Labelling of antifouling paints

1. Definition of an antifouling paint

An antifouling paint is any film-forming coating that allows the controlled release of biocides contained within the coating. The biocides are intended to prevent the settlement and growth of fouling marine organisms, including algae, on the hulls of boats, fish nets used in aquaculture and other structures in the aquatic environment.

2. Introduction

The most common method of applying antifouling agents is in the form of paint.

Generally, the provisions of the requirements on preparing a labellabel presentation and layout, and label content apply to antifouling paints; hence, this guideline should be used in conjunction with those requirements. However, antifouling paints are often produced with a colour range that can affect the level of active constituents; their method of application often differs from that of agricultural chemicals; and the Standard for the Uniform Scheduling of Medicines and Poisons (the Poisons Standard) have special labelling provisions relating to paints.

3. Label content

3.1. Main panel

3.1.1. Signal heading

3.1.1.1. Relevant particulars

If the paint contains a substance listed in any of the following—Schedule 5 of the Poisons Standard; Appendix A or B of the Poisons Standard; or below the listed level in Section 7/Appendix I of the Poisons Standard—it does not have to be labelled as a poison. No signal word is required.

If the paint contains a substance that is listed in Schedule 6 or 7 in the Poisons Standard, but is not covered by Section 7/Appendix I of the Poisons Standard, that substance must be labelled in accordance with the usual requirements for a Schedule 6 or 7 poison. The relevant signal word is POISON or DANGEROUS POISON.

If the paint contains a substance specified as a First Group or Second Group paint in Section 7/Appendix I of the Poisons Standard, the signal word WARNING must be used:

WARNING/POISON/DANGEROUS POISON

KEEP OUT OF REACH OF CHILDREN
READ SAFETY DIRECTIONS BEFORE OPENING OR USING

3.1.1.2. Layout and placement

Where signal words or cautionary statements (or both) are required, the requirements specified for those statements in the label content requirements apply.

3.1.1.3. Legibility

Where signal words or cautionary statements (or both) are required, the requirements specified for those statements in the label content requirements apply.

3.1.2. Product name

The requirements in the label content requirements apply. The APVMA will, however, allow a name to contain figures or letters that are used internationally to identify these products.

3.1.3. Active constituents

The requirements in the label content requirements apply, except as indicated below.

Where an antifouling paint has a colour range and is formulated in such a way that the amount of pigments for each colour results in a variation in the concentration of the active constituents by less than 5 per cent of the product, a single label can be used for the colour range, provided that the concentrations of the active constituents are shown as a range. For example:

     490–510 g/L CUPROUS OXIDE
300–315 g/L ZINC OXIDE

If the variation exceeds 5 per cent, separate labels declaring the concentrations of the active constituents for each colour must be produced.

Provision must be made to identify the colour of the paint either in the distinguishing name or in the lower part of the main panel of the label.

3.1.4. Solvents

A solvent must be declared on the label if it is a poison that is:

  • listed in Schedules 5, 6 or 7 of Part 4 of the Poisons Standard

All other requirements of the label content requirements apply.

3.1.5. Poisons that are not active constituents or solvents

A substance that is not an active constituent or solvent must be declared on the label if it is:

  • listed in Schedules 5, 6 or 7 of Part 4 of the Poisons Standard, and is not covered by the Uniform Paint Standard poison-labelling exemption
  • a poison as specified in the Schedules of the Uniform Paint Standard; in this case, it must be declared on the label in accordance with the instructions in that Standard.

The requirements in the label content requirements apply.

3.1.6. Statement of claims for use

The requirements in the label content requirements apply.

3.1.7. Net contents' statement

The requirements in the label content requirements apply.

3.1.8. Colour of paint

If the colour of the paint is not specified in the name of the product, the label should include a panel in which to identify the colour.

3.1.9. Company name and address

The requirements in the label content requirements apply.

3.1.10. Ancillary panel(s)

The ancillary panel(s) should include directions for use and other information necessary for proper use of the product, as indicated below.

3.1.11. Directions for use

The requirements in the label content requirements generally apply, with appropriate modifications; for example, it is acceptable to describe pests as ‘fouling organisms’, ‘marine fouling’ or similar terminology without identifying specific organisms.

For antifouling paints, the directions for use must provide adequate instructions for the use of the product, including information on application methods, surface preparation, clean up, recoat time, immersion and so on. It is acceptable to refer to the availability of more detailed directions in a technical bulletin, product data sheet or similar, but on its own this will not be regarded as sufficient directions for use on the label.

The following is an example of the directions for use that may be used.

THIS ANTI-FOULING is suitable for most vessel types/aluminium hulls only. To be applied over an anti-corrosive coating (such as THIS PRODUCT) or existing ANTI-FOULING provided it is in sound condition which has been high pressure water washed and allowed to dry thoroughly.
MIXING: Thoroughly power mix before use.
THINNING: Thin up to X% with [THINNER NAME].
APPLICATION METHOD: Spray is preferred, brush/roller is acceptable but extra coats may be required to achieve the correct thickness. Apply two coats per season on the hull and three on leading and trailing edges, rudder, keel and skeg.
COVERAGE: Theoretical coverage is X m2/L per coat.
DRY FILM THICKNESS: Recommend at X µm per coat. For further information refer to ‘technical data sheet
DRYING TIMES: @ 20–25°C. Allow minimum of X hours between coats.
TIME BEFORE LAUNCHING: @20–25°C. Allow minimum X hours and maximum Y hours.

3.1.12. 'Not to be used' statement

The requirements in the label content requirements apply. A label must include the following 'Not to be used' statement:

NOT TO BE USED FOR ANY PURPOSE, OR IN ANY MANNER, CONTRARY TO THIS LABEL UNLESS AUTHORISED UNDER APPROPRIATE LEGISLATION. 

3.1.13. Other limitations and prohibitions

Any other general limitations or prohibitions that may be necessary, including any surface to which the product may not be applied. For example:

NOT TO BE USED ON ALUMINIUM HULLS

3.1.14. Protection statements

The requirements in the label content requirements apply.

The following heading should appear on the label for an antifouling paint:

PROTECTION OF WILDLIFE, FISH, CRUSTACEANS AND ENVIRONMENT

The statements under this heading will vary depending on the materials contained in the product, but in general they must include warnings about the hazards of the product to the environment and non-target marine organisms. The following statements may be used:

Very toxic to aquatic life.
DO NOT contaminate soil or waterways with paint, dust and scrapings, or with used containers.

3.1.15. Storage and disposal statements

The statements under this heading must provide appropriate instructions on the safe and appropriate means of storage and disposal of containers and leftover paint. The following disposal statement should be used:

Store in the closed original container, in a cool, well ventilated area. Do not store for prolonged periods in direct sunlight. Do not re-use any empty containers.
Dispose of empty containers by crushing and disposing in an industrial waste bin or at a municipal refuse disposal site. DO NOT pour leftover paint down drains. Keep unwanted paint in sealed containers for disposal via specified chemical waste collections. DO NOT burn empty containers or product.

3.1.16. Safety directions and first aid instructions

The requirements in the label content requirements apply. The label must include safety directions that relate to safety in handling, mixing and use of the product. Safety directions are specific to the active constituent and other constituents in a formulation and apply regardless of scheduling considerations related to the product. First aid instructions specify the initial action to be taken to counteract the effects of exposure to the product.

Safety directions and first aid instructions for common anti-fouling paint active constituents and excipients have been determined by the APVMA in the Anti-fouling paint guidance.

If no safety directions and first aid instructions in the Anti-fouling paint guidance are appropriate you must apply to the APVMA to obtain an appropriate statement.

3.1.17. Batch number, date of manufacture of formulation and expiry date

The requirements in the label content requirements apply.

3.1.18. APVMA approval number

The requirements in the label content requirements apply.

4. Label examples

An example label is shown below. Approved labels for existing registered anti-fouling paints can be accessed through PubCris (https://portal.apvma.gov.au/pubcris) by searching ‘antifouling’.

4.1. Example

A label for an antifouling paint that contains one active constituent, one non-active poison, (Schedule 6 or 7 poisons) and a solvent that is required to be declared on the label.

4.1.1. Main panel

  1. Signal heading (whichever is applicable):

    POISON or DANGEROUS POISON
    KEEP OUT OF REACH OF CHILDREN
    READ SAFETY DIRECTIONS BEFORE OPENING OR USING

  2. Product name, for example:

    SEAFAST ANTIFOULING PAINT

  3. Active constituent statement:

    Active constituent: [x]g/L [Approved common name of active constituent]

  4. Solvent statement:

    Solvent: [x] g/L [Approved common name of solvent]

  5. Other poison statement :

    Also contains [x] g/L [Approved common name of poison]

  6. Statement of claims for use, for example:

    An ablative antifouling suitable for wooden hulls

  7. Contents
  8. Colour panel
  9. Name and address of company

4.1.2. Ancillary panel(s)

  1. Directions for use, for example:

    DIRECTIONS FOR USE

    [provide full information about preparation, application, etc.]

  2. Limitation on use statement:

    NOT TO BE USED FOR ANY PURPOSE, OR IN ANY MANNER, CONTRARY TO THIS LABEL UNLESS AUTHORISED UNDER APROPRIATE LEGISLATION

  3. Other limitations, for example

    NOT TO BE USED ON ALUMINIUM HULLS

  4. Precautionary statements, for example:

    PROTECTION OF WILDLIFE, FISH, CRUSTACEANS AND ENVIRONMENT
    VERY TOXIC TO AQUATIC LIFE

    DO NOT contaminate soil or waterways with paint, dust and scrapings, or with used containers

  5. Storage and disposal
  6. Safety directions
  7. First aid instructions
  8. Additional information is listed in the safety data sheet
  9. Batch number
  10. Date of manufacture
  11. APVMA approval number

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