New York Sea Grant's
Marina Pollution Prevention Web Site
Section 2: Painting
& Fiberglass Repair
- Hull & Topside Painting
Hull and topside paints may be toxic and inhalation may cause
cancer. If spilled, they may harm aquatic life and water quality.
Additionally, the fumes released by some paints can contribute
to air pollution.
paint in a centralized, covered area. Return all unused paints
to that area and immediately and properly mange empty containers.
problem of having leftover paint by mixing only as much paint
as is needed for a given job. Consider sharing leftover paints
with customers or setting up an exchange area for customers to
swap unused items.
painting to interior surfaces and brightwork, where paint materials
and spills can be contained and prevented from entering the water.
Do not allow in-water hull scraping or any process that occurs
underwater to remove paint from the boat hull.
is not advised to conduct painting while the boat is in the water,
if it must be done, transfer the paint to the vessel in a small
(less than one gallon), tightly covered container. Small containers
mean small spills.
an upland area for debris-producing maintenance activities such
as sanding and painting.
Do as much
work as possible away from the water, including mixing paints
and/or cleaning brushes.
or drop cloths to collect drips. Weight the bottom edges of tarps
and plastic sheeting to keep them in place.
Use drip pans
for all paint mixing, paint transfer, and/or equipment clean up.
high solids content and water-based paints and surface preparation
products instead of traditional paints and primers.
the use of non-toxic, high bonding, and easily cleaned hull coatings
where appropriate. (For more information on non toxic paint alternatives
click on Related Resources and Information on this Topic Button
at bottom of this page.) Use brushes and rollers instead of paint
sprayers whenever possible, since paint spraying is potentially
more wasteful and more harmful to the environment. If paint spraying
must be done, see the "Paint Spraying" fact sheet,
and thinners by draining the clean product off the top once solids
clean up spilled paint or varnish immediately.
In New York, most boat bottom paints are considered pesticides.
Marinas that sell or apply these paints must follow the state's
pesticide management rules which require a business license and
certification requirements for those who apply the paint. For
more information on New York's Pesticide Management Regulations,
waste determination must be conducted on painting wastes and any
materials used to clean up spilled paint to establish whether
or not their disposal is subject to hazardous waste regulations.
To determine if they are hazardous, the generator must either
have waste materials tested or utilize reliable "knowledge
of process" information for the waste (if available) [40
CFR 262.11, click
here]. Such information could include testing by
haulers, or studies by industry trade groups. For more information
on New York hazardous waste testing requirements, click
and other containers that have residues of hazardous (e.g., oilbased)
paints must be handled as hazardous waste unless they have been
"emptied," which means the container has been cleaned
following directions given on the label. In some cases this means
the container is drained of all material that can be removed from
them by normal methods (e.g., pouring or pumping), AND no more
than one inch (or 3% by weight) of residue remains in the container
[40 CFR 261.7, click
here]. "Emptied" containers of hazardous
paints and those that have dried out residues of non-hazardous
(e.g., latex) paints may be recycled as scrap metal, or disposed
of in the regular trash.
Paint or varnish
that is accidentally discharged to the ground or waters of the
state must be reported to the state (In New York call the NYSDEC
Oil Spill Hotline at (800) 457 7362. For more information on reporting
and responding to spills in New York, click
If paint or
varnish that is discharged into navigable waters causes a visible
sheen, it may also be necessary to report the discharge to the
National Response Center at (800) 424-8802.
If there is
a storm water discharge from your facility and any paint, varnish,
thinners, etc. may come into contact with precipitation you may
have to register for a General Permit for the Discharge of Storm
Water Associated with Industrial Activity ("Storm Water General
Permit"). For more information on storm water permitting
in New York, click