02-04-2002 Port of Houston Expansion Review Committee Minutes

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12 1999). Some of the alternatives have already been banned in some countries or on some types of sailing~crafts. For example, after 2000, antifouling_paints containing copper and Irgarol® will be banned on all pleasure craft on the East Coast of Sweden, and Denmark has banned products containing Diuron and Ir ag role'. To conduct a risk assessment for most of the alternative antifoulants, exposure concentrations would have to be modeled. Additionally, effects data are limited to only a few species and most often based on standard acute toxicity tests. As a result, the toxicity endpoints are generally not comparable between TBT and other antifoulants, and toxicity data are not available for a group of species that is representative of a diverse community. Risk assessments of TBT, however, in countries with OAPCA-like regulations, have demonstrated that risks to aquatic life appear to be limited to chronic effects in a few sensitive species in marinas and some shipyards and commercial harbors, but not in fish/shellfish habitat proximal to these areas. Given that the estimated risks posed by TBT have been well studied and tend to be low and localized to its source, and that the exposure and effects data are limited for alternative antifoulants, there is currently no basis for replacing TBT with an alternative antifoulant. A comprehensive and defensible comparative risk assessment of TBT and alternative antifoulants will be necessary to demonstrate whether alternative antifoulants would be expected to have fewer impacts on the environment than TBT. Irgarol is a registered trademark of Ciba-Geigy Corporation. All rights reserved. Underline emphasis mine Conclusion There is currently no United States regulation or Marine law which can force compliance of foreign vessels into harmony with U.S. environmental regulations concerning the leaching of Organotin and other unwanted Marine traffic pollutants into Galveston Bay. This due solely to the passage of Non-Compliant International ship traffic If the Corps of Engineers gives approval to the Bayport expansion, it is in the unenviable position of encouraging an acute violation of the Law regarding the obvious increase in Organotin and other toxic pollutants in Galveston Bay, merely through the increase of International marine traffic.