During a pre-purchase survey of a 1998-built vessel, you discover the hull has TBT-based anti-fouling paint. What are the regulatory implications for a UK coastal operator?

A. TBT (Tributyltin) ANTI-FOULING — AFS Convention: the International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention) entered into force 17 September 2008. PROVISIONS: (1) PROHIBITION: since 1 January 2008, all vessels are prohibited from applying or re-applying TBT-based anti-fouling systems; (2) VESSELS BUILT BEFORE 2003: if the TBT coat is intact and not applied after January 2003, the Convention required either: (a) the TBT coat must be removed; OR (b) sealed with an overcoating that prevents TBT leaching; (3) INTERNATIONAL ANTI-FOULING SYSTEM CERTIFICATE (IAFS Certificate): required for vessels of 400 GT+ on international voyages. Confirms the vessel does not use TBT and complies with the AFS Convention; (4) PRACTICAL IMPLICATION for your vessel: a 1998-built vessel with original TBT paint — the paint is potentially still leaching TBT (which is toxic to marine organisms, particularly shellfish — causes imposex, a sex change, in gastropods at extremely low concentrations). REQUIRED ACTION: remove or seal the TBT coat in accordance with AFS Convention requirements before operating. The vessel cannot lawfully enter most ports while TBT is actively leaching; (5) DECLARATION: AFS Declaration required for vessels under 400 GT.

B. TBT anti-fouling paint was only prohibited for new ships built after 2008. Vessels built in 1998 are permanently exempt as historic ships.

C. The TBT prohibition only applies in designated Special Areas. UK coastal waters are not a TBT-restricted area.

D. TBT paint cannot be detected by port state inspectors. Purchase the vessel and repaint with compliant anti-fouling during the next drydock cycle — no immediate action is required.

A. MARPOL Annex I bilge water discharge — small vessel rules: MARPOL Annex I Regulation 15 covers machinery space bilge water. For vessels of 400 GT and above: bilge water may be discharged overboard only if: (a) outside Special Areas; (b) more than 12nm from the nearest land; (c) vessel is en route (not at anchor or in port); (d) oil content does not exceed 15 ppm (monitored by approved OCM); (e) Oil Record Book entry made. For vessels BETWEEN 400 GT and 400 GT (your vessel at 350 GT): MARPOL Annex I Regulation 15.2 applies a different regime — vessels of less than 400 GT must retain oil residues and bilge water on board or deliver to port reception facilities. There is no 15 ppm discharge provision for vessels under 400 GT outside special areas. PRACTICAL IMPLICATION: your 350 GT vessel CANNOT legally discharge bilge water overboard at 8nm. Options: (a) Pump to the bilge holding tank; (b) Continue to port and discharge to reception facilities; (c) If flooding emergency — it may be necessary, but this is a distress provision only.

B. Any vessel can discharge bilge water beyond 3nm from shore. MARPOL only applies to vessels over 1000 GT.

C. Discharge is permitted at 8nm as long as the bilge water is mixed with sea water to reduce the oil content below 50 ppm.

D. MARPOL does not apply within territorial waters (12nm). Beyond 12nm, all bilge water discharge by any vessel is unrestricted.

A. MARPOL Annex V (as amended 2013) — garbage discharge: (a) FOOD WASTE: may be discharged in territorial sea (>3nm from nearest land) or in special areas (>12nm from nearest land) only when comminuted or ground (passed through 25mm mesh) and the vessel is en route. Outside special areas and >12nm from land: food waste may be discharged without comminution provided it does not create a floating debris hazard; (b) PLASTIC — ALL FORMS: completely prohibited for overboard discharge in all ocean areas. This includes synthetic fishing nets, plastic bags, plastic packaging of any kind. No minimum distance applies — plastic NEVER goes overboard; (c) PAPER, RAGS, GLASS, METAL, CROCKERY: prohibited within 12nm from nearest land; permitted (outside special areas) beyond 12nm from land. IN THIS SCENARIO: food scraps at 15nm — permitted with caution (outside special area, >12nm, en route). Plastic — ABSOLUTELY PROHIBITED at any distance. Paper — permitted at 15nm in non-special areas. A Garbage Management Plan (for vessels 100 GT+) must be carried and followed.

B. Food scraps and paper can always be discharged more than 3nm offshore. Plastics can only be discharged if they are biodegradable.

C. MARPOL Annex V only applies to commercial vessels over 5000 GT. Small near-coastal vessels are exempt from all garbage regulations.

D. All waste can be discharged at more than 12nm offshore — this is the MARPOL Annex V general limit for all waste types.