3.10 CONCLUSION

The risk of translocation of exotic marine species via hull fouling may be as great as that associated with ballast water discharge. The Committee notes that presently the most effective way to prevent hull fouling, and to reduce the frequency of in-water hull cleaning, is through the use of TBT anti-foulant paints, which in themselves pose threats to the environment due to their toxicity.

The Committee supports the recent ban on in-water hull cleaning in Victoria, but emphasises that while the ban should reduce the risk of exotic species introductions, it will not remove the risk of transfer. Regardless of hull cleaning practices, fouling organisms may still transfer from ships' hulls to nearby wharves and pylons; or drop to the sea floor; or release spores, eggs or larvae into the water column. The Committee also notes that fouling material from shipyards must be disposed of appropriately in order to achieve the aims of the ban.

The Committee recognises the risk of exotic organism transfer within and between Victorian ports on the hulls of commercial fishing vessels and recreational craft. The Committee acknowledges and commends the EPA on the current development of guidelines for the disposal of waste from marine and boat harbour operations, including the disposal of hull fouling organisms⁶⁷ The Committee notes, however, that in order for such guidelines to be effective, improved monitoring and enforcement measures will be required.

Given the potential environmental impacts of exotic organism incursions, the Committee considers that biological waste from hull cleaning operations is at least as serious a pollutant as chemical waste. Enforcement activities to ensure appropriate disposal of hull cleaning waste, as required by the EPA Act 1970, should therefore be directed towards both chemical and biological waste.

Finally, the Committee strongly believes that in order to minimise exotic species introductions to Victorian waters via ships' hulls, management strategies must extend beyond regulation of hull cleaning practices. Such strategies could include monitoring of the levels of fouling on incoming vessels, and should be incorporated into Port Ballast Water Management Plans (Chapter 10).