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.

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.

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 spillage’s 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 Agency’s 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.

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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