the retail sale of antifouling paints cxsntaining organotin cxstpounds if: 

 (1) the total concentration of tin in dried copolymer paints e xc eeded 7.5% 

 by weight of tin, or (2) the total concentration of tin in other 

 non-copolymer [free association] paints exceeded 2.5% by weight of tin 

 (The Control of Pollution (Anti-Fouling Paints) Regulations - Statutory 

 Instruments No. 2011, 1985) . These regulatory actions were enacted with 

 the provision that they would be reviewed with the interim results of the 

 comprehensive scientific studies that were being carried out by both 

 government and non-government laboratories, which included studies on the 

 distribution, fate and effects of TOT in the environment and laboratory 

 toxicity studies. 



During the 1986 boating season, a detailed monitoring program was 

 conducted by the Ministry of Agriculture, Fisheries and Food (MAFF) , (as 

 proposed above) in oyster cultivation areas of 9 estuaries of England and 

 Wales. These studies found that water column TOT concentrations still 

 exceeded 20 ng/1 [the UK proposed EQT] by up to ten times in six of the 

 nine estuaries. An in-depth review of these data and add i tional data 

 provided by other UK researchers led to the conclusion that the proposed 

 EQT was not being met in areas of high boat densities. Also there were 

 measurable environmental problems resulting from the use of TBT as an 

 antifoulant on nets and pens used in salmon cultivation in Scotland (see 

 Davies, 1987) , and significant findings of imposex (sex changes of females 

 to males) in dogwhelk populations (see Section 4.2.4 and Figures 4.3 and 

 4.4 this report) . The finding of these high levels following regulatory 

 actions led DOE in July of 1987 to initiate the total ban on the use of 

 TBT in antifoulant paints on small boats and to revise the previous 

 regulatory actions, because these results suggested that the existing 

 controls were not effective enough in reducing TBT Water column 

 concentrations to acceptable levels to protect sensitive species. The DOE 

 has also suggested a lowering of the TBT water quality standard from 20.0 

 ng/1 to 2.0 ng/1, but as of February 1988, no action has been taken. 

 These new regulations, introduced in January 1987, reduced the maximum 

 allowable tin content of copolymer paints from 7.5%. to 5.5% through The 

 Control of Pollution ACT (COPA) of 1986, which amended the Control of 

 Pollution Act of 1985 (the Antifouling Paints Regulations, of 1985) No. 

 2300, 1986) . These prohibited the retail sale and the supply for retail 

 sale of antifouling paints containing a triorganotin compound as well as 

 the wholesale and retail sale of antifouling treatments containing such a 

 compound. The ban also did not make any exceptions to accommodate vessels 

 with aluminum hulls, outboard drives, parts or fittings, as have U.S. 

 regulatory strategies. The DOE expected the paint companies to provide 

 suitable products in the short term, and in fact both International Paints 

 and Blakes are now marketing in the UK, paints, which they say are 

 suitable for this use (AI27 and Lynx) . These regulations came into force 

 an May 28, 1987 (The Control of Pollution (Anti-Fouling Paints and 

 Treatments) Regulations, 1987 - Statutory Instruments No. 783, 1987). It 

 also should be noted that the control of pesticide regulatory actions in 

 the U.K., has shifted from DOE to the Ministry of Agriculture, Fisheries 



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