Cost]benefit analysis of the use of TBT: the case for a treatment approach

The current climate of hostility towards the use of tributyltin TBT. as an active ingredient in ship anti-fouling paint appears to be based on a very biased assessment of its environmental impact. While many national and international regulatory agencies are moving towards further restriction, and a complete ban is under active discussion, a number of factors appear to have been ignored. The economic impact of a ban on TBT when no adequate substitute exists could be substantial. Environmentally, consequences would include a substantial increase in the consumption of fossil fuel, with corresponding increases in carbon dioxide and sulphur dioxide emissions; the construction of more vessels; the transfer of ship-building, ship-repairing and ship-breaking activities from well-regulated to unregulated or under-regulated areas in the developing world; and a shift from sea transport to less environmentally acceptable forms of transport. Experience in Europe and other parts of the developed world shows that existing restrictions, where they are properly enforced, are probably adequate to alleviate the environmental damage associated with TBT. Some existing legislation acts to inhibit the search for effective substitutes. The environmental benefits of TBT have been ignored. Little thought has been given to a technical, rather than a legislative solution to controlling TBT inputs to the environment. A method is described for treating TBT-contaminated wastewaters, which has been successfully tested in prototype at full scale. Legislative measures against TBT will do nothing to address the problem of the existing backlog of contaminated material, nor even to permit the IMO proposal for the removal of TBT from all ships by 2008 to be successfully concluded in an environmentally safe manner, since no provision has been made for the disposal of the existing TBT; most probably it will be dumped in environmentally sensitive, unregulated areas in the developing world.