APPROVAL PROCEDURE

FOR IN-WATER CLEANING COMPANIES

Approval procedure for in-water cleaning companies

Terms of use

The main users of this procedure are cleaning companies, approval bodies, accredited laboratories, and independent
testing organisations. The information given in the Approval procedure is intended to be used at the user’s own risk. No
warranties or representations are given, nor is any duty of care or responsibility accepted by the authors, their membership
or employees of any person, firm, corporation or organisation (who or which has been in any way concerned with the
furnishing of information or data, or the compilation or any translation, publishing, or supply of the procedure) for the
accuracy of any information or advice given in the procedure; or any omission from the procedure or for any consequence
whatsoever resulting directly or indirectly from compliance with, adoption of or reliance on guidance contained in the
procedure, even if caused by a failure to exercise reasonable care on the part of any of the aforementioned parties.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES  1

Introduction

The objective of this procedure is to set minimum requirements for approval of cleaning companies
for various types of operations. The Approval procedure for in-water cleaning companies (Approval
procedure) is one of two separate documents that outline performance-based requirements for in-
water cleaning of a ship’s hull, propeller and niche areas with the capture of the materials that are
removed during the process:
„ Approval procedure for in-water cleaning companies (Approval procedure)
„ Industry standard on in-water cleaning with capture (Industry standard).

The Approval procedure ensures:

1. that the cleaning system and process are tested, audited and approved in accordance with the
Approval procedure by an independent approval body
2. that after approval, the quality management systems of the cleaning companies are subject to
periodic internal audits, and external audits are to be carried out by the Approval Body at regular
intervals
3. that ships, AFS manufacturers and cleaning companies will use the requirements in the Industry
standard on in-water cleaning with capture for planning, conducting, and reporting on the
cleaning itself
4. that testing results can be utilised to apply for local permissions from port and other relevant
authorities to operate within their jurisdictions.

The Approval procedure has been written by an industry working group consisting of AFS
manufacturers, in-water cleaners, shipowners, ports, international organisations and authorities.
The following were represented in the work: Akzo Nobel, BIMCO, C-Leanship, CMA Ships, DG Diving
Group, Fleet Cleaner, Hapag-Lloyd AG, Hempel, HullWiper, International Association of Classification
Societies, International Chamber of Shipping, Minerva Marine, Portland Port (UK), Port of Rotterdam
and PPG Coatings.

A reference group has been invited twice to comment on the Approval procedure and it has been
updated accordingly. Members of the reference group are: Chevron Shipping, CleanSubSea Ltd, DHI,
NACE International and, PML Applications Ltd.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Introduction 2

Contents
Introduction............................................................................................................................................................. 2
1 Bibliography................................................................................................................................................... 4
2 Definitions...................................................................................................................................................... 5
3 In-water Cleaning Systems.............................................................................................................................. 8
4 Approval requirements ................................................................................................................................ 10
5 Granting of approval..................................................................................................................................... 14
ANNEX A Test protocol for in-water cleaning systems with capture.............................................................................. 16
1 Introduction........................................................................................................................................................... 16
2 Performance criteria.............................................................................................................................................. 16
3 Independent verification testing........................................................................................................................... 16
4 Experimental design ............................................................................................................................................. 17
5 Documentation of test conditions and operations................................................................................................ 17
6 Criterion A – removal of macrofouling ................................................................................................................. 18
7 Criterion B – effectiveness of the separation and/or treatment unit of removing captured materials................. 20
8 Criteria C and D – Impact on local water quality .................................................................................................. 22
9 Assessment of paint damage................................................................................................................................ 25
10 Data management and quality.............................................................................................................................. 26
11 Reporting............................................................................................................................................................... 26
ANNEX B Sample format of approval certificate........................................................................................................... 28
ANNEX C Documents applicable for different types of audit........................................................................................ 30

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Contents 3

 1 Bibliography

Alliance for Coastal Technologies [ACT] and Maritime Environmental Resource Center [MERC] (2019).
Evaluation of Subsea Global Solutions In-Water Cleaning and Capture Technology for Ships. Available
at: http://www.maritime-enviro.org/Downloads/Reports/MERC_Inwater/ ACT_MERC_SGS_IWCC_
Evaluation_Report.pdf.

A. Whitman Miller, Melanie Frazier, George E. Smith, Elgin S. Perry, Gregory M. Ruiz, and Mario N.
Tamburri (2011). Enumerating Sparse Organisms in Ships’ Ballast Water: Why Counting to 10 Is Not So
Easy.

Craig D.H. Sherman, Geordie Jennings and Adam D. Miller (2020). Assessment of reproductive
propagule size for biofouling risk groups. Available online at: https://www.agriculture.gov.au.

International Maritime Organization [IMO] (1995). The IMO Code of Safety for Diving Systems.
London: International Maritime Organization.

International Maritime Organization [IMO] (2011). Guidelines for the Control and Management of
Ships’ Biofouling to Minimize the Transfer of Invasive Aquatic Species. London: International Maritime
Organization.

Morrisey, D., Inglis, G., Tait, L., Woods, C., Lewis, J., and Georgiades, E. (2015). Procedures for
Evaluating in-Water Systems to Remove or Treat Vessel Biofouling. Available online at: http://www.
mpi.govt.nz/document-vault/10811.

Naval Sea Systems Command [NAVSEA] (2006). Naval Ships’ Technical Manual Chapter 081.
Waterborne Underwater Hull Cleaning of Navy Ships, Revision 5. Washington, DC: Naval Sea Systems
Command.

Scianni, C., and Georgiades, E. (2019). Vessel in-water cleaning or treatment: Identification of
environmental risks and science needs for evidence-based decision making. Front. Mar. Sci. 6 (467).
doi: 10.3389/fmars.2019.00467.

Sylvester, F. and MacIsaac, H.J. (2010). Is vessel hull fouling an invasion threat to the Great Lakes?
Diversity and Distributions 16: 132-143.

Tamburri MN, Davidson IC, First MR, Scianni C, Newcomer K, Inglis GJ, Georgiades ET, Barnes JM and
Ruiz GM (2020). In-Water Cleaning and Capture to Remove Ship Biofouling: An Initial Evaluation of
Efficacy and Environmental Safety. Front. Mar. Sci. 7:437. doi: 10.3389/fmars.2020.00437.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Bibliography 4

 2 Definitions

Accredited laboratory A laboratory verified to an appropriate level of expertise, and whose

quality management system can perform specific test methods
accredited to internationally accepted standards or standards
recognized by the government of the country, in which the laboratory is
located.
Anti-fouling paint coating The combination of all component coatings, surface treatments
system (AFC) (including primer, sealer, anti-corrosive and anti-fouling coatings)
or other surface treatments, used on a ship to control or prevent
attachment of unwanted aquatic organisms.
Anti-fouling system (AFS) A coating, paint, surface treatment, surface, or device that is used on a
ship to control or prevent attachment of unwanted organisms.
Approval Body An organisation which audits the cleaning company (including its
subsidiaries and sub-contractors) in accordance with the requirements
of the Industry standard on in-water cleaning with capture and the
Approval procedure for in-water cleaning companies and issues a
certificate of approval.
Background sample A sample of water from the place or in the vicinity where cleaning takes
place but that is not impacted in any way by the cleaning activity. The
sample can be collected before, during and/or after a designated test
cleaning event.
Biocide A chemical substance incorporated into anti-fouling coatings to prevent
settlement or survival of aquatic organisms.
Biofouling The accumulation of aquatic organisms such as micro-organisms, algae,
and animals on surfaces and structures immersed in or exposed to the
aquatic environment. Biofouling types can include soft biofouling (soft
microfouling and soft macrofouling) and hard calcareous biofouling (see
below).
Cables and hoses These connect the cleaning unit to the unit ashore or on a barge. The
hoses may carry water or other means of transporting the captured
material from the cleaning unit to the separation and/or treatment
unit. Cables are used to power the cleaning unit.
Cleaning company A person or company who provides services in reference to underwater
hull cleaning which may also include services such as in-water
inspection.
Cleaning inspection An inspection of the area to be cleaned prior to the actual cleaning
activity or just the cleaning.
Cleaning unit The cleaning device interacts with the ship’s hull and other areas to
remove and capture the material attached to the surface. This unit may
be operated by a diver or by a remotely operated vehicle (ROV) pilot.
Continuous, time- A representative sample taken continuously during the designated
integrated water sample cleaning period. This approach integrates concentrations of water
quality parameters over the testing period into one single sample.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Definitions 5

Control unit This unit houses the controls such as remote control of ROVs,
communication devices with divers, camera monitors etc.
Diver A person who is qualified to dive underwater safely using self-contained
breathing apparatus or other similar systems. He/she is trained in
one of the diving standards recognized by relevant authorities and
has working knowledge on the use of tools normally used in in-water
cleaning/visual inspection as well as emergency escape training.
Hard biofouling Often referred to as hard calcareous biofouling, which consists of
organisms visible to the human eye. It can include barnacles, mussels
tube worms and bryozoans etc.
Independent Testing A testing facility with appropriate quality assurance and quality
Organisation control (QA/QC) in place, that is not owned or affiliated with the
cleaning company, manufacturer or vendor of any equipment, by the
manufacturer or supplier of the major components of that equipment
for.
Invasive aquatic species A species which may pose threats to human, animal and plant life,
economic and cultural activities and the aquatic environment.
In-water cleaning The physical removal of biofouling from a ship while in the water.
Manufacturer A company who manufactures the equipment utilized in the in-water
cleaning process (eg hull cleaning equipment, water treatment systems
etc).
Macrofouling Large, distinct multicellular organisms visible to the human eye such as
barnacles, tube worms, or fronds of algae.
Marine growth An AFS used for the prevention of biofouling accumulation in internal
prevention system seawater cooling systems and sea chests and can include the use of
(MGPS) anodes, injection systems, electrolysis, ultrasound or other methods.
Materials The solid substances captured during the cleaning of the ship. This
may include biofouling (macro and micro) growth, paint flakes and
the matters contained within, such as biocides, heavy metals, silicon
substances etc.
Niche areas Areas on a ship that may be more susceptible to biofouling due to
different hydrodynamic forces, coating system wear or damage, or
being inadequately, painted, eg, sea chests, bow thrusters, propellers
and propeller shafts, rope guards, inlet gratings, dry-dock support
strips, rudder pintle areas etc.
Out of water cleaning The cleaning of the hull areas when the ship is out of water, for
example, in a dry-dock.
Proactive cleaning Cleaning carried out at pre-planned intervals regardless of ship’s
performance.
Remotely operated A vehicle that may be used as part of a cleaning unit, which is
vehicle (ROV) and navigated remotely from the surface to inspect and/or clean
submerged hull and niche areas.
Responsive cleaning Cleaning initiated by a marked reduction in the ship's performance or
when an inspection shows that cleaning is needed.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Definitions 6

Sea water effluent The water that has been filtered, and/or treated to specifications
mentioned in the Industry standard and is ready to be discharged back
into the environment.
Sea water influent The water that is captured into the cleaning system during the cleaning
process. This water may still contain biofouling, paint flakes and other
associated solids.
Separation performance The effectiveness of separating solid materials from water during in
water cleaning. The separation unit used in connection with in-water
cleaning shall be able to remove particles of solid materials that are
larger than a defined limit.
Separation unit Consists of the equipment that uses physical processes to remove solid
material (macrofouling, coating chips, etc) from water, including but
not limited to settling tanks, filtration, and centrifugation. Separation
and treatment stages may be combined into one unit.
Ship A watercraft of any type whatsoever operating in the aquatic
environment and includes hydrofoil boats, air-cushion vehicles,
submersibles, floating craft, fixed or floating platforms (excluding
licensed aquaculture assets), floating storage units (FSUs) and floating
production storage and off-loading units (FPSOs).
Single test cleaning event A test cleaning event starts with the onsite safety preparation of the
in-water cleaning and lasts until the cleaning and associated equipment
have been returned to its original state.
SOP (Standard Operating A set of step-by-step instructions compiled by a cleaning company to
Procedure) help workers carry out routine operations.
Storage unit Captured material is pumped directly into tanks, a barge, etc. The
captured material and seawater in storage can be directly disposed of
appropriately or subsequently processed through separation and/or
treatment units.
Subcontractor A person or company providing services to the cleaning company.
Subsidiary A company partly or wholly owned by the cleaning company.
Treatment unit Treatment consists of a physical, chemical or biological addition(s) to
alter or remove solid and/or dissolved material. They can include but
are not limited to flocculation, metals sorbent media, UV and biocides.
Treatment and separation stages may be combined into one unit.
Total suspended solids Solids in water that can be trapped by a filter.
(TSS)

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Definitions 7

 3 In-water Cleaning Systems

This Approval procedure is specific to in-water cleaning service providers that remove and capture
macrofouling organisms (ie, visible to the human eye, as defined in IMO Guidelines 2011) which have
colonized the immersed surfaces of ships. Cleaning systems comprise a series of units, which manage
the cleaning process (figure 1).

CLEANING
UNIT

STORAGE CONTROL
UNIT UNIT
CLEANING
SYSTEM

TREATMENT SEPARATION
UNIT UNIT

Figure 1: Schematic diagram of a cleaning system outlining the various component parts that are common to such systems.

The cleaning system is made up of one or more of the modules shown on Figure 1 and the order of
operation in which these components are placed will vary between systems. The cleaning system can
be self-contained on a waterborne platform or contained from a jetty or pier.

The cleaning unit may be either diver operated or remotely operated using a remotely operated
vehicle (ROV). The cleaning unit is used to clean the hull, propeller and/or niche areas. The cleaning
unit removes and captures materials and is attached to the separation and/or treatment unit by
hoses.

Some cleaning systems pump the captured material and seawater into a storage unit (eg, a barge
or mono-hull tanker). The captured material and seawater in the storage unit will subsequently be
pumped to the separation and/or treatment unit.

The hoses provide means of transporting the captured material and seawater from the cleaning unit
to the separation and treatment unit or a storage unit. Cables are used for communication purposes
and to power and control the ROV or other cleaning technology.

The separation unit houses the equipment that removes the captured material from the seawater
influent.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES In-water Cleaning Systems 8

The treatment unit can be used as an integrated part of the separation unit or as an additional unit to
further treat the influent water after the separation unit. Treatment may include use of heat, biocides
or sorbent media, as examples. The separation and treatments units can be used to ensure the
seawater effluent comply with the performance criteria of this standard and local regulations.

Seawater effluent is generally returned to the environment although there are examples where the
seawater can or must be discharged elsewhere eg to comply with local regulations.

The following parameters can affect the performance of in-water cleaning systems and have been
considered in the development of the testing protocol (Annex A). While it is not feasible to include
all parameters listed as variables in performance testing, they should be considered in the approval
process.

Key ship parameters

Ship type (design, complexities/niche areas and operational profile: where the ship has operated during which seasons
and what type of activities have been undertaken)
Ship availability/access for cleaning and/or testing (eg, time at berth or anchorage)
Ship AFC(s) type, age and history
Ship MGPS
Ship biofouling coverage and types
History of cleaning operations of the ship
Biofouling distribution on hull and niche areas
Key environmental parameters
Water depth, under keel clearance
Water visibility
Currents, wind and waves
Water quality (eg, salinity, temperature, total suspended solids (TSS), pH, metals, and dissolved and particulate organics)
Ambient levels of biocides (eg, background levels of copper)
Key in-water cleaning with capture system parameters
In-water cleaning system design1 and operations, including:
„ diver or ROV driven
„ operator/diver skill and experience
„ mode of attachment to and movement over ship
„ cleaning brushes, blades, or water jets and type, amount, configuration, etc.
„ maximum curvature radius that can still be cleaned while capturing the removed biofouling
„ planned and actual rate of movement of cleaning unit over the test area
„ number and overlap of passes (accuracy of surface coverage)
„ capture methods (eg, cleaning unit shroud and suction)
„ flow rate of sea water influent including materials
„ materials and sea water influent and effluent transport and processing (eg, time for particle settlement, level of
handling, treatment, separation, type media removal of metals)
„ various pre-set modes of operations and operational adjustments during cleaning
„ contingency plans and response to system failures.
Regulatory status at the location of the test and/or operational cleaning
National, regional and local jurisdictions
for eg but not limited to the following water quality regulations
Biosecurity regulations
Table 1: Parameters that affect the testing of cleaning systems (based on Tamburri et al, 2020).

1 Includes information relevant to cleaning methodology but excludes propriety and commercially confidential information.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES In-water Cleaning Systems 9

 4 Approval requirements

Cleaning companies approved in accordance with this procedure should be considered competent
at meeting the minimum requirements to conduct safe and effective operations worldwide, for the
specific applications and operations tested.

An approved cleaning company may have to apply for a local permission(s) to operate in a country,
region or port. Compliance with performance criteria may suffice in some locations but further
criteria may be required by local regulations or requirements.

Approvals may be issued by the Approval Body based on test results, relevant documentation and the
outcome of third party audits verifying the cleaning company meets the requirements of the Industry
standard and the Approval procedure.

The approval shall clearly state the scope of services including type of equipment whilst specifying
any limitations or restrictions imposed.

Verification testing
The capability of the cleaning system shall be tested by an independent Testing Organisation.
While being tested, the system shall be operated in the way it is intended to be used during normal
operation.

In-water cleaning companies will be tested for different performance criteria relevant to their
declaration of the cleaning system’s operational capabilities and performance ie (A) the capability of
the system to remove macrofouling; (B) the effectiveness of the separation and/or treatment unit
system at removing material, and (C and D) control of the emission to the local environment from the
cleaning unit and from the separation and/or treatment unit.

The verification testing will take place on actual ship surfaces (submerged hull, propeller and/or niche
areas) and AFC (non-biocidal and/or biocidal) depending on cleaning company’s declarations. The
cleaning company’s declaration should, as a minimum, include the following information:
„ biofouling type and extent
„ AFC type(s)
„ division of categories of ship areas to be cleaned:
• hull and niche areas that do not need special cleaning equipment
• niche areas that require special cleaning equipment; and/or
• propellers
„ visibility and operational limits.

The Approval Body should develop test plans that are based on which stratum (vertical and flat-
bottom hull, curved areas, niche areas, or propeller) the cleaning company declared that the
individual cleaning devices can clean and any stated limitations these devices may have for example in
terms of the curvature of surfaces, AFC, distances to bilge keels etc. Depending on the intended use of
the system, the test plans may include:
„ areas used for testing on the flat sides of the hull
„ curved areas used for testing, for example the turn of bilge, and angles where the orientation of
the surface changes abruptly, such as the chine, keel and skegs

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Approval requirements 10

 „ niche areas used for testing, eg, propeller shafts, rudders, anodes and gratings
„ propellers.

The performance criteria, and protocols to measure them, are described in detail in Annex A.

Certification audit
The cleaning company, subsidiaries and subcontractors if any, shall be subject to an audit of relevant
documentation, training and experience of personnel, and quality management system, (see below).
Upon successful completion of this certification audit and testing process, a certificate of Approval
shall be issued (See Annex B. Sample format of certificate of Approval). The cleaning company will be
subject to periodical renewal audits (see below) after approval.

Testing should involve development of detailed, individualized test plans (including Standard
Operating Procedures) for each in-water cleaning system tested, in consultation with the cleaning
company and Approval Body. Testing shall be conducted by an independent Testing Organisation.

Documentation
The following documentation shall be submitted for verification:
1. outline of cleaning company eg organisation and management structure, including subsidiaries to
be included in the approval/certification process
2. The cleaning company shall give information of agreements and arrangements if any parts of the
services provided are subcontracted. This should include quality management by the cleaning
company when following-up such subcontracts to ensure the relevant requirements of this
procedure are met.
3. declaration of the services requested to be under the scope of approval
4. experience of prior in-water cleanings carried out by the cleaning company (ie companies
requiring personnel that have experience in cleaning specific ship categories, hull forms, AFC
coating types, propellers and niche areas)
5. description of equipment(s) used in cleaning process, including but not limited to cleaning units,
hoses, cables, surface units, separation and treatment units, communication devices, recording
devices such as cameras. Manufacturer’s technical documentary evidence where applicable, to
the operations being carried out eg filter sizes
6. documentation of part-testing or pilot-testing on a smaller scale showing, eg performed under
laboratory conditions, the results of that testing eg:
a. Site Acceptance Testing (SAT) of system (test propulsion, test control systems including ROV
and diver control systems, Factory Acceptance Testing (FAT), test camera system, test cleaning
unit, test collection system (cables, hoses, and pumps), test separation system, etc
b. capture test of cleaning unit (test vacuum, test enclosure, test pumps, stationary test, moving
test etc)
c. efficacy test of separation unit (test flowrates, test filters, etc)
d. impact test of cleaning unit and/or cleaning methodology (test for level of contact with ship
coated surfaces (note-brushes have to have contact), test standoff distance if applicable
(note – as above), test brushes/nozzles cleaning focal point, details of material type of brush
bristles & nozzles, test continuity of speed of cleaning, etc)
e. quality of photographic camera, video camera and CCTV system
f. test quality of video and photo recording and CCTV or photographic reporting
g. small scale test on paint systems, which can be done in partnership with paint manufacturers
(test different paint types, test different setups depending on system, test scrub pressure
(brushes), test water pressure (ROV), test stationary, test moving, test rotation, test speed, etc)
7. list of operators/technicians/inspectors/divers

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Approval requirements 11

 8. training records for operators/technicians/inspectors/divers
9. an SOP manual covering at least the following:
a. Specific operational procedure to be followed by the personnel involved when undertaking
cleaning activity. This shall include specific procedures followed in the use of the cleaning
equipment, guidance of diver along the hull to provide complete coverage of cleaning as
required, camera and/or video operation.
b. If the above includes a ROV, procedures to follow for the operation of ROV, methods and
equipment to ensure the ROV operator can determine the ROV’s location and orientation in
relation to the ship.
c. maintenance and calibration of equipment involved in accordance with the instructions of the
manufacturer
d. training requirements of the operators/technicians/inspectors/divers – these should as a
minimum cover the points mentioned in the “training of personnel” below
e. supervision and verification process to ensure compliance with operational procedures
f. recording and reporting of information such as collection of photographs of AFS condition,
biofouling status, use of biofouling coverage scale, development of cleaning and service
reports
g. periodic review of near misses, work processes, procedures, complaints, corrective and
preventive actions
h. process of issuance, maintenance and control of documents
i. contingency plans based on risk analysis for breakdowns, accidental discharges, and any other
untoward incident that the cleaning company anticipates during the cleaning process.

A set of procedures covering the following environmental aspects shall be submitted for verification
against the performance criteria:
1. operational procedure of the cleaning system’s capability in capturing the materials from hull
and/or niche areas, as applicable
2. operational procedure for separation, treatment, and maintenance of the units in the systems
3. operational procedures for the handling of the captured material including disposal or alternative
arrangements
4. record of each cleaning operation2 for eg number of hours cleaning, amount of material captured,
record of separation/treatment and discharge of seawater effluent, record of separation/
treatment and disposal of the captured material
5. operational procedure for self-checks and testing/monitoring of the system on an ongoing basis
and associated reporting, including how the risk of incidents is thus reduced.

Records of near misses, incidents and corrective actions thereof:

1. damages to AFS
2. deficiencies in cleaning
3. accidental discharges
4. personnel injuries
5. other incidents, such as damage to ship, jetty structures, equipment damage.

The records should include both documents as well as visual evidence (videos, photographs, etc).

2 In instances where a cleaning company has extensive experience detailed and specific information should be given for the last five cleanings. For
cleanings before a summary will suffice indicating the number of cleans, types of ships, AFCs cleaned, types of cleaned biofouling, procedures for
effluent and waste handling etc.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Approval requirements 12

Training of Personnel
The cleaning company shall maintain records of personnel training and present and previous work
experience for all cleaning operations performed including but not limited to the following:
a. qualification of divers
b. qualification of ROV operators
c. qualification of diving and/or ROV supervisors
d. training requirements of technicians involved in operation and maintenance of surface units,
separation and treatment units
e. operation of under-water communication system for manned operations
f. any special equipment necessary to carry out the work safely eg cranes, barge operations, storage
units, ship to ship transfer
g. understanding of the specific cleaning process and technology applied, as applicable
h. knowledge of and ability to assess biofouling encountered during normal course of operation
i. awareness of AFS types and working knowledge of associated cleaning procedures
j. knowledge of underwater video monitoring systems using still cameras, video cameras, TV-
monitors on deck.

The above records shall be updated periodically and be made available to the Approval Body upon
request.

Experience of Personnel
The cleaning company shall demonstrate that the experience requirements for its personnel are in
line with the cleaning company policy and specific to the procedure/methods/technology adopted
for cleaning operations. The cleaning company will demonstrate competence and experience in
diving and/or ROV operations in accordance with the documentary requirements of this procedure.
Furthermore, the following experience is required for specific personnel:
„ Supervisor – Diving and ROV supervisors shall be qualified according to cleaning company’s
general requirements and shall have a minimum of two years’ experience as a diver carrying out
cleaning or ROV operations as appropriate.
„ Divers – An assistant diver shall participate in a number of cleaning procedures that cover the
specific services of the company in accordance with the cleaning companies’ internal procedures.
ROV operators – ROV operators shall have participated in a minimum number of cleaning
operations to be approved in accordance with the cleaning companies’ internal procedures.

Quality Assurance
The cleaning company shall document a quality management system, which demonstrates
consistency with international standards and conventions. The following should at least be covered:
„ standard operating procedures for safe and environmentally sound operations
„ maintenance and calibration of equipment
„ training programmes for operators/technicians/inspectors/divers
„ supervision and verification to ensure compliance with operational procedures
„ recording and reporting of information
„ quality management of subsidiaries and subcontractors
„ job preparation
„ periodic review of near misses, work process procedures, complaints, corrective and preventive
actions as well as the issuance, maintenance and control of documents

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Approval requirements 13

 5 Granting of approval

The Approval Body shall audit the cleaning company in accordance with this procedure and review
and verify the outcome of the tests. Based on this, the Approval Body may approve the company and
issue a certificate (see Annex B) stating that the cleaning company’s operation system, procedures
and management are satisfactory and that the results of services performed in accordance with that
system can be accepted and utilised by shipping companies and ports.

Approval can be issued for one or a combination of the following services, based on the result of one
or more of the performance criteria mentioned in the test protocol for cleaning systems with capture
and should be stated in the certificate:
a. hull, and niche areas present on the vertical side or the bottom of the ship that can be readily
cleaned
b. propellers
c. niche areas that due to bends, turns etc. need special cleaning equipment and procedures.

The approval shall clearly state the type of service, type of cleaning system and manufacturer,
and what criteria have been passed. If the type of equipment and/or names of manufacturers of
equipment result in any limitations or restrictions, these should also be listed.

The cleaning company should be included in the Approval Body’s record of approved cleaning
companies.

Annual verification audit

An annual verification audit shall be held from three months before or after the anniversary date of
the issued in-water cleaning approval certificate.

The annual audit involves verification of documents and a visual inspection of the cleaning system
and its units.

Annual verification audits will be performed by the Approval Body to ascertain that system structure,
equipment, systems, fittings, and materials in the cleaning system have been maintained to a
satisfactory level for the service, for which the cleaning system is intended.

If the cleaning company has not performed an in-water cleaning with capture during the 12 months
prior to the annual audit, a renewal of certificate of approval must take place during the first
upcoming cleaning event.

Renewal of certificate of approval

Renewal or re-endorsement of the certificate of approval shall normally be carried out at intervals not
exceeding five (5) years by verification through inspection, testing and audit.

A renewal audit shall include an inspection of the system structure, equipment, systems, fittings, and
materials to ascertain compliance with the requirements of the Approval Procedure.

As part of this audit, a renewal test, based on a single ship, shall be conducted to verify the
operational performance of the cleaning system. The performance test shall be carried out in
accordance with Annex A of this Approval procedure.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Granting of approval 14

Alterations to system or cleaning procedure
When any alteration is made to the system or operating procedure that affects the approval criteria
of the approved cleaning system, the cleaning company shall immediately notify the Approval Body.
Depending on the extent of the alteration and its effect on the system, a renewal of the approval
certificate or a new approval certificate may be required when deemed necessary by the Approval
Body.

Furthermore, cleaning companies may request an additional audit to confirm the compliance of their
systems.

Suspension or cancellation of approval

The Approval Body reserves the right to suspend or cancel the approval should the cleaning company
breach any of the conditions of the approval. The list of approved cleaning companies will then be
updated accordingly. The following circumstances may also be considered as a breach of conditions.

Approval may be suspended:

1. where an audit, requested by Approval Body, has not been carried out.
2. when no corrections or corrective actions have been taken in the following cases:
a. where the cleaning did not meet the performance criteria as defined in the Approval
procedure or the results were improperly reported
b. where incidents result in a negative impact to safety of operation, personnel or protection of
the environment
c. where deficiencies have been found by an Approval Body representative.

Approval may be cancelled:

1. where alterations have been made to the cleaning company’s operating procedures relevant to
the approval certificates, without notifying the Approval Body beforehand.
2. where wilful acts or omissions are ascertained
3. where any deliberate misrepresentation has been made by the cleaning company
4. if the cleaning company has already been suspended and it has made no efforts to resolve the
non-conformities during the next 6 months.

A cleaning company whose approval has been cancelled may apply for re-approval after it has
corrected the findings/non-conformities. This re-approval will be treated like a new application for
approval and will require the cleaning company to undergo a new verification test and certification
audit.

Expiration or suspension of a parent company’s approval automatically invalidates the approval of all
subsidiaries of that company if these have been collectively certified approved in accordance with this
procedure.

In case the approval is suspended or cancelled, the port and other local authorities should be notified
by the Approval Body and/or the cleaning company.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Granting of approval 15

 ANNEX A Test protocol for in-water cleaning systems with capture

1 Introduction
This annex provides the framework for verification testing of in-water cleaning with capture systems
in accordance with the Approval procedure. As part of the approval process, a cleaning company shall
be subject to testing of the cleaning system’s declared operational capabilities and performance. This
testing will take place on actual ship surfaces (hull, propeller and/or niche areas) depending on the
cleaning system’s declared operational capabilities and performance and will be based on a series of
water quality samples which will be collected and analysed to quantify impacts of in-water cleaning
on local water quality.

2 Performance criteria
The approval of in-water cleaning systems with capture will be based on an independent testing and
assessment of the following criteria:
A. The in-water cleaning process removes at least 90% of macrofouling (ie individuals or colonies
visible to the human eye).
B. The separation and/or treatment of captured materials during in-water cleaning both: (1)
removes at least 90% (by mass) of material from seawater influent and (2) at least 95% of
particulate material in effluent water is < 10 µm in equivalent spherical diameter (ESD).
C. Local water quality parameters of TSS, in the vicinity of the cleaning unit and at the effluent
discharge point from the separation and/or treatment systems, are not elevated above ambient
levels during the same time period.
D. When applicable, dissolved and particulate biocides found in AFC (eg, copper and zinc), in the
vicinity of the cleaning unit and at the effluent discharge point from the separation and/or
treatment systems, are not elevated significantly above ambient levels during the same time
period.

To be approved, the test results will have to equal to or better than performance criteria A, B and
C. The test results of criterion D will be published on the approval certificate enabling relevant local
authorities to evaluate them and compare them to local requirements in needed.

While not a formal performance criterion, observations of any damage to ship coatings, surfaces
and structures during the testing of the in-water cleaning system should also be documented (eg,
scratches, brush marks, paint flakes, pits, bare metal/polish through, and blemishes).

3 Independent verification testing

Given the complexities of cleaning systems with capture and their application, the following test
protocol is focused on a predictive and feasible series of field trials (similar to Tamburri et al, 2020).
As mentioned above, it is not feasible or practicable to test all possible conditions, parameters and
variables that can impact in-water cleaning performances, but specific test plans should be designed
to be as predictive as possible to verify the cleaning system’s declared operational capabilities and
performance to the fullest extent possible.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 16

Testing should involve development of detailed, individualized test plans (including scope of testing,
methods, SOP, quality management system, etc) for each in-water cleaning system tested, in
consultation with the cleaning company and Approval Body. The cleaning company should secure
permission from local authorities to undertake testing if applicable.

All testing of in-water cleaning systems should be conducted by a third-party testing facility or
organisation that:
a. is independent from the cleaning company and technology manufacturer or vendor
b. implements appropriate quality assurance and quality control (eg International Organization for
Standardization/International Electrotechnical Commission [ISO/IEC] 17025 standard)
c. acceptable to the Approval Body.

4 Experimental design
A single cleaning event, on an individual test ship, is considered the unit of replication. A minimum
of three consecutive cleaning events involving a different ship on each occasion is required for
approval. The goal is to capture variability in operations, applications and environmental conditions
that will allow for verification of in-water cleaning company claims with respect to the cleaning
system’s declared operational capabilities and performance. Thus, if the in-water cleaning company
claims to meet the above criteria for safe and effective biofouling removal on both hull and/or niche
areas, performance will be quantified on both hull and/or niche areas on each of the three test ships.
Similarly, if the in-water cleaning company claims to meet criteria on both non-biocidal and biocidal
AFCs, at least two of the three ships must have appropriate biocidal coating for testing.

Conditions or applications (eg, niche areas, biocidal AFCs, biofouling level, etc.) outside of
specifications and claims for the cleaning system’s declared operational capabilities and performance
do not need to be included in the approval tests but those restrictions or limitations will be clearly
noted in the approval certificate.

5 Documentation of test conditions and operations

As part of the documentation, a list of participants of the people who take part in the test and
operation shall be made (for example handlers, workers, controllers, and/or divers). Details of who
does what shall be documented.

The following information shall be documented and reported for each test ship:
„ ship type (design, complexities/niche areas and operational profile of the ship)
„ ship availability/access for cleaning and/or testing (eg, time at berth or anchorage)
„ AFC type, age, and history
„ biofouling type and percentage cover on relevant surfaces (hull, propeller and/or niche areas) eg
from a recent inspection report
„ history of cleaning operations of the ship since last drydocking.

The following environmental information shall be measured, documented and reported for each test
trial:
„ water depth and under keel clearance
„ water visibility
„ currents, wind and waves

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 17

 „ water quality parameters of interest (eg, salinity, temperature, TSS)
„ ambient levels of biocides (eg, background levels of copper).

The following cleaning system design and operational information (during the cleaning of each
test ship), shall be documented and reported (excluding propriety and commercially confident
information):
„ in-water cleaning system design and operations
„ diver or ROV driven
„ operator/diver skill and experience
„ mode of attachment to, and movement over ship, cleaning brushes, blades, or water jets and
type, amount, configuration, etc
„ planned and actual rate of movement of cleaning unit over the test area
„ number and overlap of passes (accuracy of surface coverage)
„ capture methods (eg, cleaning unit shroud and suction)
„ flow rate of influent water including materials
„ materials and seawater influent and effluent transport and processing (eg, time for particle
settlement, level of handling, treatment, separation, type media removal of metals)
„ various pre-set modes of operations and operational adjustments during cleaning
„ contingency plans and response to system failures
„ the claimed maximum curvature, and the maximum curvature where cleaning was carried out
successfully during the test without loss of material into the water column
„ the diameter of the hose from the cleaning unit to the treatment and/or separation unit and the
declared flow rate.

6 Criterion A – removal of macrofouling

The in-water cleaning process removes at least 90% of macrofouling (ie individuals or colonies visible
to the human eye).

6.1 Sampling procedure

A semi- quantitative assessment of cleaning efficacy should be made to determine the amount of
biofouling removed from each of the areas defined during test cleaning events. Using images and/or
videos of selected areas selected for testing before and after cleaning, each area should be assessed
for percentage coverage and basic type of macrofouling. For consistency, the same video or camera
equipment, and methods should be used to assess the coverage of macrofouling before and after
cleaning.

To avoid any confusion resulting from possible changes to the biofouling over time, all before and
after images and/or videos shall be taken within a timeframe of seven days.

The Approval Body will randomly choose the areas to be used for the testing. Areas used for testing
should be relevant for the cleaning device and take into consideration safety factors such as local
weather conditions and other activities being carried out on the ship during the testing.

Before the testing, areas shall be selected by the Approval Body. Areas used for testing should be
chosen to match the sampling stratum (vertical and flat-bottom hull, curved areas, niche areas, or
propeller).

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 18

For each of the test areas, macrofouling organisms should be identified in broad taxonomic groups
(eg, soft corals, barnacles, sponges, mussels, hydroids, tube worms, anemones, bryozoans, tunicates
and algae).

The following methods should be considered before and after cleaning biofouling assessments:
1. use of the installed cameras on the cleaning unit showing videos in front of (before video) and
behind the cleaning unit (after video)
2. use of ROV’s filming minimum three vertical runs starting from the surface and moving down to
the keel – the runs should be done so the areas used for testing are easily identifiable making it
possible to compare the same areas before and after the cleaning
3. use of still photos.

For niche areas and the propeller, the entire area should be pictured or videoed before and after the
cleaning. In case of using divers during such inspections, the IMO Code of safety for diving systems
should be adhered to.

Photographs and videos should clearly depict the condition of the AFS and biofouling growth and be
taken in a consistent manner in terms of angle and distance from the surface during each run.
The water visibility should be a least 0.5 metres during the testing

The pictures and video should include or be accompanied by the name of the ship. The dive/camera
operator should carefully choose the camera settings to ensure proper lighting, exposure, focus,
colour, tone etc for capturing an accurate image.

6.2 Analytical Procedures

The percentage coverage of the biofouling should be determined before and after by comparing both
sets of images. The before and after pictures should:
1. use the same distance between the ship’s surface and the camera
2. be taken either perpendicular to the surface or if that is not possible at the same angle to the
surface
3. be date and time stamped and
4. if possible, include an electronic scale that enables the size of the pictured area to be estimated.

Each before and after image should be the same size and shape or cropped to be the same size and
shape. The size of images used for comparison should be at least 400 cm2.

The Approval Body should plan the documentation to cover different test areas to be representative
of the entire underwater area. The minimum number of images, that should be compared, depends
on:
„ hull, and niche areas present on the vertical side or the bottom of the ship that can be readily
cleaned at least 60 images
„ propellers at least 20 images
„ niche areas that due to bends, turns etc need special cleaning equipment and procedures at least
5-10 images per niche area.

6.3 Determining if Criterion A has been met

Videos or pictures as described in section 6.2 should be used for comparison to assess the efficacy of
the cleaning.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 19

The percentage of the biofouling coverage should be estimated by superimposing a 50-point grid to
the images.

The percentage coverage of the before and after pictures must be determined for each image in order
to compare them in pairs. The efficacy of the removal shall be calculated as follows:

percentage before – percentage after

Efficacy =
percentage before

The comparison can made using artificial intelligence/machine learning or an automated software
analysis system.

The average of efficacy of the cleaning of all the examined areas shall be no less than 90%.

In case one or more of the calculated efficacies are smaller than 90%, an assessment must be carried
out to determine if the results were caused by curves or bends on the surface or by restrictions in
manoeuvrability of the cleaning unit. The result of the assessment should determine if restrictions or
limitations should be added to the approval certificate.

7 Criterion B – effectiveness of the separation and/or treatment unit of

removing captured materials
The separation and/or treatment units remove(s) captured materials during in-water cleaning as
follows:
1. at least 90% (by mass) of material from seawater influent and
2. at least 95% of particulate material in effluent water is < 10 µm in equivalent spherical diameter
(ESD).

7.1 Sampling procedures

A series of water quality samples should be collected and analysed to quantify impacts of in-water
cleaning on local water quality during each approval test of the hull, propeller and/or niche areas,
in accordance with Tamburri et al, 2020. Continuous, time-integrated water samples, during a
predesignated in-water cleaning test period of at least one hour, should be collected at two locations:
at the inlet (influent) of the separation and/or treatment unit, and at the outlet (effluent) of the
separation and/or treatment unit (figure 2).

Con�nuous �me – Con�nuous �me –

integrated sampling of integrated sampling of
influent to processing processing effluent
unit during cleaning during cleaning
SEPARATION/
TREATMENT

Figure 2: Schematic arrangement of sampling.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 20

Details for each station includes the following:
„ Separation and/or treatment unit inlet sample – During the test cleaning event, a continuous,
time-integrated sample of the influent to the treatment unit, should be collected to quantify
captured material and separation and/or treatment unit efficacy. An appropriate inlet sample
port should be provided by the cleaning company. Flow rate should be set to draw at least 10 –
20 litres of sample water (exact volume and flow rate should be measured) continuously during
the entire test cleaning period. The large container sample should be uniformly mixed prior to
distributing sub-samples for at minimum, triplicate analyses of each parameter. Note that in some
cases, where large amounts of hard macrofouling is captured, a two-stage sampling approach
may be needed for effective inlet sampling, which can involve a sieve to both collect and quantify
(by wet and dry weight) material larger than 1 mm in size and for material passing through the
1mm sieve to be analysed for TSS.
„ Separation and/or treatment unit outlet sample – During the test cleaning event, a continuous,
time-integrated sample of the effluent from the treatment unit, should be collected to quantify
separation and/or treatment unit efficacy and environmental safety of treatment discharges. An
appropriate outlet sample port should be provided by the cleaning company. Flow rate should
be set to draw at least 10-20 litres of sample water (exact volume and rate should be measured)
continuously during the entire test cleaning period. The large container sample should be
uniformly mixed prior to distributing sub-samples for, triplicate analyses of each parameter as a
minimum and as per any test method requirements (ie ASTM or ISO method necessary for each
parameter).

Sampling should only be conducted when the cleaning unit is transferring biofouling material to the
separation and/or treatment unit. When cleaning unit is idle during a test cleaning event, but the
capturing system remain active the sampling activities should be paused.

Relevant
When Type of Sample
Sample Location Analyses performance
sampled sample depth
criteria
TSS,
Separation Just prior to particle size
and/or separation 1x, during Time- NA distribution B
treatment unit and/or cleaning integrated (PSD) and
inlet treatment unit biocide

Separation Just after the

and/or separation 1x, during Time- TSS, PSD and
NA B, C and D
treatment unit and/or cleaning integrated biocide
outlet treatment unit

Table 2: Water quality collection sampling summary.

7.2 Analytical Procedures

After the initial sample collection, exact container volumes should be measured. Then the container
samples should be uniformly mixed prior to collecting sub-samples for triplicate analyses of TSS
and PSD. All sub-samples should be placed in cleaned bottles of the appropriate analysis type and
size and all sample bottles should be labelled with unique identification numbers prior to sampling.
Sub-samples should be stored at the appropriate temperature for the analysis and delivered to the
accredited/approved analytical laboratories within the appropriate time frame for each analysis.

The following standard and/or approved methods may be relevant when determining TSS and PSD
in water samples collected during assessment of the cleaning system. The list is not exhaustive and
other methodologies may be available.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 21

 „ US EPA Residue, Non-Filterable (Gravimetric, Dried at 103-105°C) (EPA 160.2): Published 1971
„ ISO Particle size analysis – Image analysis methods (13322-1): Published May 2014.
„ US EPA Determination of Trace Elements in Waters and Wastes by Inductively Coupled Plasma-
Mass Spectrometry (EPA 200.8): Published 1994.
„ US EPA Inductively Coupled Plasma – Mass Spectrometry (EPA 6020A): Published January 1998.

7.3 Determining if Criteria B has been met

The separation and/or treatment of captured materials during in-water cleaning both removes: (1) at
least 90% (by mass) of material and (2) at least 95% of particulate material in effluent water is < 10
µm in equivalent spherical diameter (ESD).

For criteria B, the percent reduction in mass of material in water entering the separation and/or
treatment unit(s) (influent) versus the water discharged from the separation and/or treatment unit(s)
(effluent) for each test cleaning event should be calculated and reported. The mass of material should
be determined, per unit volume, using accepted methods for TSS. The two sub-criteria must be met
for each individual test cleaning.

8 Criteria C and D – Impact on local water quality

Particulate and dissolved biocides and compounds relating to the AFS shall be tested and reported to
measure if local water quality parameters of TSS, and when applicable dissolved biocides found in AFC
(eg, copper and zinc), in the vicinity of the cleaning unit and at the effluent discharge point from the
separation and/or treatment systems, are not elevated significantly above ambient levels during the
same time period.

8.1 Sampling procedures

A series of water quality samples should be collected and analysed to quantify impacts of in-water
cleaning on water quality during each approval test of the hull, propeller and/or niche areas,
in accordance with Tamburri et al, 2020. Continuous, time-integrated water samples, during a
predesignated in-water cleaning test period of at least one hour, should be collected at three
locations: on the cleaning unit (to quantify debris capture efficacy), greater than 50 m away from
the cleaning activity (as simultaneous quantification of background conditions), and at the outlet
(effluent) of the separation and/or treatment unit (figure 3). It is also recommended that background/
ambient water quality conditions also be measured by using discrete time point samples before and
after the test cleaning event at the discretion of the Approval Body and Testing Organisation.

> 50 m away, con�nuous On the outside of the Con�nuous �me –

�me-integrated water cleaning unit, con�nuous integrated sampling of
background sample at �me-integrated water processing effluent
mid-depth during cleaning sample during cleaning during cleaning
SEPARATION/
TREATMENT

mid-depth

Figure 3: Schematic arrangement of sampling.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 22

Details for each station includes the following:
„ Cleaning unit sample – A sampling hose or submersible pump should be attached to the cleaning
unit to collect a continuous, time-integrated samples for at least 1 hour during each test cleaning
event. The intake location (and method of mounting the hose or pump) should be agreed with
Approval Body and should be based on location of highest possible signal (eg, computational fluid
dynamics assessment of the location of the highest potential concentrations of material removed
from the test ship during in-water cleaning). Water should be drawn to sample container(s) using
a pump or pushed from a pump attached to the cleaning unit to the sample container(s). The
sample collection station can be located on the shoreside or on a small boat/barge positioned
at the cleaning unit’s point of entry into the water. Flow rate should be set (and recorded) to
draw at least 10 - 20 litres of sample water (exact volume should be measured) continuously. The
large container sample should then be uniformly mixed prior to distributing sub-samples for, at
minimum, triplicate analyses of each parameter.
„ Background sample during cleaning – In order to assess ambient levels of measuring parameters
during the test cleaning event, a continuous, time-integrated sample should be collected at
least 50 metres away from the test area (not impacted by cleaning or discharges from the ship).
A pump and hose system should be deployed adjacent or adhered to the test ship with intake
positioned at approximately mid-depth between water line and bilge keel. Flow rate should be
set to draw at least 10 - 20 of sample water (exact volume and flow rate should be measured)
continuously during the entire test cleaning period. The large container sample should be
uniformly mixed prior to distributing sub-samples for at minimum, triplicate analyses of each
parameter
„ Separation and/or treatment unit outlet sample – During the test cleaning event, a continuous,
time-integrated sample of the effluent from the treatment unit, should be collected to quantify
treatment unit efficacy and environmental safety of treatment discharges. An appropriate outlet
sample port should be provided by the cleaning company. Flow rate should be set to draw at least
10 – 20 litres of sample water (exact volume and rate should be measured) continuously during
the entire test cleaning period. The large container sample should be uniformly mixed prior to
distributing sub-samples for a minimum, triplicate analyses of each parameter. Note, that the
same outlet/effluent sample, analyses and results above in criteria B can be used for criteria C.
„ Pre and post cleaning background samples (optional) – Variability in ambient water quality
should be characterized by discrete sampling at a predetermined test ship berth or anchorage
location before and after the in-water cleaning event. At least one sample should be collected
before, and at least one sample collected after, the test cleaning event, using a discrete water
sampling device (eg, Van Dorn- or Niskin-style water sampler) lowered to the same depth as
the background sample above (approximately mid-depth between water line and bilge keel of
the test ship). Each sample should be uniformly mixed prior to distributing sub-samples for at
minimum, triplicate analyses of each parameter.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 23

 Relevant
When Type of Sample
Sample Location Analyses performance
sampled sample depth
criteria
Varies over
Attached to 1x, during Time- TSS, PSD and
Cleaning unit cleaning C and D
cleaning unit cleaning integrated biocide
period
Separation Just after the
and/or separation 1x, during Time- TSS, PSD and
NA B, C and D
treatment unit and/or cleaning integrated biocide
outlet treatment unit
Adjacent to
the ship, at
Background 1x, during Time- TSS, PSD and
least 50 metres Mid-draft C and D
during cleaning cleaning integrated biocide
from cleaning
activity
Optional
pre-clean
Berth or 1x, during TSS, PSD and
background Discrete Mid-draft C and D
anchorage cleaning biocide
within 24
hours
Optional
post-clean
Berth or 1x/day prior to TSS, PSD and
background Discrete Mid-draft C and D
anchorage test biocide
within 24
hours
Table 3: Water quality collection sampling summary.

8.2 Analytical procedures

The analytical procedures for TSS and PSD are described above in section 7.2. The following
are examples of standard and/or approved methods for quantifying AFS biocides. The list is not
exhaustive and other methodologies may be available.
„ ASTM Rotating Cylinder (method D6442-06)
„ ISO Method for Copper-ION (15181-2): published 01 June 2007.
„ ASTM Method for organotin (method D5108-07): re-approved 2007
„ ASTM Methods for organic biocides (zinc and copper pyrithione, DCOIT and CDMTD) (method
D6903-07): published 2007.
„ ISO Method for Zineb (15181-3): published 01 June 2007.
„ ISO Method for pyridine-triphenylborane (PTPB) (15181-4): published August 2008. I
„ ISO Method for tolylfluanid and dichlofuanid (15181-5): published May 2008. vi.
„ ISO Method for tralopyril (15181-6): expected publication, 2011.

8.3 Determining if Criteria C and D have been met

Criterion C
TSS is used as a measure of both biofouling and the impact that particulate material from the AFS has
on water quality, and determination of this criteria should assess:
1. cleaning unit samples, against the same parameter(s) from background samples during the same
cleaning time period, and
2. outlet samples from separation and/ or treatment unit against the same parameter(s) from
background samples.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 24

Test results should not be elevated significantly above ambient levels. To determine this statistical
analysis (eg confidence interval of 95% or α = 0.05 in a t-test) should be used.

Criterion D
Dissolved biocides and compounds (eg copper and zinc) are used as a measure of AFS’ impact on
water quality and determination of this criteria should assess: eg
1. cleaning unit samples, against the same parameter(s) from background samples during the same
cleaning time period, and
2. outlet samples from separation and/or treatment unit against the same parameter(s) from
background samples.

Results of the test(s) should not be elevated significantly above ambient levels. To determine this
statistical analysis (eg confidence interval of 95% or α = 0.05 in a t-test) should be used.

If the system cannot comply with the requirements of D, it is recommended that a risk-based
approach is used to establish the potential impact on water quality in consultation with the local
authorities. The result of testing for dissolved biocides and compounds found in the AFS (eg copper
and zinc) shall be stated on the approval certificate to allow for the system to be evaluated in
accordance with local requirements.

9 Assessment of paint damage

Pictures and/or videos of AFC should be examined for obvious signs of in water cleaning damage.
While not a performance criterion, a description of any and all observed damage should be included
in the final report. Such damage can include symmetrical swirl patterns caused by the cleaning
mechanism and/or linear traction damage caused by drive wheels.

Figure 4: Examples of paint damages.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 25

9.2 Analytical procedures
Images taken before and after the cleaning procedure under criteria A should be selected to visually
assess if the painting has been damaged during the cleaning process. If possible, images with a
coverage of biofouling less than 15 percent should be used.

A minimum of 5 images taken before the cleaning, are to be compared with images of the same
areas taken after the cleaning. Based on the comparison of the before and after pictures, it should be
assessed if the damage likely occurred during the individual test.

The biofouling type and coverage should be taken into consideration and use of images where
removal of the biofouling may cause damage to the AFC should not be used.

9.3 Determining the paint has been damaged

Damage to the paint that has been caused evidently by the cleaning unit should be documented in
the testing report.

In case such damage has been found, a dialogue should be commenced between the Approval Body
and cleaning company. Based on the dialogue, a correction plan provided by the cleaning company
that describes how such damages can be avoided to be drawn up to the satisfaction of the Approval
Body.

The correction plan should be accepted by the Approval Body before further testing can take place.

In case damage is observed on consecutive tests, the Approval Body may add restrictions or
limitations to the approval certificate. Example: Cleaning can be carried out on AFS other than silicone
based coatings.

10 Data management and quality

The independent testing facility should follow standard/accepted data management and analysis
procedures (see Tamburri et al, 2020). For example, data logs should be recorded throughout
testing, copied or duplicated, and archived. The datasheets should be signed by the analyst upon
completion, verified by a quality officer, and stored until the data are logged into a digital file, and
the data themselves are verified. Additionally, data from other analyses should be recorded in
standard formats, such as data collection forms, bound and paginated laboratory and field notebooks,
spreadsheets, and electronic data files.

Specific data analyses should be conducted as prescribed in individual test plans. All testing should
occur at a Testing Organisation that has been approved, certified, and audited by an independent
accreditation body or the relevant regulatory agency. A test plan and standard operating procedures
(SOPs) should be followed while conducting all tests.

11 Reporting
The test report should include the test plan, all SOPs, all logged instrument data collected, and all raw
data (both direct verification test and ancillary environmental data). Regardless of which of the three
criteria Approval is granted, all results should be included in the final reports.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 26

The following should be reported:
„ an audit report from the certification audit or the renewal audit (chapter 2 and Annex C) including
given recommendations, findings and corrective actions
„ a description and specification of the cleaning system tested (chapter 2)
„ details of the ship (Annex 1, section 5)
• ship type (design, complexities/niche areas and operational profile of the ship)
• ship availability/access for cleaning and/or testing (eg, time at berth or anchorage)
• AFC type, age, and history
• history of cleaning operations of the ship since last drydocking.
„ a list of participants who took part in the test (Annex 1, section 5)
„ a resume of how the test was undertaken for each of the criteria A-D, including:
• claimed limitations of operations (chapter 2)
• a description of the procedures followed during set-up, testing of the system and close down
(Industry standard, chapter 9).
„ before cleaning: description and coverage of biofouling present in each of the test areas (Industry
standard, chapter 5)
„ environmental information (Annex A, section 5)
„ cleaning system design and operational information (Annex A, section 5)
„ experimental design and conditions under which the results of samples were taken, including
where and when the samples were taken and the total duration of treatment (Annex A, sections
4-8)
• number of test areas and size of each area
• locations of the test areas
• a description of residual biofouling observed in images of each replicate treated area selected
for analysis
• whether a ship underwent a full or partial clean and rate of cleaning as expressed in m2/unit
time.
„ any damage to the condition of the anti-fouling coating in each test area (section 9)
„ description of any variations or deviations in application of the test relative to the SOP and test
requirements
„ a discussion of the system efficacy, including whether the criteria were met
• based on report from the independent Testing Organisation
• documentation in form of pictures and video regarding removal of macrofouling.
„ recommendations for system or SOP improvement
„ resume of test result including detailed information of the measured concentrations etc for all
criteria (A-D) and whether the system passed the test
„ conclusion stating criteria that were passed/failed and restrictions or limitations that will need to
be added to the certificate.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Testprotocolforin-watercleaningsystemswithcapture 27

 ANNEX B Sample format of approval certificate

APPROVAL CERTIFICATE OF IN-WATER CLEANING COMPANIES Cert Number: XXXXXX

This is to certify that the operations and management systems of [name of company] is in compliance with the
Approval procedure for in-water cleaning companies and has been approved to perform [in-water cleaning of
the hull and niche areas that do not need special cleaning equipment] [in-water cleaning of the niche areas that
require special cleaning equipment] [in-water cleaning of propellers]

The following performance criteria have been tested:

Criteria A: The cleaning system is able to remove XX% of macrofouling -
Criteria B: The cleaning system is able to perform the separation and/or treatment of captured materials.
During in-water cleaning the system:
i) removes at least XX% of material from seawater influent (by mass) and
ii) XX% of particulate material in seawater effluent is > 10 µm in equivalent spherical diameter (ESD).
Criteria C: The level of applicable TSS and particulate biocides of Anti-fouling system (eg copper and zinc)
found in the local water are not statistically elevated above ambient levels during cleaning -

The following performance criteria has further been tested:

Criteria D: Dissolved biocides and compounds (eg copper and zinc) in the effluent are/are not statistically
elevated above ambient levels.

Restrictions or limitations: (height of biofouling, non-compatibility with certain AFS etc). Insert restrictions or
limitations, if any, else write “none”.

Details of the cleaning system:

Type of cleaning system:
Name of the manufacturer:
Model:

Result of tests conducted:

1. claimed height of hard calcareous biofouling and maximum height of hard calcareous biofouling removed
during the test: enter text (in mm)
2. amount of biofouling removed during the test: enter text
total suspended solids released to the marine environment during testing: enter text

This certificate is valid until enter date

Issued at enter text on enter date
Details of Approval Body: enter text

Digitally signed
Approval conditions:
„ The operation of cleaning system should take place within the criteria mentioned in the Approval
procedure for in-water cleaning companies, version 1.0.
„ If changes are made to the operations and management system of the cleaning company, such
changes shall be reported to the Approval Body. Re-audit may be deemed necessary by the
Approval Body.

The full-scale results of test are attached to this certificate as an Appendix.

Date certificate valid until (subject to annual review): enter text

Issuing Approval Body: enter text

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Sample format of approval certificate 28
NOTES ON THE BACK OF THE CERTIFICATE

Performance criteria:

Criterion A – removal of macrofouling

The in-water cleaning process removes at least 90% of macrofouling (ie individuals or colonies visible to the
human eye).

Criterion B – effectiveness of the separation and/or treatment unit of removing captured materials

The separation and/or treatment units remove(s) captured materials during in-water cleaning as follows:
3. at least 90% (by mass) of material from seawater influent and
4. at least 95% of particulate material in effluent water is < 10 µm in equivalent spherical diameter
(ESD).

Criteria C and D – Impact on local water quality

Particulate and dissolved biocides and compounds relating to the AFS shall be tested and reported to measure
if local water quality parameters of TSS, and when applicable dissolved biocides found in AFC (eg, copper and
zinc), in the vicinity of the cleaning unit and at the effluent discharge point from the separation and/or treatment
systems, are not elevated significantly above ambient levels during the same time period.

Criterion D is not mandatory for a cleaning company to get approved.

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Sample format of approval certificate 29
 ANNEX C Documents applicable for different types of audit

Certification Annual Renewal

Type of audit
audit audit audit
Agreements and arrangements for parts of the services that are
x x
subcontracted
Declaration of the services requested to be under the scope of
x x
approval

Description of equipment used in cleaning process x x x

Documentation of part-testing or pilot-testing on a smaller scale x

Experience of prior in-water cleanings carried out by the cleaning

x x
company. A history of operations undertaken
List of subsidiaries, if applicable, and documentation regarding
x x
maintenance and the operation of the equipment

Maintenance and calibration records x x x

Outline of cleaning company eg organisation and management

x x
structure

Records of cleaning operations x x x

Records of near misses, incidents, and corrective actions X x x

Risk assessments X x

SOP manual x x x

Staff introduction record x x

Staff work experience and training records x x x

APPROVAL PRODECURE FOR IN-WATER CLEANING COMPANIES Documentsapplicablefordifferenttypesofaudit 30