Scrubbing Laws?

Tim Good

Tim Good

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Ok here goes! This is maybe as controversial as starting a post entitled “anchors”.

I can’t find any specific law prohibiting scrubbing yet. All I see is the Water Resources Act 1991 regulate any polluting matter entering controlled waters and this legislation applies to all marine businesses.

I appreciate some harbours have banned scrubbing but presumably that is a ban against polluting the water not specifically against the act of scrubbing.

My Point:

So this year I have taken back our boat to bare gel shield. All antifoul gone. I want to attempt a season without antifoul for environmental reasons.
We’re lucky enough to have legs and can dry out. I figure I can happily do a season if I scrub once or twice over a 5-6 month period providing we’re living aboard and moving around a fair bit.
 
Surely
Tim Good said:
Ok here goes! This is maybe as controversial as starting a post entitled “anchors”.

I can’t find any specific law prohibiting scrubbing yet. All I see is the Water Resources Act 1991 regulate any polluting matter entering controlled waters and this legislation applies to all marine businesses.

I appreciate some harbours have banned scrubbing but presumably that is a ban against polluting the water not specifically against the act of scrubbing.

My Point:

So this year I have taken back our boat to bare gel shield. All antifoul gone. I want to attempt a season without antifoul for environmental reasons.
We’re lucky enough to have legs and can dry out. I figure I can happily do a season if I scrub once or twice over a 5-6 month period providing we’re living aboard and moving around a fair bit.
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Surely if you are down to gel coat, you will only scrubbing what the water has stuck to your boat and you will be giving back.
 
Have a look at the current Environmental Permitting Regulations and Reg 12(1)(b) in conjunction with Reg 38.
None of this is easy and, every now and then I have to be an expert on it, but it needs quite a bit of headscratching.
At first blush, (a) putting back in water what came from seawater would not likely be pollution (which is different if antifouling is added to the mix) and (b) a 'water discharge activity' is defined in Reg1 which points to Paragraph 3 of Schedule 21 which refers to "the discharge or entry to ...coastal waters" and therefore scrubbing whilst afloat would not (again at first blush) come within those terms as whatever you scrub off is already in the water. It is different if it is your waste tank or a ballast tank. On your scenario, it wouldn't be polluting matter anyway.
 
NZ has scrubbing laws right, and they apply whether you are antifouled or not? I am ahead of the curve with my hippie furry hull coating but I think it would still catch me out
 
ryanroberts said:
NZ has scrubbing laws right, and they apply whether you are antifouled or not? I am ahead of the curve with my hippie furry hull coating but I think it would still catch me out
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Yes exactly. So many laws target the action rather than focusing on the purpose as it’s easier to define and avoids subjectivity.

So in this case I don’t want to be caught out by scrubbing even if my de facto result is not polluting or if my actual intention is to avoid polluting by not antifouling.
 
Tim Good said:
Yes exactly. So many laws target the action rather than focusing on the purpose as it’s easier to define and avoids subjectivity.

So in this case I don’t want to be caught out by scrubbing even if my de facto result is not polluting or if my actual intention is to avoid polluting by not antifouling.
Click to expand...

I don't think you will get any solace in this place. There will be a load of huffing and puffing but nobody will really know.

As you have legs you can do your scrubbing outside the environment and let us all know if it is viable, Which would be very good to know.

.
 
Tim Good said:
Ok here goes! This is maybe as controversial as starting a post entitled “anchors”.

I can’t find any specific law prohibiting scrubbing yet. All I see is the Water Resources Act 1991 regulate any polluting matter entering controlled waters and this legislation applies to all marine businesses.

I appreciate some harbours have banned scrubbing but presumably that is a ban against polluting the water not specifically against the act of scrubbing.

My Point:

So this year I have taken back our boat to bare gel shield. All antifoul gone. I want to attempt a season without antifoul for environmental reasons.
We’re lucky enough to have legs and can dry out. I figure I can happily do a season if I scrub once or twice over a 5-6 month period providing we’re living aboard and moving around a fair bit.
Click to expand...
The other thing that can cause issues in addition to the antifouling side is the invasive/non-native species side of things. Can't speak to specific laws I'm afraid but something to be aware of.
Living/sailing in a SSSI (or similar, I forget the official title) means we're quite under the spotlight from an environmental side.
 
ryanroberts said:
NZ has scrubbing laws right, and they apply whether you are antifouled or not? I am ahead of the curve with my hippie furry hull coating but I think it would still catch me out
Click to expand...
Is that that Finsulate stuff? I've seen it in use, and found it quite underwhelming.
 
geem said:
Do you think you will only need to scrub twice in a season? I would have thought you would need to do it monthly.
Click to expand...

If living aboard and moving I think twice will be ok with the occasional monthly shoreline scrub from the dinghy. Will soon find out :)
 
geem said:
Some people don't even manage a season with antifouling paint on
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We’ve lasted 2 seasons with one application. And thats being in the water over winter also. Largely depends on how it’s applied, the brand and where you are.

We have found good surface prep along with two thin coats works well for long periods. Again depends where the boat is.
 
At Itchenor in Chichester harbour Hains have been scrubbing off racing boats for ever,The boats are put on the hard and scrubbed off they are not antifoul Ed.I kept a grp yacht in Emsworth and dry sailed ,the boatwas I the water about a month and there was marginal growth with no Antifouling applied
 
I think this is why coatings such as Silic One will come to the fore as these do not bleed into the water, and the ocean's critters simply do not stick. My limited introductory experience was excellent, and I will be applying it to Billy Ruffian when the current coating wears a bit. But I didn't do enough miles last year so for me this year just a gentle blast off back into the River simply what the boat has taken from it.
 
Go for it.

In many high fouling areas you will grow grass in a week and barnacles in 2-3 weeks. Does anything grow on the pilings? Scrubbing becomes a weekly affair, which isn't fun. I've known quite a few people who announced they would try this, and they all gave up very quickly.

In the US, including Clifornia and Washington, two of the greenest places around, they have settled on a leaching rate limit, which all good 2-year paints meet. At this reduced leach raqte, copper stays at background levels, which were never zero.
 
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