Hazardous Materials
and
Liquid Waste
Source Control/Reduction
Summary
Enforce the prohibition on the use of TBT-based paint.
The use of TBT-based paints in the marine environment has been found to be harmful because of its toxicity. This finding led to the passing of a federal statute that prohibits the use of TBT in the marine environment. The state has created a law, based on the federal legislation, that phases out the use of TBT-based paint. Rhode Island General Law 23-25.3 prohibits the use of TBT-based paint in commercial boatyards except when its measured release rate does not exceed four (4.0) micrograms per square centimeter per day and it is applied only to vessels in excess of 65 feet in length or having aluminum hulls. However, federal law-which preempts the state law because it is more stringent-prohibits use of all TBT products on vessels that are less then 82 feet (25 meters), unless the vessels are made of aluminum (Federal Register, 1988). Both laws allow TBT-based paint to be applied to outboards or lower drive unit of vessels. Adhere to the stricter federal law by not using TBT-based paints in your facility, unless you meet the specific criteria. Ensure that tenants and subcontractors are operating in accordance with these standards.
Detergents and cleaning compounds used for washing boats should be phosphate-free and biodegradable. Discourage the use of detergents containing ammonia, sodium hypochlorite, chlorinated solvents, petroleum distillates, or lye.
Use products throughout the facility that are environmentally compatible. Generally, these include products that are not toxic in the marine environment and are often biodegradable. For vessel cleaning use detergents that are phosphate-free and do not contain such toxins as ammonia and sodium hypochlorite. If the facility has a store where detergents and solvents are sold, consider stocking products that are also environmentally compatible. Encourage your customers to use products that will not degrade the environment.
There is a growing number of services that grade a product's environmental compatibility. Discover if one of these services is available to the marina and consider using the information it can provide.
Use antifreeze that is less toxic to the environment.
Currently there are two types of antifreeze on the market. Ethylene glycol is standard or traditional antifreeze and is usually discernible by its green or blue coloring. This antifreeze is toxic in the environment and should be collected and recycled. If recycling is not an option, the ethylene glycol should be collected and disposed of according to appropriate state regulations. Propylene glycol antifreeze is less toxic in the environment and is often identified by its pinkish color (Gannon, 1990). Consider using propylene glycol instead of standard antifreeze, especially if there are no means for recycling anti-freeze. Encourage your tenants to use propylene glycol because of its greater compatibility with the environment.
Amounts of hazardous material stored and used should be kept to a minimum.
Review the facility's hazardous material inventory and identify any materials that can be stored in smaller amounts. The benefits of maintaining only minimal amounts include: secondary spill revetments can be smaller; the amount of potential contamination is limited if there is a spill; and, the conservation of the product may be encouraged. Also, in some instances, regulatory requirements are based on the volume of material being stored. If these amounts do not exceed regulated levels, the facility may be subject to less stringent storage and disposal rules.
Keep amounts to a minimum when toxic material is used during maintenance activities. Use only enough detergent, solvent, or other compounds to get the job done. Encourage your tenants to use only a minimum amount of cleaning material when they are washing their boats. Minimizing the amount of material being applied also reduces the amount of material that eventually enters surface waters.