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area, the biosecurity risk is low. The decision support tool for granting exemption under regulation 
A-4 of the IMO Ballast Water Management Convention (BWMC) by HELCOM/OSPAR for the 
North and Baltic Sea is an existing tool for identifying low risk conditions. This decision support 
tool bases on the “target species list”, which is part of the JHP process and comprises a list of 
non-indigenous species that are likely to impair or damage the environment, human health, 
property and resources if they spread in the BSR. 
An option to use this tool also in the context of IWC would be, to develop a Biofouling Target 
Species list in the BSR. Discussion on this option, based on discussions within the COMPLETE 
PLUS stakeholder group, has already started at TG BALLAST 11-2020 (Outcome of TG BALLAST 
11-2020, paragraph 9.2) and could further take place at the HELCOM/OSPAR Joint Task Group 
Ballast and Biofouling. 
We recommend that trading areas containing the same Biofouling Target Species should be 
defined as “Same port and surrounding” whereas a ship’s trading area with occurrences of 
different Biofouling Target Species in e.g. port of departure and arrival could be classified as 
“International”. 
Not only as long as this differentiation of NIS and their occurrence is not standardized or defined 
but also afterwards, the Biofouling Management Plan and Biofouling Record Book (going further 
into detail in chapter 3.1.1) could be used. They comprise the ship’s voyage history since the last 
Sleaning or paint application and all relevant management measures that serve relevant 
authorities as information and proof regarding conducted measures. Furthermore, it informs about 
possible origins of the biofouling growth and helps to assess the risk of IWC (Department of the 
Environment and MPI 2015). 
Marine Pest Alert 
If a ship has travelled within areas announcing a Marine Pest Alert, IWC in the Baltic Sea is not 
permitted. There are no specific marine pest alert programs actively in use in the BSR but currently 
under development for the BWMC and could possibly be extended for biofouling species. 
2 Risk of hazardous substances/biocide and particle input 
AFS and MGPS are used for ship hull and niche areas to decelerate the attachment and growth 
of biofouling on submerged areas. Despite the deceleration of the accumulation, biofouling starts 
to grow within the first hours after the ship’s immersion into the water and hence needs to be 
sleaned at some point. Ships and boats cannot be taken out of the water as often as they would 
need to be cleaned due to low capacities and high costs of dry docks in the BSR (Information from 
stakeholder meetings). Thus, the cleaning is proceeded in-water, which causes the risk of 
hazardous substances and particles from the hull coating entering the aquatic environment during 
and after IWC. Paint flakes and other particles might enter the water by blistering or delaminating 
or biocides could be released due to abrasion (Morrisey et al. 2013). Age and condition of 
coating therefore have a crucial impact on the environmental risk of IWC.