slipways_sub_aug_03.htm  

Tasmanian Fishing Industry Council (TFIC) Submission on the
Draft Environmental Management Guidelines for Operational Best Practice at Slipways and other Boat Repair and Maintenance Facilities May 2003

Introduction
The Tasmanian slipway issues have been highlighted by the State Government Departmental attention being paid to Tasmanian slipways and boat repair facilities over the past few months.

The release of the Draft Environmental Management Guidelines for Operational Best Practice at Slipways and other Boat Repair and Maintenance Facilities May 2003 resulted in consternation and apprehension amongst the various stakeholders due to a lack of explanations or interpretive notes within the document.

TFIC Slipways Stakeholders Meeting
In an effort to address this problem and redress any misconceptions, TFIC organised a Slipways Stakeholder meeting on July 2 at the Tamar Yacht Club.

The message received from the DPIWE representative at this meeting was that the new Draft Guidelines would not be mandatory or enforceable, but that a move towards voluntary compliance to as many of the recommendation objectives as is possible would be expected within an undetermined timeframe. This of course removes the need for an onerous point by point dissection of the Draft Guidelines, but raises other questions.

As a matter of interest, Appendix (a) of this submission is an article written for the Tasmanian fishing industry bi-monthly magazine (Fishing Today). This article is an outcome of both the Stakeholder meeting and some further research of other initiatives that may affect slipways operations.

Appendix (a) forms part of this submission.

Relevant Issues in the Draft Guidelines

2.1, 2.2, 2.3: Occupational Health and Safety (O H & S)
Many of the issues raised in the Draft Guidelines document are basic O H & S protocols that should be an integral part of any responsible workplace. Record-keeping (2.1); Correct materials use and storage (2.2); along with Environment safety and emergency response (2.3) fall into this category.

Many other vessel maintenance activities on slipways relate directly to O H & S and as such will not be addressed here, as they should already be part of healthy and responsible workplace ethics.

Slipways activities that contravene the State Acts as described in the Appendices of the Draft Environmental Management Guidelines for Operational Best Practice at Slipways and other Boat Repair and Maintenance Facilities May 2003 should be dealt with under those laws as appropriate. This submission does not pretend to argue for or against activities of this nature. Obvious and deliberate breaches are environmentally irresponsible and should be dealt with accordingly.

Comment

2.4: Vessel haul-out, repair and maintenance area:
High Tide and slipway inundation

Some of the recommended measures detailed in 2.4 will be difficult to implement at a number of Tasmanian slipways. Most cannot locate the entire vessel work area 'at least one metre above the Australian Height Datum (AHD)' due to various constraints. The main constraint is the spatial restriction that is evident at many slipways.

To gain a one metre elevation above the high tide would in some cases require many metres to be added to rails and cables, or the rails remounted on an unworkably steeper angle. In virtually all cases, neither of these solutions is desirable, practical, economically viable, or even possible.

Bunding the work area
That said, there was moderate consensus after discussion at the Slipway Stakeholder meeting that material removed from vessel hulls could be adequately contained if activities at those slipways (that have tidal inundation) were orchestrated with the low tide and calm conditions.

This concept could include the recommendation for the installation of some drains and bunds within the intertidal zone work area, coupled with a work ethic established to ensure that all waste material is specifically collected and removed before the high tide returns, inundating the area.

The Draft Guidelines should be amended to reflect the fact that there may be more than one established way to achieve the required objective and that innovative alternative methods should be encouraged and explored.

Concreted or sealed hard stand area
The Draft Guidelines recommended measures suggest that… 'Hull cleaning should not take place within 50m of the shoreline where the hardstand is not sealed and bunded and no hull cleaning activities should take place were (sic) the washdown waters and other wastes can be washed into the receiving estuarine/marine waters'.

In many cases, the objective of this recommendation is difficult or impossible to achieve. It was noted during the TFIC visits to slipways that many of the slipways do not have a hardstand work area with a hard impervious surface. To construct a surface as described in the recommendations will be an expensive operation at many of these slipways, while some muddy substrates do not lend themselves to this at other slipways. Considering the low volume of slipway traffic at some of these slipways, it is unlikely to be economically viable to lay down a hard surface.

However, it is likely that there other ways to achieve the objectives. Identification of an impervious plastic sheet type membrane that could be developed/manufactured to catch waste hull debris as effectively as a concreted or sealed surface may be an option. This would obviously preclude any welding or activities that generate sparks, but could be an option worthy of exploring.

Definitions
While the Draft Guidelines address the different slipping facilities and the various methods of removing vessels from the water, it would seem sensible to have clear definitions of the various facilities.

For instance, is a tractor drawn carriage/cradle (mounted on normal trailer axles) that can support a big vessel considered to be a trailer or a slipway? It performs the same function as rails and wheels, but has no rails. It is drawn by a tractor instead of a winch, but can still be used for hull maintenance. It is also infinitely more mobile than a cradle mounted on rails. What about crane/sling systems used to lift vessels up onto the hard surface? Is it necessary to clearly define each method of vessel moving device as well as its capacity for use as a slipway?

TFIC submits that a clear and concise list of slipway definitions should become part of the Draft Guidelines.

Registered Association for Slipway Operators
TFIC submits that all Tasmanian slipway operators and owners should be encouraged to become part of a registered association that gives them a common voice, with this body then becoming proactive in the development, implementation and peer-auditing of their own code of conduct for slipways.

Slipways Register
TFIC submits that a system be developed in the form of a register to ensure that up-to-date data can be kept on all Tasmanian slipways. This would be a good basis to analyse the many variables that should be taken into consideration in the regulation of slipway operations.

Small private rails/wheeled cradles could perhaps be registered and audited via a questionnaire to owners, with guidelines sent to each one clearly stating what boat maintenance activities can and cannot take place on those private facilities.

Individual Slipway Assessment
TFIC submits that a 'one size fits all' approach will not work and that all Tasmanian Slipways that include repair and maintenance work be individually assessed.

This assessment should include:

• slipway activities,
• where a slipway can/cannot achieve Draft Guidelines recommendation objectives,
• adjacent community/industry activities,
• water flows past the facility,
• substrate type,
• siltation tests if and where needed,
• slipway volume/traffic,
• other adjacent sources of pollution or environmental loading,
• environmental cost benefit analysis
• slipway economic cost benefit analysis
• geographic situation/importance in marine safety.
If individual slipway assessment proves that achieving the objective (stated in a recommendation in the Draft Guidelines) will make a measurable difference and improvement to the environment around a slipway, then (in consultation and cooperation with the owner/operator) assistance should be given to sourcing suitable funding to achieve this.

In the interim, specific slipway activities may have to be scaled back at slipways where activities impinge on the quality of the marine environment, other stakeholders and community activities.

If there is no measurable deleterious effect from slipway activities on the adjacent marine environment or to other stakeholders, then TFIC has to seriously question the advantages or outcomes from expecting a marginal operator to invest additional funds (seemingly unnecessarily) unless there is additional funding assistance available.

Categorisation [As also detailed in Appendix (a)]
Once this assessment is completed, another measure that may be appropriate could involve the categorisation of slipways. A system such as this could be phased in over an appropriate timeframe with all commercial slipways working to an agreed code of conduct. This code should include a determination for all participants to achieve as many of the objectives as possible as are recommended in the Draft Guidelines.

Bear in mind that what is listed below is simply a series of suggestions to get the ball rolling. They may not be workable in this form.

Category A
For instance, those slipways that do full maintenance on larger vessels from a certain agreed tonnage could be designated Category A. They would have to demonstrate a willingness and capacity to conform to an agreed number of the recommendations within the Draft Guidelines and would be able to carry out all necessary vessel maintenance activities as required. They would be situated away from sensitive areas and areas used for recreation, as well as other industries that could be adversely affected by slipway activities.

Category B
Perhaps Category B slipways may only handle vessels to a maximum agreed tonnage (less than Category A) with all slipway activities permitted if the equipment and infrastructure is in place to conform to an agreed number of the recommendations in the Draft Guidelines.

Category C
Those who would normally fit into Category B but are unable to conform to the majority of the recommendations could perhaps have limitations placed on some of their activities, (such as no sand/grit blasting) yet continue their work as Category C slipways. Many may already have limitations placed on them. Slipway activities unavoidably impacting on adjacent industry, primary production or community activities may fall into this category.

Category D
This category may include those that cannot seal or concrete their hard stand area or are unable to control waste material from the hulls, yet can perform other maintenance work. Hull maintenance may be restricted to washing down and repainting, but no paint removal permitted.

Category E
Category E may be those yacht clubs that have haul-out and hard stand areas. They would have to be able to demonstrate that they have agreed limitations placed on activities and that they are conforming to an agreed number of Draft Guideline recommendations. Being part of a code of conduct agreement may be helpful.

Category F
Category F may be privately owned slipways as are common on the West Coast for commercial fishing vessels. Activities taking place on these slipways would be limited to normal routine maintenance, excluding the removal of anti-foulants. Normal hull washing may or may not be appropriate.

Category G
Category G may be all other privately owned slipways that are used simply for putting a boat into the water or retrieving it. Limited or clearly prescribed maintenance would possibly be permitted.

Banned coatings; e.g., tri-butyl-tin (TBT)
While there is a world-wide initiative to ban TBT hull coatings, it is likely that the problem of TBT contamination of the marine environment will persist for a number of years as existing spent hull coatings are removed from hulls.

TFIC submits that a way to ensure a responsible handling of this problem would be to certify all boats that have a TBT free hull and have this certification as part of the vessel survey. Those that are unable to demonstrate a TBT-free hull, or those where a test detects TBT should attend (for that one particular maintenance event) a certified slipway capable of appropriately removing and disposing of the waste hull material, in order to gain the TBT free certification.

Disposal of waste material
Both the Draft Guidelines and the DPIWE website are not particularly clear as to the best way for Tasmanian Slipways to dispose of controlled wastes removed from boat hulls. Numerous comments within the Draft Guidelines indicate that some disposal of some substances through the sewage system may be appropriate with Council approval.

TFIC questions this process. If substances containing biocides are introduced to the sewage system (that relies on microbiological activity to treat the effluent) how can this process be advantageous or responsible? What method of assessment or monitoring can be put in place to ascertain that the substance will not adversely affect the sewage treatment? If the sewage outfall exhausts into the marine environment, surely there is an elevated risk of contamination?

If substances containing heavy metals such as copper and tin are introduced into the sewage system, they will exit the system into the marine environment unchanged and constitute the same environmental pollution loading, but in a different location. How can this be responsible stewardship of the environment?

There clearly needs to be a system established here in Tasmania for the disposal of controlled waste. To rely on Victorian companies to remove it every three months or so at significant cost is inappropriate.

Project Officer
TFIC submits that it would seem appropriate for the Department to appoint a dedicated Project Officer to work with slipway operators in an effort to encourage modification of slipways and slipway activity. Some form of partnership agreement between the Department and stakeholders may be of value, whereby the officer works constructively with the slipway operators rather than in an enforcement capacity.

This agreement will detail the Draft Guidelines recommendations that are achievable, and establish a realistic timeframe to make the modifications to the slipway itself, to the work activity that takes place on the slipway, or to the work ethic that the slipway embraces.

This officer's duties could include the assessment/categorisation of slipways, as well as working with individual operators investigating ways to achieve compliance with recommendations within the Draft Guidelines within an agreed timeframe.

When considering each slipway individually, some form of standard needs to be established regarding some of the basic modifications that may need to be done to various slipways. Examples of these standards may include the dimensions and positioning of bund walls and spoon drains, settlement tanks, pumps, waste containment and disposal etc.

The Project Officer would also be involved in the identification of funding sources and assist in applying for funds should that be necessary for slipway improvements.

It is very important that efforts be made to establish a realistic timeframe for any change within the industry to ensure that there is minimal disruption to survey and maintenance work on commercial vessels, while providing minimal increases in costs to the industry.

Contaminated areas
While controls are being established for responsible slipway activities, the question must be asked about existing contaminated sites that have had slipway activities taking place on them for decades with little or no care for the environment. These sites exist, with measurable amounts of pollutants being released and washed into the marine environment at each rain or storm event. These pollutants can and do adversely affect marine farmers.

TFIC submits that while it may be cost effective to concentrate on existing activities, contaminated ground should be identified and rehabilitated. This should have the effect of reducing conflict between existing slipway operations and other adjacent industries.

Summary
The clear objective should be to assess the current situation at individual slipways and to reduce the level of contaminants entering the marine environment by carefully planning viable actions that may be appropriate. This will need realistic timeframes along with funding assistance to retain individual slips and to keep slipping costs at minimum levels.

TFIC strongly advocates the following measures to be taken with commercial slipways:

• Clear definitions of each type of slipway/haulout operation or method should be established and included within the Draft Guidelines.
• All slipway operators should be encouraged to join into some form of association that gives them a common voice and lobbying power.
• A slipways register should be established, detailing all slipways around Tasmania.
• All slipways should be individually assessed and categorised (small private launching rails evaluated through questionnaire if possible).
• Commercial vessels should be able to have certification that the hull is free of TBT as a part of the vessel survey. Where there is any doubt, the vessel should have the paint removed and replaced at a slipway capable of carrying out this work in an appropriate manner, with certification issued.
• A system for the appropriate disposal of controlled wastes such as hull coatings should be established within Tasmania to provide a cost effective and efficient means of waste disposal.
• A dedicated Project Officer should be appointed specifically to work constructively with the slipway industry.
• A basic standard should be devised and developed that consider the basic modifications needed for compliance with Draft Guidelines recommendations, addressing such things as bund wall/spoon drain position and dimensions.
• Each slipway should be assessed to establish which of the Draft Guidelines recommendations are possible to achieve, also considering innovative measures that will achieve the same outcomes. These may include a modification of work ethics and/or a reduction of some slipway activities.
• A partnership agreement should be established between the department and individual slipway operators, detailing which of the Draft Guidelines recommendations may be achievable, establishing a timeframe that is realistic and appropriate for any agreed modifications while also assisting with the sourcing/application process of external funding.
• Areas contaminated with chemicals from previous slipway operations should be identified and rehabilitated within a realistic timeframe.

Appendix (a) Fishing Today August/Sept. 2003 Article