 - $650

Source: International Yacht Paint (2012) Personal Protective Equipment (PPE)

www.yachtpaint.com/nzl/diy/health-safety-and-environment/personal-protective-equipment.aspx

NZ Safety (2012)

www.nzsafety.co.nz/servlet/Srv.Ecos_Signon?CN=15366&AC=185E7D4D361E7D4D&UC=NZSGUEST

For DIY painters there are simpler lower cost options available from DIY shops with

total costs adding to no more than about $60-70 for goggles, a respirator mask, gloves

and disposable overalls; for those using brush and roller the costs would be only for

gloves and overalls – approximately $30. Using these numbers, we estimate total costs at

$272,800 (Table 6), but this assumes that all DIYers currently have no equipment.

Table 6 Costs of DIY PPE

Cost Proportion(1) Number(2) Cost

Brush & roller $30 75% 5,280 $158,400

Spray paint $65 25% 1,760 $114,400

Total Weighted average = $39 100% 7,040 $272,800

(1) Taken from NIWA (op cit); (2) Total = 64% of 11,000 small boats per annum.

3.6 Summary of Costs

In Table 7 we summarise the impacts discussed in this section. In the next section we

discuss possible responses to the regulations in the form of changes in behaviour that

might alter these costs and their incidence.

The response to these costs will mean that some people will face costs that are different

from those estimated above. For example, there will be some shift from DIY painting to

professional painting of small boats.

18

Table 7 Total Impacts

Category Small boats Large boats Total

Paint bans Some increase in costs: 5-10% in short run for those using banned paints; negligible in long run

Some increase in costs: 5-10% in short run for those using banned paints; negligible in long run

Less than $0.2 million per annum(

Enclosed work areas Can be managed

through brush and roller painting.

Fence screening likely to be acceptable

Potentially high costs if

full encapsulation is required

Costs depend on

whether complete enclosure is required. High costs for large boats

Collection and disposal of waste

Filtration systems equivalent to $120-170/marina berth

Mostly in place $1-1.5 million for filtration systems

Sealed hard stand 80-85% of marinas

already have sealed hard stands

Not applicable $1.7-2.6 million up-

front or $260-390,000 per annum.

Approved handler Some impact – cost for DVD or on-line training (less than $100 per person)

Small impact Total of less than $0.5 million

PPE requirement Up-front costs of approximately $40

No impact –

professional painters likely to have equipment already

$0.3 million

Total <$5 million pa

19

4 Response and Counter-Factual

In this section we discuss two issues:

Expected responses to the regulations, including shifts in behaviour;

The question of what would happen in the absence of the proposed regulations,

ie the counter-factual. This particularly addresses other sources of regulation.

4.1 Response

In most cases the regulations are not expected to lead to significant changes in

behaviour. Paint bans can readily be accommodated with existing substitutes and costs

are relatively small. Requirements for improvements at marinas appear to be treated as

requirements to meet a variety of regulations, both from central and local government;

as such it is expected that the costs will be passed on in marina fees and not in charges

for antifouling. These prices are not expected to lead to a reduction in the rate of

antifouling but overall increases in costs of boat ownership may reduce total numbers of

boats.

Requirements for approved handlers of paints to undertake painting is likely to have

the most significant impact. This is likely to shift more people towards using

professional painters rather than DIY painting, and as above, may lead to an overall

reduction in boat ownership amongst pleasure boaters.

It is possible that there will be some increase in the number of boats that are not painted

but this is likely to be a very minor response.

4.2 Counter-Factual

4.2.1 Local Government Regulation

One of the issues that became obvious in discussions with marinas and boatyards was

that many of the investments made already to deal with pollution from antifouling

paint had been to address other legislative or regulatory requirements. This included:

Air quality policy that restricted the ways in which paint could be applied;

Water quality policy that restricted the extent to which contaminants could enter

water bodies and the marine area; and

Requirements for the treatment of wastewater.

As an example, the Auckland Regional Plan Coastal (Chapter 20) defines, as a permitted

activity, discharge of any contaminant resulting from the cleaning, anti-fouling or

painting of vessels, subject to the following conditions (20.5.1):

a. the discharge or escape of contaminant materials or debris onto the foreshore, seabed or

into the water shall be collected as far as practicable and removed from the coastal marine

area; and

b. any discharge will not, after reasonable mixing, give rise to any or all of the following

effects:

20

i the production of any conspicuous oil or grease films, scums or foams, or floatable or

suspended materials; or

ii any conspicuous change in the colour or visual clarity water in the coastal marine

area; or

iii any emission of objectionable odour; or

iv any significant adverse effects on aquatic life, and

c. no discharge of contaminants from this activity shall occur into Coastal Protection Areas

1, other than those in Table 20.2, and Tangata Whenua Management Areas.

NB: the installation of collection devices such as ground covers, netting or other devices to ensure

the collection of any contaminant or debris from the operation may be necessary to comply with

this rule.

These rules only apply to areas in the Coastal Marine Area (below Mean High Water

Spring) such as tidal cleaning grids; it does not include marina hard stand areas which

are covered under the Industrial or Trade activities rules of the Air Land and Water Plan

(ALWP). The Auckland ALWP includes the requirement that ‚Wastewater produced by

the Industrial or Trade Activity [that includes boat or ship construction, repair or

maintenance ] shall be collected either for recycling, or disposal to a system or facility with all

the appropriate authorisations to accept wastewater of that type.‛

Thus, with the exception of bans on individual paints, much of what is being required

under regulations proposed by the EPA will occur anyway under local council

requirements. This has implications that include:

the regulations may not be necessary s the results will occur anyway;

the costs of regulation by the EPA will be low because there is little need for

additional investment or activity.

We note also that the Auckland Council is applying rules that are consistent across more

than one contaminant, ie the rules do not apply only to antifouling paints but to other

commodities and activities that produce similar effects. This approach is consistent with

comments made to us by some who would be affected by the regulations, for example

those arguing that requirements for the envelopment of boats being painted with

antifouling paints went beyond the requirements for painting using isocyanates that

were likely to bear high risks.

4.2.2 Health and Safety

Comments were also made that some of the requirements for protective equipment

were also covered by health and safety regulations and that these were driving the shift

towards safer working practices. As with the comments about the local government

environmental rules above, such approaches also enable a more consistent approach

across a variety of substances and activities.

4.2.3 Voluntary Activities

There is some voluntary activity to improve marinas under the umbrella of the Clean

Marina Programme. This might be motivated by demand by boat owners for clean

marinas or the threat of regulation. Conversations with marina owners suggest that the

21

latter is the more important driver: there is a general anticipation that marinas will need

to control their impacts on the environment and discharges to the marine environment

in particular. However, we cannot use this as a reason for downplaying the impacts of

actual regulation: that would imply that the threat of regulation is always sufficient as a

way to induce behaviour change, but this cannot be true over the long run. Responding

to the threat of regulation is simply investing early when this fits better with a firm’s

own investment cycle.

The impacts of other regulations are a more important factor in determining the extent

to which the impacts are downplayed.

22

5 Benefits

The primary benefit of the proposed regulations will be a reduction in the risk of

harmful effects on the environment and on human health.

5.1 Ban on products containing Chlorothalonil, Diuron and Irgarol

Irgarol is not currently approved for sale in the New Zealand market, but was shown to

be very toxic to marine life, to be highly persistent, and to bioaccumulate in aquatic

plants. Similarly, derivatives of chlorothalonil bioconcentrate substantially in oysters,

and is possibly carcinogenic to humans.12 Diuron has the following toxicological

effects:13

Slightly toxic to mammals, however the only reported case of human exposure

produced no significant symptoms.

Prolonged exposure in rats has shown changes to the spleen, bone marrow,

changes to blood chemistry, increased mortality, growth retardation, abnormal

blood pigment, and anemia.

Diuron is moderately toxic to fish and highly toxic to aquatic invertebrates.

The EPA’s preliminary risk assessment found that, even when the highest level of PPE is

worn, paints containing diuron may lead to adverse health effects to users. Banning

these products will result in reduced harm to human users, in addition to a reduction in

the harm done to, and concentration in marine life.

Figure 5 shows the results of the assessments made of human health and

ecotoxicological risks using risk quotients. It shows the maximum risk levels identified

for any one substance.

Ecotoxicological risk quotients (RQs) are calculated as the environmental concentrations

of a substance relative to the non-effective concentration; the maximum exposure which

‚ensures an overall protection of the environment‛.14 RQs for human health compare

the predicted exposure (dermal or through inhalation) with an acceptable operator

exposure level, identified in relevant studies. Therefore in either category, a RQ above 1

indicates that biocide levels are likely to lead to adverse effects.

The figure illustrates how the risks specifically associated with ziram, diuron,

chlorothalonil and irgarol are considerably greater than those for the other ingredients.

Diuron has the lowest risk levels amongst those proposed for banning, but in human

health risk terms it has a maximum risk identified of 15.8 for a non-professional using

PPE compared to a highest identified level of 5.0 and 4.6 for octhilinone and thiram

12 EPA (2012) Antifouling paints reassessment 13 Extoxnet (2012) Pesticide Information Profile: Diuron. http://extoxnet.orst.edu/pips/diuron.htm 14 For more information, see EPA (2012) Preliminary Risk Assessment and the Technical Guidance

Document on Risk Assessment at http://ihcp.jrc.ec.europa.eu/our_activities/public-

health/risk_assessment_of_Biocides/doc/tgd

23

respectively; DCOIT (Sea Nine) has a risk quotient of 10.1 for ecotoxicological effects,

slightly below that for copper which is present in most products.

Figure 5 EPA Maximum Risk Assessment Results

Source: EPA

The benefits of banning the proposed products are that the only paints available will be

those with lower risk quotients. The practical effect of this has not been straightforward

for us to identify. Ideally the implications could be specified in terms of expected

changes in incidents of specific health effects or hospitalisations, or in observable

ecological effects. However, we have not identified data to enable us to do this.

The benefits of reductions are thus left in this study as a residual and we concentrate on

providing information on costs.

5.2 Marina and Dock Improvements

Requiring the collection and safe disposal of all waste from antifouling, asphalt sealing

of areas for paint application, and spraying within an enclosed work area, will all

contribute to reduced concentrations of biocides in the aquatic environment. As

discussed above, these substances can be highly toxic to elements of the marine system,

and can concentrate in shellfish leading to harmful outcomes for human consumption.

5.3 Approved Handler Qualification and Protective Equipment

The risk posed by the different biocides is significantly reduced by wearing less

permeable coveralls. Additionally, a face mask, gloves and boots all reduce the levels of

exposure through inhalation or through the skin. High-pressure spraying is the task

63.3

15.8

9.6

5.0 4.6 4.52.5 1.8 1.6 1.3 0.9 0.9 0.8 0.8 0.8 0.7 0.6 0.41.0 14.8 14.8 8.7 2.7 14.8 11.3 11.3 2.5 1.0 1.0 11.3

102.1

0.5 10.1 5.1

755.2

10.10

100

200

300

400

500

600

700

800

0

10

20

30

40

50

60

70

80

Zira

m 5

%

Diu

ron

7%

Diu

ron

4.2

3%

Oct

hili

no

ne

1.4

%

Thir

am 3

%

Diu

ron

2%

Co

pp

er 5

2.4

%

Co

pp

er 3

8.1

%

Pyr

ith

ion

e (c

op

per

an

d z

inc)

3%

Dic

hlo

flu

anid

4.2

%

Dic

hlo

flu

anid

2.9

2%

Co

pp

er 1

6.8

%

Ch

loro

thal

on

il 7

.9%

Zin

eb a

nd

Man

coze

b 6

.92

%

DC

OIT

2.1

3%

Glo

bic

Toly

lflu

anid

5%

Irga

rol 3

%

DC

OIT

2.1

3%

Ris

k Q

uo

tie

nt

(Eco

toxi

colo

gica

l)

Ris

k Q

uo

tie

nt

(Hu

man

He

alth

)

Human health (left axis)

Ecotoxicological (right axis)

Series4

24

with the highest risk, highlighting the importance of users being qualified to apply

antifouls in this way.

Thiram, which might be the most common biocide by market share after the bans take

effect, has been shown to cause headaches, dizziness, fatigue, nausea & diarrhea.15

Taking steps to ensure users of these paints are very aware of the hazards, trained in the

task they are performing, and equipped with appropriate levels of PPE will all result in

improved health outcomes.

In addition to benefits of using PPE, there may be benefits associated with painting by

professional painters rather than non-professional. We show the EPA’s risk assessments

for Octhilinone, Thiram and Sea Nine (DCOIT) in Figure 6; these would be the highest

risk paints used after the bans were in place. There are differences in frequency of

painting (once every year or more for non-professional (DIY) painters, as discussed in

Section 2.1.2 vs daily or weekly for professionals), but we understand that these are

taken into account in identifying the risk quotients. Thus there is a significant change in

risk by shifting to professional painters.

Figure 6 Human health risk quotients for non-professional and professional applicators

Source: EPA data

15 Extoxnet (2012) Pesticide Information Profiles: Thiram. http://extoxnet.orst.edu/pips/thiram.htm

0

1

2

3

4

5

6

Non-professional Professional Professional Professional

Ris

k Q

uo

tie

nt

Octhilinone 1.4% Thiram 3% DCOIT 2.13%

(Brush & Roller) (Brush & Roller) (Mixing & Loading) (High Pressure Spray)

25

6 Summary and Conclusions

6.1 Bans on Individual Paints

Paints proposed to be banned are those that have high risk quotients for human health

or ecotoxicological risks.

The bans on paints will have little total impact on costs. There appear to be substitutes

available in all markets, allowing consumers to switch products. The impacts will fall

mainly on the producers and importers of the products proposed to be banned; this is

particularly Awlcraft currently. However, phasing in the ban would enable new

formulations to be developed allowing firms to maintain market share.

6.2 Improvements to the Location of Painting

Improvements to the location of painting include sealing hard stands, isolation of

painting via enclosure behind fences (or in full encapsulation) and collection and

disposal of wastes. All of these measures would be expected to yield benefits, although

many are being undertaken anyway as a result of requirements imposed by local

authorities and other government departments, eg Occupational Safety and Health

(OSH) regulations. This means that the costs directly attributable to these regulations for

antifouling paint may be limited; but it might also suggest that the regulations are

unnecessary.

We note the comments made by several industry members spoken to that introducing

regulation specifically for antifouling paint was somewhat inequitable. It might also be

inefficient. Addressing issues more generically through regulations that tackled all

sources of pollution to air or water, and all substances, in a consistent way would

reduce the regulatory costs while addressing these equity issues.

That said, the measures proposed appear to be accepted by most as inevitable and,

while in some cases resulting in significant costs, as being reasonable requirements to

protect the marine environment. It is likely that the level of costs will be too great for a

number of small boat yards and that there will be some consolidation of where boat

maintenance and painting takes place. This will limit choice for small boat owners.

6.3 Improvements to Paint Handling

Improvements to paint handling include requirements for approved handlers and PPE

requirements. The latter appears to be a relatively low cost measure with DIY stores

selling equipment that could improve safety. The requirement for approved handlers

could have a significant impact on activity if it effectively stopped DIY painting. This

would result in small boat owners facing increases in costs of between 100% and 400%

of their current paint costs, although the perceived impacts will depend on how they

value their time.

There will be ways in which these costs might be minimised, including through

supervision by marinas, eg checking that people are using adequate PPE and using

26

spray equipment under the right weather conditions. These costs would need to be

covered via increases in haul-out charges.

27

Annex 1 Impacts of Ban on Copper Paints

Table A1 presents the cumulative effect of banning paints in order of maximum risk

quotient, for the scenario which includes copper. It clearly demonstrates that banning

copper would be infeasible given the lack of substitute paints currently available.

Table A1 Cumulative Effects of Paint Bans (shaded paints not currently available on NZ market)

Ingredient

Banned Max RQ

Paints Avail.

Paints Avail. Al compatible Paint Types(1)

Retail Comm. Retail Comm. A SP R H

Nothing banned 239.6 34 13 21 4 3 4 19 3 3

Irgarol 102.1 34 13 21 4 3 4 19 3 3

Chlorothalonil 63.3 34 13 21 4 3 4 19 3 3

Ziram 15.8 33 13 20 4 3 3 19 3 3

Diuron 11.3 25 9 16 4 2 3 14 2 2

Copper 10.1 0 0 0 0 0 0 0 0 0

DCOIT 8.7 0 0 0 0 0 0 0 0 0

Octhilinone 7.6 0 0 0 0 0 0 0 0 0

Thiram 4.9 0 0 0 0 0 0 0 0 0

Mancozeb 4.5 0 0 0 0 0 0 0 0 0

Tolylfluanid 4.4 0 0 0 0 0 0 0 0 0

Zinc Pyrithione 2.5 0 0 0 0 0 0 0 0 0

Copper Pyrithione 1.3 0 0 0 0 0 0 0 0 0

Dichlofluanid 0.8 0 0 0 0 0 0 0 0 0

Zineb 0 0 0 0 0 0 0 0 0

(1) A = Ablative, SP = Self-Polishing, R = Resin, H = Hard

Source: EPA (including industry questionnaires); Material Safety Data Sheets; advertised information

from paint manufacturers.