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Hull Surface Treatment (HST)

Working In Ports & Harbours

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“It is the Simplicity that lies beyond the Complexity”

In support of the proposed use of Hull Surface Treatment (HST) technology within Australian Ports and Harbours the following research, legislation and determinations are relied upon:

Ships travel faster through water, consume less fuel and emit lower Green House Gases when their hulls are clean and smooth – free from fouling organisms, such as slime, algae, weed and/or molluscs. This in turn ensures that hull fouling on commercial shipping is eliminated as a vector for the introduction of Imported Marine Pests (IMPS).

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. During the 1960’s the chemicals industry developed efficacious and cost-effective anti-fouling paints using metallic compounds, in particular the organotin compound tributylin (TBT). By the 1970’s, 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, TBT was shown to cause shell deformations in oysters; sex changes in whelks; and immune response, neurotoxic and genetic affects in other marine species.

In the 1970’s – 1980’s, high concentrations of TBT in shellfish on the coast of France caused the collapse of commercial shellfisheries in at least one area, and this prompted many States to act and enforce some restrictions on the use of TBT in anti-fouling paints. In 1988, the problem was brought to the attention of the Marine Environment Protection Committee (MEPC) of the International Maritime Organisation (IMO), the United Nations Agency concerned with the safety of shipping and the prevention of marine pollution.

As a result, IMO in 1990 adopted a resolution recommending governments to adopt measures to eliminate anti-fouling paints containing TBT. In the 1990’s, the MEPC continued to review the environmental issues surrounding anti-fouling systems, and in November 1999, IMO adopted an Assembly resolution that called on the MEPC to develop an instrument, legally binding throughout the world, to address the harmful effects of anti-fouling systems used on ships. The resolution called for a global prohibition on the application or organotin compounds which act as biocides in anti-fouling systems on ships by 1 January 2003, and a complete prohibition by 1 January 2008.

It has taken 20 years to establish an international response to harmful anti-fouling paint systems. It is clear from all available information that a technology similar to Hull Surface Treatment (HST) was never contemplated when the current legislation was introduced around the world. Albeit there are numerous references to the urgent need for an effective, environmentally safe anti-fouling process.

In October 2001, IMO adopted a new International Convention on the Control of Harmful Anti-fouling Systems on ships, which prohibits the use of harmful organotins in anti-fouling paints used on ships and establishes a mechanism to prevent the potential future use of other harmful substances in anti-fouling systems.

Resolution A.895(21) adopted on 25 November, 1999
Anti-Fouling Systems Used On Ships

The IMO 21st Assembly on 25 November 1999 said among other things that...

“RECOGNIZING the need to continue to develop anti-fouling systems which are effective and environmentally safe,

HAVING CONSIDERED the recommendations made by the Marine Environment Protection committee at its forty-second session

At Resolution 3...”URGES ALSO Member Governments to encourage industries to continue to develop, test and use as a high priority anti-fouling systems which do not adversely impact on non-target species and otherwise degrade the marine environment”.

In his 2007 address to the International Maritime Organisation, the Secretary-General Mr. Efthimios E. Mitropoulos delivered a paper entitled “Shipping’s Environmental Credentials”. He said, “My concerns in the area of the International Convention on the Control of Harmful Anti-fouling Systems on ships are three fold: first, that, by not bringing the instruments mentioned above and other relevant ones into force at a reasonable time after their adoption, their implementation is delayed, thereby depriving the environment of their beneficial effects; second, that any further delay in tackling the issues regulated by these instruments may motivate individual countries or groups of countries to develop unilateral or regional measures, with all the attendant negative repercussions such action entail; and, third, that any prolongation of the situation may lead to ambiguities, which, in the final analysis may count against seafarers, the maritime industry and the environment.

In the world of global business today, it is not unusual to find major commercial concerns freely embracing the notion that good environmental and social stewardship actually make good business sense. Companies are learning the value of their own environmental credentials as their markets and their customers become increasingly sensitized to environmental issues. Shipping is no different from any other industry in that, both collectively and individually, shipowners and operators need to protect their brand image.

However, there is an inherent quandary in the fact that, on the one hand, everybody, it seems, wants more for less – while, on the other, society’s concerns about safety and the protection of the environment continue to grow. Of course, shipping needs to do whatever it can to solve this apparent conundrum; but, in the long term, society will need to address its own priorities and understand that nothing comes for nothing.

Shipping has to ensure that its activities are sustainable, which, in this context, is normally understood to mean that any negative impact an activity may have on the environment must be reduced to the point where it is clearly outweighed by the positive benefits that the activity brings. However, I believe we are rapidly approaching the time when we should move beyond this and understand that caring for our environment must become out top priority, even though that may come with an economic price.

One of the greatest challenges faced by anyone involved in environmental work is how to overcome the feeling that, because of the sheer scale of the problems to be addressed, individual efforts appear minuscule by comparison with the daunting tasks ahead. At such times, it is always helpful to remember that the efforts of each and everyone contribute to a bigger picture and that there are very capable, clear-sighted people and organisations that not only have a view of it all, but are also getting to grips with it.”

Commercial Diving Services Pty Ltd has risen to the challenge in their development of Hull Surface Treatment (HST) technology.

APEC Marine Resource Conservation Working Group ( November, 2001) in developing a Regional Risk Management framework for APEC economies for use in the Control and Prevention of Introduced Marine Pests.

Responses which should be considered...The Rio Declaration notes that ‘where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation’.

APEC economies ranked commercial shipping as the most important factor affecting the strength of pathways transporting introduced marine pests... Managing the threat of introduced marine species can be done effectively through a hierarchical approach similar to that used to manage infectious diseases. There are 6 essential elements to this hierarchy: prevention, detection, quarantine, eradication, control, and mitigation. Ideally managing the threat should occur at the earliest possible time in this hierarchy.

In their final statement they said, “The translocation of marine organisms and micro-organisms beyond their natural environment is a serious and escalating problem in the region, particularly given the environmental, economic, cultural and social impacts of marine pest species and the reliance of many APEC economies on their marine and coastal resources. Once a marine pest is established remediation is often not possible or extremely costly. Given the rapid spread of marine pests, urgent action is essential.

HULL SURFACE TREATMENT (HST) TECHNOLOGY is the long awaited solution to this serious problem, provided it is used in a programmed and pre-emptive maintenance regime eliminating the primary spore, slime and algal growth. A localised thermal sterilisation of primary fouling, effectively eliminating the opportunity for secondary and tertiary fouling to occur. A stitch in time.

In their subsequent PHASE II Consultancy Report in 2005 the Centre for Maritime Policy, University of Wollongong, in collaboration with APEC Economies further considered the management, prevention and control of Introduced Marine Pests in the APEC Region. Throughout the 86 page report the theme remained on tune, i.e. the critical nature of establishing an effective protocol to prevent and/or reduce the incursion of Imported Marine Pests.

Code Of Practice for Antifouling and In-water Hull cleaning and Maintenance

An ANZECC strategy to protect the marine environment. The Maritime Accidents and Pollution Implementation Group consisted of numerous state and federal agencies including:

Ms Barbara Richardson from NSW Environment Protection Authority.
Pauline Semple - Queensland Environmental Protection Agency
Prue Gaffey - Environment Australia
Paul Nelson – Australian Maritime Safety Authority
Helge Pedersen – Dept of Land Planning and Environment Northern Territory
Dr Paul Vogel – department of Environmental planning Western Australia
Ian Kirkegaard – Department of Environment South Australia
Phillip Johnstone – Victorian environment Protection Authority
Jon Delaney – Royal Australian Navy Environment
Jim Huggett – Queensland Transport maritime
Jonathon Barrington – Australian Quarantine & Inspection Service
Rob Dineen – Department of Primary Industry, Water & Environment Tasmania

Their findings at Section 5, state... ‘Hosing and brushing down activities, without the use of detergents or abrasives to remove weed and barnacles, generally do not require specialised treatment to retain and dispose of material removed. However, if the material includes live organisms from another country or a distant part of Australia, all debris should be collected for disposal as solid waste. Check with the port or marina management on controls on ballast or fouling organisms.’

Hull Surface Treatment (HST) Technology does not damage or remove any of the anti-fouling paint. Primary spore, slime and algae are terminated via thermal sterilisation and does not dissolve or come away from the vessel whilst in the sensitive coastal zone, harbour or port. And therefore does not breach any of the recommendations in the Code of Practice.

At the request of the NSW Department of Environment, independent water testing was undertaken by Eco Wise Environmental whilst HST was being used in Sydnet Harbour. A summary of their findings is linked at the bottom of this page.

Section 7 states...’This code of Practice also includes other measures aimed at protection of the health of workers and of the environment.

When best practice improves on these measures, best practice should be adopted’.
HST is a vast improvement on current Best Practice and is the simplicity that lies beyond the complexity.

The International Convention on the Control of Anti-Fouling Systems on Ships, 2001 (HAFS)

Adopted by the IMO on 5 October 2001. On the 9 January 2007, Australia became a Party to the HAFS Convention, which has been implemented in Australian domestic legislation by the Protection of the Sea (Harmful Anti-fouling Systems) Act 2006 which commenced on 17 September 2008. Its purpose is to ban the use of organotin compounds which act as biocides in anti-fouling paints on ships, specifically tributyl tin (TBT) based anti-fouling paints. Australia is a Party to the Convention administered by the International Maritime Organisation (IMO). Article 8 (1) says, ‘The parties shall take appropriate measures to promote and facilitate scientific and technical research on the effects of anti-fouling systems as well as monitoring of such effects. In particular, such research should include observations, measurement, sampling, evaluation and analysis of the effects of anti-fouling systems’.

Commercial Diving Services Pty Ltd have used Hull Surface Treatment (HST) technology for various clients including Svitzer, TeeKay Shipping, International Paints and Inco. Those vessels include the MV Torrens, Pacific Triangle and several Tugs. The success of these applications has underpinned further progress by the regulatory authorities.

Hull Surface Treatment (HST) technology has undergone credible and exhaustive environmental testing in what is arguably the most beautiful harbour in the world. And after meetings with:

The Federal Department of Agriculture Fisheries and Forestry
Australian Quarantine Inspection Services (AQIS)
The New South Wales Department of Fisheries
New South Wales Maritime
New South Wales Department of Environment and Climate Change(DECC)

The Sydney Harbour Ports Authority has issued Commercial Diving Services Pty Ltd with work permits to operate Hull Surface Treatment (HST) technology within Sydney Harbour. The first such treatment was performed on Carnival Australia’s Pacific Dawn on 16 April, 2009.

Hull Surface Treatment (HST) technology uses no paints, chemicals, detergents, poisons or substances which are foreign to the marine environment.

It does not perform any physical damage or harm to the marine environment.

Hull Surface Treatment technology was not contemplated when current legislation was enacted and whilst technically, its application falls broadly within the definitions of an ‘anti-fouling system’, that definition was primarily directed at paint/chemical applications to the external hull of a ship.

Hull Surface Treatment technology has evolved from a vast knowledge of the sea, thirty five years of underwater experience and a passion for green, environmentally sustainable technology.


Supporting Documents

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Australian Government - Department of Agriculture, Fisheries and Forestry

Aquenal Pty Ltd - Aquatic Environmental Analysts - Marine, Estuarine and Coastal Assessment

EcoWise Environmental - Report on effects of HST treatment on Harbour Water



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