The Uncomfortable Truth About Marina Pollution

Why the Global Leisure Marine Industry Needs to Take Routine Wash-down Pollution Seriously

For decades, routine boat cleaning within marinas and boatyards has largely been treated as normal day-to-day activity.

Wash the deck. Clean the hull. Rinse the fenders. Flush the bilge. Polish the propeller.

All standard practice.

But an increasingly important question is now emerging across the global marine industry:

What happens when the products routinely marketed for marine cleaning are themselves classified as hazardous to the aquatic environment?

Over recent months, I have been engaging directly with maritime administrations, environmental regulators and marine authorities around the world regarding the interpretation and application of MARPOL Annex V within marina and boatyard environments.

The responses have been remarkably consistent.

Authorities including the UK Maritime & Coastguard Agency (MCA), Japan’s Ministry of Land, Infrastructure, Transport and Tourism (MLIT), Transport Canada, Rijkswaterstaat in the Netherlands, Hong Kong Marine Department, Maritime New Zealand, the Australian Maritime Safety Authority (AMSA) and others have all confirmed variations of the same underlying principle:

Where cleaning products are discharged into the marine environment, they must not be harmful to the marine environment.

MARPOL Annex V Is Clearer Than Many Realise

MARPOL Annex V is often associated primarily with garbage disposal from large commercial ships.

However, the Convention also specifically addresses cleaning agents and additives contained in wash water.

MARPOL Annex V Regulation 4 states:

“Cleaning agents or additives contained in deck and external surfaces wash water may be discharged into the sea, but only those cleaning agents or additives which are not harmful to the marine environment.”

While implementation differs between countries, the wording itself is comparatively direct.

And increasingly, maritime administrations appear to be interpreting this consistently.

The Assumption Gap

Alongside the regulatory review, a technical assessment was undertaken examining manufacturer-issued Safety Data Sheets (SDS) for commonly marketed leisure marine cleaning products.

The results were significant.

The assessment identified that:

• 69.05% of Boat Wash products screened carried aquatic hazard classifications

• 41.67% of Bilge Cleaner products screened carried aquatic hazard classifications

• Across both categories combined, 56.41% of products screened carried aquatic hazard classifications

These classifications included:

• H400: Very toxic to aquatic life

• H410: Very toxic to aquatic life with long lasting effects

• H411: Toxic to aquatic life with long lasting effects

• H412: Harmful to aquatic life with long lasting effects

• H413: May cause long lasting harmful effects to aquatic life

This creates what the paper describes as an “Assumption Gap”.

Consumers purchasing products marketed specifically for marine cleaning reasonably assume those products are suitable for use around the marine environment when used as directed.

Yet many products marketed for routine marina and vessel cleaning may simultaneously carry aquatic hazard classifications declared within their own Safety Data Sheets.

Why This Matters Operationally

The issue is not theoretical.

Within marinas and boatyards, the discharge pathway is often entirely foreseeable.

Boat wash products are routinely rinsed directly into marina basins. Bilge cleaners are discharged overboard through bilge pump systems. Hull cleaning and propeller polishing release contaminants directly into surrounding waters.

At the same time, marina operators globally are facing increasing pressure surrounding:

• water quality

• environmental compliance

• sustainability standards

• discharge controls

• insurance and liability exposure

• ESG expectations

• local environmental permitting

The distinction between HME and Non-HME cleaning products is therefore becoming operationally significant.

The Global Direction of Travel

Different countries are implementing MARPOL Annex V through different legislative frameworks.

Some apply additional environmental legislation. Some require permits. Some prohibit certain in-water maintenance activities entirely.

But despite those differences, the overall direction of travel is becoming increasingly clear.

The international responses received consistently support the principle that:

• harmful cleaning agents should not be discharged into the marine environment;

• marina wash-down activities fall within broader environmental protection frameworks;

• vessel operators and marina operators carry increasing responsibility; and

• greater scrutiny of routine operational pollution is emerging globally.

This Is Not About Attacking the Industry

The leisure marine industry has made significant progress in many areas of sustainability.

This issue is not about blaming boat owners, marinas or the wider industry.

Nor is it about suggesting that products currently sold through chandlery and marine retail channels are unlawful.

The issue is transparency.

The issue is awareness.

And the issue is whether the industry fully understands the environmental and operational implications of products being routinely discharged into the marine environment during normal maintenance activity.

The Need for Non-HME Solutions

As environmental scrutiny increases globally, there is likely to be growing operational pressure toward the use of cleaning products that can clearly demonstrate they are not harmful to the marine environment.

Particularly within:

• marinas

• enclosed harbour systems

• inland waterways

• maintenance pontoons

• boatyards

• wash-down areas

• environmentally sensitive waters

The distinction between HME and Non-HME products is no longer simply a technical classification issue.

It is increasingly becoming:

• a compliance issue;

• an operational risk issue;

• a marina management issue;

• an environmental accountability issue; and

• potentially a future insurance and liability issue.

Read the Full Technical Position Paper

The full technical paper:

“MARPOL Annex V, Marina Wash-down Activities and the Use of Non-Harmful Cleaning Products: An International Regulatory Position Review”

is now publicly available.

Read the paper here:

https://doi.org/10.6084/m9.figshare.32251908

The paper includes:

• direct responses from international maritime administrations and regulators;

• review of MARPOL Annex V wording;

• analysis of aquatic hazard classifications;

• operational discharge pathway assessment;

• marina and boatyard implications; and

• international regulatory context.

The conversation surrounding operational marine pollution within the leisure marine sector is only just beginning.

But it is becoming increasingly difficult to ignore.