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Means of avoiding, minimising
and addressing the potential impacts of maintenance
operations
Educate and encourage
Good housekeeping
Provision of reception
facilities and other infrastructure for the collection
of maintenance wastes
It can be seen from the literature review that
it is possible for animals and plants found within
marine SACs to be harmed as a result of maintenance
activities undertaken in port and harbour areas.
However any long-term adverse effects are highly
unlikely to occur. Ports and harbours have no powers
to regulate maintenance activities and marine runoff
which is a matter for the marina or vessel operators
to observe regulations which will be enforced by
the environment agencies who are the relevant authority
responsible for protecting controlled waters against
pollution. Ports can, and should, support campaigns
initiated by the environment agencies, such as encouraging
the observance of their Pollution Prevention Guidelines
for marinas and craft (PPG14) which contain guidelines
for boat maintenance activities (Appendix K).
Maintenance activities undertaken to keep harbours
working must comply with health and safety regulations
and harbour authorities, managers and operators
have a duty of care to prevent and minimise possible
impacts on the environment. In most cases, these
practices are considered sufficient to ensure that
the effects of maintenance activities are insignificant
in relation to the reasons for which the site was
designated and any possible remaining impacts are
likely to be only temporary and minimal in nature.
More serious environmental effects are generally
only likely to occur as a result of poor working
practices and accidents which may cause unnecessary
or increased inputs of toxic maintenance substances
and wastes into harbour waters. Encouraging staff
to follow simple good working practice may reduce
these possible impacts. Many UK harbours already
do this. Where good working practices are considered
insufficient to prevent an identified pollution
problem, harbour infrastructure in outside maintenance
areas can be modified to minimise the amounts of
contaminants entering the marine environment. In
such cases the cost of doing this needs to be weighed
up against the possible environmental benefits.
Public awareness of the steps taken in harbours
to protect the environment needs to be increased.
Suitable actions to reduce the possible impacts
of maintenance activities in harbours, many of which
are already in operation, are outlined below.
Educate and encourage
The education of staff and the public plays an
important role in environmental management. The
emphasis for environmental management in recreational
harbours is placed on the use of voluntary approaches
to educate and raise awareness of possible issues
and to encourage sensitive operation among staff
and harbour users alike. A wealth of environmental
guidance and codes of conduct have been produced
in recent years as a result educational campaigns
aimed at boat owners and other harbour users (Box
21). However, similar guidance for harbour authorities
and their staff remains largely unpublished.
Port and Harbour Authorities should
provide information to all employees of harbours,
marinas, and boat yards to raise awareness of:
- the importance of the area in which they work
for its marine conservation features and the reasons
why it has been designated as a marine SAC,
- the potential environmental impacts that may
occur as a result of maintenance activities undertaken
in the harbour area,
- more environmentally sensitive ways of undertaking
maintenance activities, illustrating practical
and economic benefits where they exist, and
- any future developments in finding effective
alternatives to anti-fouling paints.
Good housekeeping
The majority of the potential pollution problems
that may arise from maintenance activities
within port and harbour areas can be avoided or
minimised by ensuring that all employees follow
simple good housekeeping practices and by the use
of environmentally sensitive alternatives to damaging
cleaning agents wherever practical. However, there
will be cases when harbours are faced with no suitable
effective alternative to the chemical already used
and limited procedures available to reduce pollution.
In such instances steps can be taken to reduce the
amounts of substances being used in the first place.
This type of environmental management is already
widely practised in ports and harbours and examples
of good working practices include the following:
- Staff should be required to sweep up all solid
waste such as paint chippings and sandblasting
wastes and place these in skips for land disposal.
- The occurrence of accidental spills of polluting
substances may be reduced by keeping cans, bottles
and tins securely closed when not in use, and
ensuring that they are given safe storage according
to health and safety requirements.
- Any spillages of cleaning agents, paints
and other maintenance products should be mopped
up and never swilled over the side of jetties
and wharves into the harbour waters.
- After cleaning operations, excess liquids and
algal wastes should be contained and mopped up
as much as possible.
- Where it is difficult to prevent direct discharge
when cleaning jetties and pontoons, ports, harbours
and marinas might discourage or where necessary
prohibit the use of cleaning agents (detergents,
bleaches or oil emulsifiers) and require that
only pressure washing with harbour water is used
for cleaning. However, this should only be carried
out in areas where pressure washing is considered
sufficiently effective not to compromise safety.
- To reduce the amounts of cleaning agents, such
as bleach, being used in harbour areas they could
only be applied to surfaces where there is a safety
risk to the public or staff.
- High priority should be given to finding effective
alternative means of cleaning harbour structures
and vessels with the aim to discontinue the use
of products that contain phosphates and chlorine.
An example of this is the possible use of non-slip
paint products as an alternative to other coverings
on the surfaces of walkways to improve safety
and possibly reduce the frequency of cleaning
operations. Such paints are already used on boat
decks and quaysides, however the paints are resins
and therefore may pose a risk of pollution themselves
in sensitive situations.
Where additional work is generated, such as sweeping
up debris before washing down surfaces or more time
consuming activities are adopted as an alternative
to the use of cleaning agents, such as power washing,
staff costs can be increased. However, equally the
potential benefits and savings to be made by reducing
or stopping the use of, often expensive, cleaning
chemicals should also be considered and promoted.
Boat owners and RYA club members are finding high
pressure washing with water to be an effective way
of removing natural growth and dirt from a variety
of surfaces without the use of chemicals (Eardley
RYA personal communication 1999)
The Environment Agencys guidance note on
pollution prevention for marinas and craft provides
specific guidance for those undertaking boat hull
cleaning, painting and antifouling activities (Appendix
K). This guidance suggests that all maintenance
activities involved in removing and applying antifouling
coatings should be carried out in dry docks or scrub
off areas wherever possible and that when
maintenance activities occur near the waters edge,
the use of suitable screening or barriers will prevent
solids entering the water. Authorisation is required
from the Environment Agency for the use of TBT antifouling
paints on vessels over 25 meters.
Provision of reception
facilities and other infrastructure for the collection
of maintenance wastes
The provision of reception facilities for ship
generated wastes is a statutory requirement for
all ports and terminals, including marinas,
boatyards, yacht clubs, private wharves, and public
slipways (Section 6.4.1). Ports, harbours and marinas
provide general-use skips and bins that can be used
by employees and boat users for the disposal of
non-hazardous maintenance wastes from the harbour
area. In addition, special points for chemical waste
disposal are often provided at major mooring points
and dedicated boat maintenance areas for the collection
of toxic substances, such as oils, antifouling paints
and contaminated scrapings. Where these facilities
are not currently provided, harbour authorities,
managers and operators should give consideration
to their introduction, bearing mind the scale of
maintenance activities occurring the harbour, the
potential for pollution entering the marine environment
and not least of all the costs involved. The safe
disposal of maintenance wastes in reception facilities
can be encouraged by taking the steps summarised
below.
Means of encouraging the safe
disposal of maintenance wastes in reception facilities:
- Locating skips, bins and other containers for
collecting waste in areas that are easily accessible
to staff and boat users.
- Matching the type and capacity of facility provided
with the demand for their use.
- Training staff in their safe and proper use.
- Provision of information to boat owners and
other harbour users on their location and instructions
for their safe and proper use.
- Educating the users of waste reception facilities
about the possible environmental impact resulting
from poorly disposed of waste.
Where pollution from port and harbour maintenance
operations or ship or boat cleaning operations is
identified as a more serious problem, the installation
of infrastructure to collect maintenance wastes
should be considered. This may include the provision
of permanent scrub-off facilities in
boat maintenance areas, which collects residues
from scraping and sandblasting. In order to prevent
the direct discharge of contaminated cleaning wastes
from harbour surfaces, infrastructure can be constructed
that allows wash down wastes to be collected in
a sump and certain contaminants to be removed before
the water runs into the harbour or sewage drain
system. This might involve building bunds around
maintenance areas, installing sumps to allow debris
to settle out or investing in an oily/water separator
for oil to be removed. This, however, may require
a considerable cost to the harbour that needs to
be considered against the potential for environmental
improvement.
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