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IWC is considered unacceptable. In this case, it is recommended to haul the ship out of the water 
for cleaning or maintenance in dry-dock. 
Taking it out of the water is expensive and usually only happens every few years and not on a 
regular basis. Moreover, the dry-docks are limited in size which presents one more reason why 
more frequent cleaning on a regular basis in dry-docks in the BSR for the majority of vessels does 
not happen in practice. 
In the same time, cleaning macrofouling or specifically hard calcareous fouling contains a higher 
biosecurity risk and requires more aggressive cleaning methods which triggers a higher probability 
for abrasion and damage of AFS which presents a higher risk on hazardous substances and 
particle input. 
Consequently, it is highly advised to prevent this risk or keep it as low as possible. For this matter, 
regular inspections and a removal of slime at very frequent interval are highly recommended. 
5 Special attention to niche areas 
Niche areas are very much prone to biofouling because they are sheltered spaces, which are 
less/not exposed to hydrostatic forces. Therefore, situations where the hull has low biofouling level, 
but the niches are heavily fouled might occur regularly. To the best of our knowledge, until now, 
there are no effective biocide free coatings on the market to protect niche areas from biofouling 
and most niches are therefore protected with a MGPS. The exchange with various stakeholders 
has revealed that IWC in niche areas should be considered, given the accessibility of niches and 
the suitable cleaning equipment with capture and filtration, because heavily fouled niche areas 
have a very high potential of introducing and spreading invasive species and this risk can only be 
reduced by regular cleaning. 
6 Conclusion and Outlook 
The proposed risk assessment as basis for permission of IWC in the Baltic Sea requires a set of 
information from ships as well as from the manufacturers of the applied coatings (via the ship). 
Therefore, it is of upmost importance that ship-specific information is available. Most information 
will be covered by the BFMP and the BFRB. This information e.g. should include AFS and MGPS 
used, details on cleanability and ingredients of the AFS, cleaning recommendations, leaching rate 
under cleaning operation, accessibility of niches, inspection and cleaning history and reports. In 
addition, quality and performance of the cleaning company must be proved in the context of 
requirements of the respective AFS and MGPS. Not all equipment can be used for all AFS and in 
all circumstances. It is therefore not recommended to apply a “one fits all”, general permission for 
a cleaning company but do this ship-based, after consultation with a proved/certified cleaning 
company. 
With regard to the permission for cleaning of biocidal AFS, techniques for the capture and filtration 
of biocides must be further developed. In the meantime, as basis for the possibility to permit IWC