(2) Prohibit the use of TBI antifouling paint on all non-aluminum 

 hulled vessels under 65 feet in length and require appropriate 

 paint label restrictions. 



(3) Classify TBI antifouling paints as restricted use pesticides, 

 restrict their sale to certified applicators and their use by 

 persons under the direct supervision of an on-site certified 

 applicator. 



(4) Require additional label language and compliance with certain 

 use directions pertaining to the removal and disposal of old 

 paint prior to the application of new paint. 



Pursuant to Section 304(a) of the Clean Water Act, EPA issued a water 

 quality advisory in October 1987 (EPA, 1987) , through the Criteria and 

 Standards Division of the Office of Water Regulations and Standards 

 (OWRS) . Water quality advisories have been developed as an interim 

 vehicle for transmitting the best available scientific information 

 concerning the aquatic life and human health effects of selected chemicals 

 for which information is needed quickly but for which sufficient data, 

 resources, or time are not available to allow derivation of a national 

 ambient water quality criteria. The TBT advisory issued by EPA (1987) 

 reports that "if the measured or estimated ambient concentration of tri- 

 butyltin (TBT) exceeds 26 ng/1 in freshwater or 10 ng/1 in salt water, the 

 discharger, after consultation with an appropriate regulatory agency, 

 should evaluate the available exposure and effect data and complete one or 

 more of the following options within a reasonable period of time: 



a. Obtain additional measurements of the ambient concentration. 



b. Improve the estimate of the ambient concentration. 



c. Obtain additional laboratory and/or field data on the effects 

 of TBT on aquatic organisms and their uses so that a revised, 

 and usually higher, aquatic life advisory concentration or a 

 water quality criterion can be derived. 



d. Conduct appropriate toxicity tests on the effluent. 



e. Reduce the ambient concentration of TBI to an acceptable 

 level. 



OWRS is currently developing a water quality criteria document (a more 

 permanent set of recommended guidelines than those in the advisory) , and 

 is under congressional mandate to have the criteria in place by 

 March 31, 1989. 



As a public information self regulatory risk communication action, EPA's 

 Office of Policy Analysis of the Office of Policy, Planning and Evaluation 

 and the National Oceanic and Atmospheric Administration's National Marine 

 Pollution Program Office have cofunded Science Applications International 

 Corporation to develop and prepare a public information leaflet similar to 



11-12 



