Shipyard Waste Management during Dry Dock
Coating residues, spent abrasives and wash water must be contained, characterized and managed by composition, yard law and applicable requirements; hazard classification does not follow from the name alone.
Operational Explanation
Docking can generate coating and abrasive residues, wash water, oils, structural materials and other streams. Classification, segregation, transport and destination depend on verified composition and the law of the yard jurisdiction. Residues containing controlled biocides require particular containment, but not every blasting residue automatically has the same classification.
Operational ship waste delivered to a reception facility must be distinguished from waste generated by yard processes. Responsibilities and documents should be assigned in the contract and applicable waste plan.
Regulatory Reference
Environmental law of the yard jurisdiction; AFS Convention and AFS.3/Circ.6 for removal of antifouling coatings, including organotin and cybutryne; MARPOL Annex I/38 and V/8 for reception facilities; Basel Convention only where it applies to transboundary movement of hazardous or other covered waste.
IMO’s 2024 guidance distinguishes paint particles, contaminated abrasives and biocides dissolved in water. Settling removes solids but does not by itself establish that water can be discharged: the supernatant requires treatment and discharge under the applicable permit. Do not treat the guidance’s example parameters as universal limits. IMO AFS.3/Circ.6, 2.3 and 5.3–5.5.
Provide impermeable surfaces and collection of dust, residues and water; keep contaminated water separate from other liquids and collect waste types separately. Record quantities, containers, transfers and destinations for each stream so that environmental closeout can be verified. IMO AFS.3/Circ.6, 3.7, 4.2 and 5.2.
Scope of Application
Work generating residues, dust or process water. The plan should identify origin, properties, contaminants, responsible party, storage, treatment, transport and records for each stream.
Procedure / How to Complete It
- Inventory coatings and removed materials using specifications, SDS and available history.
- Define containment, collection and sampling under law and work method.
- Classify each stream from composition and local criteria.
- Check carrier and facility authorizations and retain manifests.
- Reconcile quantities, destinations and responsibilities at completion.
Practical Example
Before antifouling removal, owner and yard check the system specification and history, define containment and residue characterization, and document transport and destination at authorized facilities.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Classification by name | Wrong code and destination | Use composition, characterization and local criteria |
| No documentary chain | Destination cannot be evidenced | Retain authorizations, weights and manifests |
What the PSCO Checks
Operational Tips
- Put responsibility and close-out documents in the repair specification.
- Do not mix streams before classification.
- Trace residues containing controlled AFS substances.
Preparation checklist
- Materials and coatings identified
- Containment defined
- Streams characterized
- Authorized operators checked
- Quantity and destination reconciled
FAQ
Related Topics
Last substantive revision of this page: 15 September 2026 · page fingerprint 761655b1602e