Craft Risk Management Standard for Biofouling now in force for vessels heading to New Zealand

As you may be aware, on the 15^th May, the Craft Risk Management Standard for biofouling on all vessels arriving into New Zealand (the CRMS), came into force. The CRMS aims to reduce vessel biofouling by requiring vessels to take out preventative measures and maintain a clean hull before they arrive into NZ.       

The enforcement date marks a transition from the last four years, where vessels were encouraged to comply voluntarily, to one where arriving vessels must carry documentation showing one of the three measures in the standard has been applied.

These measures are:

1. a) Cleaning the hull within 30 days prior to arriving in NZ and providing MPI with documentation of that clean; or
2. b) Conducting continual hull maintenance using best practise, such as IMO biofouling guidelines, and providing MPI with documentation of that management; or
3. c) Conducting hull treatment using an MPI-approved provider within 24 hours of arriving in NZ and providing MPI with documentation of the scheduled treatment.

MPI advises all owners and operators of vessels arriving into New Zealand to familiarise themselves with the Guidance Document accompanying the CRMS, and the Frequently Asked Questions fact sheet, available on the MPI website.

Please be aware that all vessel documentation can be subject to verification upon arrival to New Zealand. As such, vessels must carry all biofouling documentation on board, as these may be requested by MPI officers. If, upon verification the documentation provided by the vessel is insufficient to prove compliance with the CRMS, further action may be taken to manage the biosecurity risk. In order to reduce any arrival delays or on-arrival directions for action by MPI relating to biofouling, please ensure that arriving vessels have valid documentation detailing biofouling management actions taken on-board the vessel.

As MPI has been informally requesting biofouling documentation over the last year, has given industry a four year lead-in to comply, and has taken a proactive communication approach regarding these requirements, MPI anticipates industry to take a proactive approach to being aware of vessel arrival requirements before vessels departs for New Zealand. MPI is also likely to take a less favourable approach to vessel operators and their agents that do not inform themselves of all the necessary requirements before entering New Zealand territory.

Please also be aware that there are no approved cleaning operators in New Zealand. Removal of any macrofouling off international and short-stay vessels is an offence under the Biosecurity Act 1993. As the intent of the CRMS is to manage the risk offshore, MPI advises all operators and owners of vessels to conduct regular inspections and proactive hull cleaning before they arrive into New Zealand territorial waters.

Frequently asked questions

What documentation should be carried on board?

Verifiable evidence that one of the three measures has been undertaken, such as:

• Antifouling certificates, including information on antifouling coating (AFC) application date, type of antifouling applied and if it is applied to niche areas.
• Reports from a recent hull and niche area inspection, with photos/video.
• Reports from the most recent cleaning of the hull and niche areas, with photos/video

o   See guidance on what MPI expects in a hull inspection report

• Records of contingency planning if a vessel falls out of its operational profile.
• Biofouling Management Plan and record book

o   Biofouling management plan template

o   See guidance on what to put in your vessel’s Biofouling Management Plan

The information included within this documentation should be sufficient to show that the vessel has carried out one of the three measures outlined in the CRMS. For example, a vessel may carry a Biofouling Management Plan and Record Book; however, if these documents are audited by MPI and do not show records that biofouling on the vessel has been managed, then the vessel will not meet the requirements.

What will MPI do to verify the accuracy of the information provided to MPI?

Upon arrival, information provided to MPI may be verified. The risk profile of the vessel, and the quality of the documentation carried on board will determine what, if any, further actions are required. Verification will take place through conversations with the operator or person in charge and by conducting verification inspections. This can include checking that the information provided in the Advance Notice of Arrival, and the Master’s Declaration is correct, inspecting records of biofouling management, asking to inspect sea strainers and marine growth prevention systems, and studying the vessel’s voyage history.

Will MPI continue to issue biofouling letters to vessels?

At this stage MPI will no longer issue letters to vessels stating their biofouling risk rating. The purpose of these letters was to inform vessel operators of the upcoming requirements and to help promote best practice hull maintenance. Under the CRMS regime, high risk vessels and a percentage of low and medium risk vessels chosen for verification will be contacted for further information regarding biofouling documentation. If MPI does not contact you within 48 hours of the submission of the vessel’s arrival documentation, no further biofouling information is required at that time.

Please be aware, however, that all vessels are subject to verification upon arrival to New Zealand. As such, vessels should carry all biofouling documentation on board, as these may be requested by MPI inspectors. If, upon verification the documentation provided by the vessel is insufficient to prove compliance with the CRMS, further action may be taken to manage the biosecurity risk.

What if your vessel is found to be non-compliant?

Vessels that are chosen for verification and cannot prove they are compliant with the biofouling standard (via documentation) may be subject to an MPI-directed dive inspection. MPI will communicate with the agent and vessel Master if a dive inspection is required.  If vessels are found non-compliant (there is biofouling on hull that is in breach of the thresholds) they will be directed to either manage the biofouling risk or to leave NZT.

Currently, approved options for managing biofouling or treating biofouling on vessels in NZ are limited to hauling out or dry docking for vessels less than 120 meters at an MPI-approved Transitional Facility (TF).   There are currently no haul out, dry docks or other treatment options for vessels larger than 120 meters.

Can you clean your vessel in-water in New Zealand?

Under the Biosecurity Act 1993, all macrofouling (anything other than a slime layer) on international vessels, including the propeller, may not be removed without a Notice of Direction from MPI. There are currently no approved suppliers of in-water cleaning in New Zealand. Therefore, if a commercial vessel arrives and is non-compliant with the CRMS, MPI may either deny entry, restrict the itinerary of the vessel, or direct the vessel to leave within 24 hours of arrival.

Can you clean a slime layer in New Zealand?

In-water cleaning or treatment methods of a slime layer are acceptable only if the contaminant discharges from the activity comply with the standards or requirements set by the relevant authority. Relevant authorities in NZ include MPI, EPA, Regional Councils, Port Authorities and Marina Operators.