 
 
 
Risk Management Proposal  
 
Amendments to the Craft Risk Management 
Standard: Vessels   
CRMS.VESSELS  
 
 
 
 
29 June  2022  Risk Management Proposal:  Amendments to the Craft Risk Management Standard: Vessels  29 June 2022  
Ministry for Primary Industries   Page 1  
 
 
Disclaimer  
This risk management proposal does not constitute, and should not be regarded as, legal 
advice. While every effort has been made to ensure the information in this document is 
accurate, the Ministry for Primary Industries does not accept any responsibility or liability 
whatsoever for any error of fact, omission, interpretation or opinion that may be present, 
however it may have occurred.  
© Crown Copyright - Ministry for Primary Industries  
 
 
 
 
 
 
 
 
 
 
 
 
 
Contact for further information : 
Environmental Health Group   
Biosecurity New Zealand  
Ministry for Primary Industries (MPI)  
PO Box 2526  
Wellington 6140  
Email: standards@mpi.govt.nz  
Telephone:  0800 00 83 33  
  Risk Management Proposal:  Amendments to the Craft Risk Management Standard: Vessels  29 June 2022  
Ministry for Primary Industries   Page 2  
Contents  
Submissions  3 
1 General information  4 
1.1 Purpose  4 
1.2 Timing and consultation  4 
1.3 Background and context to consultation  4 
1.3.1  International regulation  4 
1.3.2  Domestic regulation of biosecurity risks associated with craft arrivals  4 
1.4 Summary of proposed changes  5 
2 Biosecurity risk associated with vessels  6 
2.1 Description of risks associated with vessel inspection reports  6 
2.2 Emerging risks  7 
3 Proposed changes to the standa rd 8 
3.1 Non-regulatory changes to the standard  8 
3.1.1  Changes to non -regulatory information  8 
3.1.2  Guidance documents and guidance boxes  8 
3.1.3  Revoking Biofouling  9 
3.1.4  Minor numbering and language changes  9 
3.2 Proposed changes to the requirements for vessels  11 
3.2.1  Section 1.1: Application  12 
3.2.2  Required information – 1.4(5)(d)  12 
3.2.3  Section 1.5(3) – “Acceptable measures for ensuring a vessel has a ‘clean hull’”  13 
3.2.4  Risk management 1.5(4)  14 
3.2.5  Specifications of short -stay and long -stay 14 
3.2.6  Addition of a requirement for cruise vessels  16 
3.2.7  Lymantria  complex (formerly referred to as Asian gypsy moth (AGM))  17 
3.2.8  Addition of ‘niche area’ definition  18 
3.2.9  Schedule 2 and 3: Minimum Reporting Requirements  18 
3.2.10  Schedule 4: Biofouling thresholds  19 
4 Feasibility of the proposed change to the standard  20 
5 References  21 
6 Appendix 1: Change to Schedule 3 (Risk Areas and Risk Periods)  22 
 
  
Ministry for Primary Industries   Page 3 Submissions  
The Ministry for Primary Industries (MPI) invites comment from interested parties on the 
amended craft risk management standard Vessels  (the standard ).  
A craft risk management standard (CRMS ) “specifies requirements to be met for the effective 
management of risks associated with arrival of craft” (section 22 E Biosecurity Act 1993).  
MPI would like comment on the following changes to the  standard : 
(1) Merging of current craft risk management standards Vessels  and Biofoul ing into a single 
standard by incorporating the biofouling requirements into the standard Vessels ;  
(2) Change in common name for Asian Gypsy Moth  (AGM ) and changes to risk areas and 
risk periods ; and  
(3) Changes to biofouling requirements .  
 
Please include the follo wing in your submission:  
• The title of the consultation document in the subject line of your email;  
• Your name and title (if applicable);  
• Your organisation’s name (if applicable); and  
• Your address.  
Send submissions to standards@mpi.govt.nz  by 29th August 2022 at 5pm.  
 
Feel free to include any technical information you have that supports your submission. While 
we prefer email, if you would like to send your submission by post, you can mail it to:  
 
Invasive Species  Team  
Animal and Plant Health Directorate  
Biosecurity New Zealand  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
Submissions received  by 29th August 2022  at 5pm will be considered during the development 
of the amended standard. Submissions received after the closing date may be held on file for 
consideration when the issued standard is next revised/reviewed.  
Official Information  Act 1982  
Please note that your submission is public information, and it is MPI policy to publish 
submissions and the review of submissions on the MPI website. Submissions may also be the 
subject of requests for information under the Official Information Act 1982 (OIA). The OIA 
specifies that infor mation is to be made available to requesters unless there are sufficient 
grounds for withholding it, as set out in the OIA. Submitters may wish to indicate grounds for 
withholding specific information contained in their submission, such as information bein g 
commercially sensitive or personal. Any decision to withhold information requested under the 
OIA is reviewable by the Ombudsman.    
Ministry for Primary Industries   Page 4 1 General information  
1.1 Purpose  
The purpose of this document is to:  
• Provide relevant background information on the changes to the craft risk management 
standard  Vessels  (the standard ); 
• Outline the proposed amendments to the requirements for the standard;  
• Provide the rationale for the changes to the proposed  standard  and explain how they 
manage risk; and  
• Ask for feedback on the proposed amendments.  
1.2 Timing and consultation  
The proposed amendments to Vessels  were released for consultation on 30th June 2022 and 
will remain open for consultation until 29th August 2022 at 5pm . 
1.3 Background and context to consultation  
1.3.1 International regulation  
“The World Trade Organization Agreement on the Application of Sanitary and Phytosanitary 
Measures (SPS  Agreement) sets in place rules that protect each country’s sovereign right to 
take the measures necessary to protect the life o r health of its people, animals, and plants, 
while at the same time facilitating trade. It embodies and promotes the use of science -based 
risk assessments to manage the risks associated with the international movement of goods. 
The SPS Agreement guides how  New Zealand sets standards and makes decisions related to 
biosecurity.” (MAF et al., 2009, p. 1)  
“In particular, [it is] important to maintain the standards of transparency and scientific rigour 
required by the SPS  Agreement and to make decisions as quick ly as possible. This will 
encourage other countries to comply with the rules of the SPS Agreement and also 
demonstrate that New Zealand’s strict controls are justified to countries that challenge them.” 
(MAF et al., 2009, p. 13)  
1.3.2 Domestic regulation of bios ecurity risks associated with craft arrivals  
The New Zealand biosecurity system is regulated through the Biosecurity Act 1993 (the Act). 
Section 24E describes a craft risk management standard and requires all craft entering New 
Zealand to be managed by one . MPI is the New Zealand government ministry responsible for 
maintaining biosecurity standards that effectively manage risks associated with importing risk 
goods and craft into New Zealand (Part 3, Biosecurity Act 1993). MPI is committed to the 
principles of transparency and evidence -based technical justification for all phytosanitary 
measures we impose on importing pathways, whether new or amended. MPI periodically 
reviews all craft risk management standards, related documents and other standards so that t he 
legal requirements are clear and so that information is consistently presented and as easy as 
possible to understand.    
Ministry for Primary Industries   Page 5 1.4 Summary of proposed changes  
This document shows all the proposed changes made to the current Vessels  standard.  
 
The requirements for vessels arriving to New Zealand are currently described in two separate 
craft risk management standards , Biofoul ing and Vessels . One of the  purpose s of this review is 
to vary the current Vessels  standard to include all biofouling requirements .  
 
Having the requirements in two separate documents has cause d confusion for vessel operators 
and owners when determining the steps they need to take when planning for a vessel to arrive 
in New Zealand. Merging all the requirements into  Vessels  should  remove confusion.  
 
MPI propose s using  the current standard Vessels  as the structural base for all  vessel  
requirements, with the biofouling requirements inserted throughout.  The process of moving 
and integrating the biofouling requirements into  the proposed  Vessels  standard has meant that 
the location and wording of some requirements ha ve changed .  
 
MPI h as also review ed all the requirements  in both standards  to ensure they will continue to 
remain fit for purpose —including after the pandemic . The review process involved continu al 
engagement with stakeholders in the form of surveys, webinars and workshops. Stakeholders 
were encouraged to discuss any issues they had with the current standard s and to make 
suggestions for the future. This provided MPI with the knowledge and insight needed to 
ensure the proposed standard  Vessels  is fit for purpose.  
 
As a result of this process, there are a  number of proposed changes. Some are very minor and 
include  structure and numbering changes or  extra clarifications to reduce confusion. Other 
proposed changes change the intent or function of current  requirements  or are new 
requirements .  
 
This document explain s all the amendments  in detail , including how and why the changes are 
proposed. This proposal has  two sections  – a structure section that explains changes that do 
not change the overall intent or outcome of the requirements  (section 3.1) , and a requirement 
change section for the propose d amendments to the current requirements  (section 3.2) . In each 
section, the document  lists and explains the changes in the same order in which they appear in 
the pr oposed Vessels  standard .  
 
Summary of notable proposed changes  
- Update to the ‘Application’ of the standard to combine versions from the two current 
standards ;  
- Changes to the information requirements relating to vessel biofouling inspections ; 
- Addition of schedules containing the minimum evidence requirements for vessel 
biofouling inspections ;  
- Clarification of ‘A cceptable measures  for meeting the biofouling requi rements ’; 
- An increase to the number of days a short -stay vessel can remain in New Zealand ; 
- Addition of a clause specifically for cruise vessels ; 
- Changes to Asian Gypsy Moth (AGM) common name, risk periods and risk areas ; and  
- Alteration to the biofouling thresholds .  
  
Ministry for Primary Industries   Page 6 2 Biosecurity risk associated with vessels  
The biosecurity risks associated with the arrival of a vessel to New Zealand are described in 
three separate documents; Risk Management Proposal: Craft Risk Management Standard for 
Vessels (June 2016)  and Science Underpinning the Thresholds Pro posed in the CRMS: 
Biofouling on Vessels Ar riving to New Zealand . The third document, “Asian gypsy mot h 
(AGM) specified risk periods in Japan, Russia, Republic of Korea, and China ”, describes the 
biosecurity risk associated with some species  of Lymantria moth s (AGM) and is produced by 
the North American Plant Protection Organi zation (NAPPO). New Zealand continues to 
harmonise our  management of  biosecurity risk  of Lymantria moths with our counterparts 
from NAPPO (Canada  and USA ), as well as requir ements from Chile and Argentina .  
 
2.1 Description of risks associated with vessel inspection reports  
One of the key elements to the  Biofouling  requirements is that vessels must have certain 
documentation available on request for assessment of compliance. Overall , the shipping 
industry continues to be highly compliant with this requirement.   
Vessel inspection reports are a crucial part of the req uired documentation. While other 
documents feed into risk assessment for targeting purposes, vessel inspection reports are what 
can confirm the state of a vessel’s hull.  
If biofouling is present , a vessel inspection report  helps  inform s MPI of the actual level of 
risk. This  allow s MPI to make accurate and proportional risk management decisions  that 
mana ge biosecurity risk while also enabling trade.  
The risks associated with vessel inspection reports relate to two key issues: quality of 
reporting, and frau dulent reporting.  
The primary issue with vessel inspection reports is the range in the quality of reporting. 
Reports often:  
• contain images of low quality ( due to  image qu ality or being  taken in unfavourable 
conditions) ;  
• are missing evidence of key areas or do not have enough evidence of key areas ; and   
• are formatted in an unclear and unverifiable manner.  
A second issue is that of fraudulent vessel inspection reports being presented to make a 
vessel ’s hull appear to be clean, when it is not. Occurre nces of this are infrequent, however, 
vessel  operator s displaying this behaviour have been found to have vessels that  present high 
biosecurity risk.   
Without clear and robust vessel inspection reports, MPI cannot be sure of the status of a 
vessel’s hull an d the actual level of risk it presents. Clearance processes are slowed down by 
the additional correspondence required when a low -quality report is submitted. Risk 
management decisions are difficult to make promptly and concisely when there is ambiguity 
in the report, or if the information is misleading.  
There are also negative impacts for industry caused by  these issues. The current variation in 
the quality of reporting from underwater vessel inspection providers leads to a lack of 
consistency and predicta bility. This has meant that some vessel operators only f ind out on  
Ministry for Primary Industries   Page 7 arrival in N ew Zealand territorial waters (NZTW)  that their vessel inspection report did not 
suffice. This results in delays in clearance and potentially additional costs associated with risk 
management measures, such as needing to obtain new or additional photographs of the hull.  
MPI considers that  low quality and fraudulent vessel inspection reports can result in 
unnecessary exposure of marine invasive species to New Zealand’s environment, and cause 
operational costs and delays for industry and MPI.  
MPI proposes the addition of minimum information re quirements for vessel biofouling 
inspection reports  to ensure that accurate assessments of the risk of the vessel can be made . 
MPI also considers that  provid ing consistent evidence for the assessment of the state of a 
vessel’s hull will deliver  more certai nty for industry that their evidence will be accepted by 
MPI. 
2.2 Emerging  risks  
MPI constantly monitors all commodities and pathways for new and emerging risks. MPI will 
change the requirements of any standard where required. If you become aware of any chang es 
to a pest’s host or geographic range, establishment, or any other new or unmanaged 
biosecurity risks on a pathway that may need us to review or amend an existing standard, 
please email EmergingRisks@mpi.g ovt.nz  with any available technical information .   
Ministry for Primary Industries   Page 8 3 Proposed changes to the standard  
3.1 Non-regulatory changes to the standard  
MPI has made some changes to format of the standard to align with MPI’s current formatting 
and to ensure that the legal requirements are clear, consistently presented, and as easy as 
possible to understand. Layout changes have also arisen due to content fr om the current 
Biofouling  standard being directly transferred into the proposed standard Vessels .  
These include:  
• Changes to the order of requirements within the  standard , which in turn changes the 
numbering of the requirements; and  
• Updates to the generic wording associated with the craft risk management standards.  
None of these changes alter the requirements in the standard or the intent of the requirements. 
They are minor changes in accordance with section 24H(2) of the Act and, as such, do not 
require co nsultation under section 24F(3) of the Act.  
The p urpose of this review is to amend  the current  standard  Vessels  to include all biofouling 
requirements. MPI has also altered e xisting requirements where necessary. As such, t his 
document is structured to show any changes made .  
As a result of the review, MPI has  made  various changes to the  current  structure of the 
Vessels  standard . This has changed the  numbering of parts, clauses  and subclauses . Some 
changes in w ording relate directly to the insertion of the  requirements  from  Biofoul ing. These 
changes can be found in Table 1 .  
The introduction  sections at the beginning of the standard have been amended to include all 
the biofouling background information. These  change s do not alter the intent or meaning of 
the requirements.   
3.1.1 Changes to non-regulatory information  
Why is this important?  
The section listing which sections of  the Act can be used to issue notice of directions has been 
removed . This is because  there are  many  more  sections of the Act that can be used to issue 
directions  than what is currently listed in the Vessels standard.  
Some content has also been directly transferred  from the current Biofouling  standard.  
3.1.2 Guidance documents and guidance boxes  
Currently both standards provide guidance in two ways. Firstly , with guidance boxes inserted 
throughout the standard and secondly  with a  separate guidance document.   
MPI is not  provid ing a separate guidance document for the p roposed standard Vessels . 
Instead , all important guidance  on vessels and biofouling appears in text boxes  throughout the 
standard .   
The information in th e guidance boxes  has no legal effect.   
Ministry for Primary Industries   Page 9 Any information from the current Biofouling Guidance Document  and Guidance Document to 
the CRMS for Vessels  that has not be en included in guidance boxes will be transferred to the 
“Arrival process steps ” and “Biofouling  management ”  page s of the MPI website .  
3.1.3 Revoking Biofouling  
With the proposed amendments to the  standard , the standard  Biofouling  is no longer required.  
Therefore, there is a section within the proposed revoking the Biofouling  standard . All 
biofouling requirements have been transferred into the proposed standard . No biofouling 
requirements have been removed.  
3.1.4 Minor numbering and language changes  
There are a number of alterations within the requirement sections of the proposed standard 
Vessels  that have come from the incorporation  process. These minor language and numbering 
changes that are not considered to impact the intent or meaning of the requirements. These 
can be found in Table 1.  
Table 1.  Minor language and numbering changes that are the result of transferring biofouling information 
into Vessels  and updates to guidance for clarity  
Change  Reason for Change  
Removal of references to the standard 
Biofouling  throughout  Integratin g biofouling information  into 
Vessels  because Biofouling  is being revoked.  
Change in numbering throughout Vessels  
standard  Changes in numbering due to the insertion of 
a biofouling section.  
Addition of wording to “Who should read 
this?” section  Integrating biofouling information into 
Vessels  
Change in wording of guidance box under 
“Other requirements of the Act”  The title s of some import health standards 
have changed.  
Addition and change to wording of 1.3(1) 
“Required Information” (proposed 1.4(1))  Addition to clause 1 to include reference to 
the requirements copied from Biofouling  
Change in wording under section 1.3 
“Required information” (proposed 1.4)  Current vocabulary has changed.  
Addition of wording to section 1.3 
“Required Information” (proposed 1.4)  Integration of biofouling information into 
proposed section 1.4 as 1.4(4) and 1.4(5).  
Removal of clause and change in wording 
under section 1.3 “Required Information” 
(proposed clause 1.4(4))  Removal of clause requiring information 
about intended length of stay and itinerary as 
it is covered above in 1.4(3 )(c) and 1.4(3 )(d). 
Minor language updates throughout to reflect 
the vocabulary currently used.  
Change in wording under section 1.3 
“Required information” (proposed clause 
1.4(5)(c)  Minor wording change  to clarify when 
antifouling certificates need to be supplied.  
Ministry for Primary Industries   Page 10 Some vessels (i.e. ice -breakers) do not operate 
under normal antifouling regimes.  
Change to guidance box below section 1.3 
“Required information” (proposed 1.4)  Change in names of required f orms to reflect 
those currently used.  
Addition of clause to S ection 1.4 “Risk 
management” (proposed 1.5(2))  Addition and rewording of biofouling 
requirement transferred from section 2.1 of 
Biofouling . This does not change the outcome 
of the requirement.  
Addition to guidance box under section 
1.4(1) (proposed 1.5(2))  Addition of guidance that reminds operators 
that the next part separates vessels into three 
categories and that the ‘clean hull’ thresholds 
depend on which category the vessel fits into.  
Addition of clause to section 1.4 “Risk 
management” (proposed 1.5(3))  Transfer of ‘Acceptable Measures for Meeting 
the Standard’ from Biofouling  (section 2.2). 
For more details on changes to this clause, see 
Table 2 in this document.  
Addition of guidance  box and wording to 
guidance box under section 1.4(1) 
(proposed 1.5(3))  Guidance box transferred from Biofouling.  
Section added to guidance box on clarification 
to MPI -STD-ABTRT.  
Addition to guidance box under 1.4(3) 
(proposed under 1.5(5))  Addition of description of examples of marine 
related pests and biosecurity contamination  
Addition of guidance box under 2.1 – 
“Short -stay vessels”  Two guidance points added:  
First point adde d to remind operators to notify 
MPI if they wish to extend a vessel’s stay past 
the short -stay limit.  
Second point  added as a reminder that all 
short -stay vessels must continue to manage 
any uncleared goods or risk goods 
appropriately.  
Change to clause 2 .2 – “Long -stay vessels 
and other vessels”  Clarification that long -stay clearance must be 
obtained from an inspection at a place of first 
arrival.  
Addition of clause to 2.2(2) – “Long -stay 
vessels and other vessels”  Integrating biofouling information int o 
Vessels  (Clause 2.2(2)(b)(iii) )  
Change to 3.1(4)(a) – “Additional 
Requirements for Specific Regulated 
Pests”  Clarification that a certificate of freedom 
should be obtained on the same calendar day 
as the vessel’s  departure  
Addition to Guidance under 3.1 – 
“Additional Requirements for Specific 
Regulated Pests”  Clarification that vessels may sometimes need 
to arrive at specific ports for inspection .   
Ministry for Primary Industries   Page 11 Change to definition for ‘Biosecurity 
Contaminant’  Addition of description of examples of marine 
related pests and biosecurity contamination  
Change to definition for ‘Goose barnacle’  Addition of physical description of the 
organism  
Addition of Schedule 3 The Biofouling Thresholds have been directly 
transferred from Biofouling  into proposed 
Vessels  as Schedule 3.  
 
3.2 Proposed changes to the requirements for vess els 
The structure of this section follows the order the requirements appear in the proposed 
standard Vessels .  
Table 2. Showing requirement changes and a short summary of these changes  
Change  Reason for Change  
Revised wording of 1.1 “Application ” The application in the proposed standard  is a 
combination of applications from both the 
current standards . Together they  create an 
improved application that is fit for purpose for 
the proposed standard . 
Revised wording of  proposed Clause  
1.5(3) “Acceptable measures for meeting 
the standard”    Changes to clarify the acceptable measures for 
ensuring a vessel has a ‘clean hull ’. These 
revisions will ensure the options are clear and 
will also specify the times when certain 
options are not operationally feasible.  
Addition to Clause 1.5(4) (previously 
Vessels  1.4(2))   Reminder that there should be no removal of 
biofouling from an  international vessel within 
NZTW.   
Change, rewording and addition to parts 
2.1 and 2.2 “ Short -stay a nd long -stay 
requirements ” 
 Extension in time allowed in NZTW for short -
stay vessels to ensure requirements remain fit 
for purpose.  
Addition of clause for cruise vessels 
(proposed 2.3)  New clause to cater for the unusual operating 
profile of cruise vessels to ensure they can 
meet the proposed standard . 
Change in  Part 3: Additional requirements 
for specific regulated pests   Asian Gyps y Moth ( AGM ) is now “species of 
the Lymantria complex”. There is also a 
proposed c hange in risk areas and risk periods 
to align with the n ew changes being adopted  
Ministry for Primary Industries   Page 12 internationally  due to new data o n flight areas 
and flight periods of the moth s.  
Addition of definition for ‘cruise vessel’  A clause specifically for cruise vessels has 
been added and a definition is required 
alongside this.  
Addition of definition for ‘ niche area’  Previously there was no niche area definition. 
Because it is a commonly referred to term , the 
definition in IMO Biofouling Guidelines  
(2011)  has been added  to the definitions list .  
Change in wording of “Schedule 2: 
Biofouling threshol ds” Change in wording of Schedule 2 to simplify 
the thresholds for vessels aiming to comply 
with the proposed Vessels .   
 
3.2.1 Section 1.1: Application  
The “Application ” section is found in both current versions of the craft risk management 
standards . The Application in the proposed Vessels  is a combination of both applications that 
creates an improved application that is fit for purpose for the proposed Vessels .   
The proposed standard Vessels  will apply to all vessels that enter New Zealand territor y after 
a voyage originating outside New Zealand’s territorial waters. It will not apply to vessels that 
are passing through  New  Zealand territory on innocent or transit passage as defined in the 
United Nations Convention on Law of the Sea.  
The proposed Vessels  standard  captures vessels that enter New Zealand territory after a 
voyage originating outside New Zealand’s territorial waters. To remove any further 
confusion,  alongside the application , a proposed definition for ‘voyage’ has been include d 
within Schedule 1 – Definitions.  This aims to explain which vessels are required to meet the 
standard and which are not.  
MPI proposes to alter when a vessel triggers the  biofouling requirements . It is proposed the 
trigger for biofouling moves  from  when  a vessel ‘anchors, berths or will be brought ashore’ , 
to align with the current Vessels  trigger , which is ‘ when a vessel ‘enter s New Zealand 
territory ’. The proposed alignment for when the requirements are triggered removes any 
ambiguity as it specifies the exact point all requirements for vessels come into effect . 
Operationally , there should be no noticeable  difference  from current practice.    
3.2.2 Required information – 1.4(5)(d)  
Requ ired information clauses 1.4(4) and 1. 4(5) have been transferred from Biofouling . In 
addition to the existing requirements, MPI proposes clause 1.4(5)(d) , which  requires vessel 
operators to obtain underwater inspection reports that meet the criteria and are obtained in 
accordance with Schedule 2  and 3  (these schedules are discussed in detail in section 3.2.9) .  
A key part of meeting the biofouling requirements of  the proposed Vessels  relies on vessel 
operators submitting recent evidence of the vessel ’s hull in the form of a vessel biofouling 
inspection report. This allows MPI to assess whether a vessel is compliant with the biofouling  
Ministry for Primary Industries   Page 13 thresholds and/or is followin g continual maintenance using the International Maritime 
Organisation  best practise guidelines  (IMO  2011 ). 
In the time since the Biofouling  requirements have been enforced, MPI has observed a broad 
range in the quality of vessel biofouling inspection reports. This inconsistency in reporting 
has been identified as a risk to New Zealand’s marine environment, and the shipping industry 
have indic ated that it can directly result in monetary loss.  
MPI proposes to manage the issue of inconsistent reporting quality through setting  minimum 
requirements for vessel biofouling inspection reports . MPI considers the review and merging 
of Biofouling and Vessels as the right time to introduce the proposed information 
requirements.  
MPI acknowledges that industry will require time to adapt to the proposed new minimum 
requirements for vessel biofouling inspection reports, and as such propose s a 12 month  lead in 
period  (after issuance)  for these specific requirements.  
3.2.3 Section 1.5(3)  – “Acceptable measures for ensuring a vessel has a ‘clean hull ’” 
The proposed standard aims to clarify the acceptable measures for ensuring a vessel has a 
‘clean hull ’. Members of the shipping industry regularly seek clarification to ensure they can 
comply  as some find the current wording confusing . The proposed reword ing is intended  to 
ensure the options are clear and specify the circumstances  when MPI considers certain 
options to be  operationally unfeasible.  
The explanatory paragraph at the beginning of the clause now includes a reminder that the 
operator or pe rson in charge of vessel must show compliance with the standard by using one 
of the below measures.  
The main change is that Option A  in Biofoul ing has been split into two separate options to 
provide clarity for vessel operators . In the proposed standard the two separated options are 
Option A “Inspect be fore arrival ” and Option B “Clean out of water on arrival ”. Some vessels 
may not need cleaning if they are already compliant with the long -stay thresholds of a slime 
layer and goo seneck barnacles only. Because of this , Option A has been split to  provide 
clarification that vessels that have been inspected  less than 30 days  before arriv ing in  New 
Zealand and can show evidence they meet the long -stay requirements do not have to clean 
their vessel before arrival. More emphasis is also given in Option B to ensure it is obvious 
that cleaning on arrival must be undertaken out of the water.  
The meas ure “Continual maintenance using best practice ” is now  Option C.  
“Application of approved treatments”  is now  Option D “Treat on arrival ”. The measure 
specifies where approved treatments  can be found. A note has been added to highlight that 
remov ing biofou ling in an approved haul -out facility is excluded from this option because  it is 
covered under Option B.  
An addition to the guidance box explain s that there are currently no MPI-approved treatments 
under MPI -STD-ABTRT but that Option D has been included in the standard for when  
treatments become available in the future .   
Ministry for Primary Industries   Page 14 3.2.4 Risk man agement 1.5(4)  
Clause  1.4(2) in the current Vessels  standard  is 1.5(4) in the proposed standard.  It details risk 
management steps that an operator or person in charge of vessel must ensure are taken when a 
vessel is in New Zealand territory . A subclause has been added as a reminder that biofouling 
cannot be removed from  an international  vessel with in NZTW.  
Guidance has been added to the guidance box to clarify that the risk goods managed under 
1.5(4)(a) includes any cargo, packaging and equipment used overboard (i.e.  fishing equipment 
or aquaculture equipment), but does not include safety equipment such as anchors.  
3.2.5 Specifications of short -stay and long -stay 
Since MPI introduced  biofouling requirements in 2018, our understanding of operational 
constraints and the logi stics chain  for vessel movements  has evolved , along with our  
understanding of the condition  of vessels ’ hulls on arrival. MPI gained its understanding  
through  managing the movement of vessels during the pandemic , continuous engagement 
with stakeholders and ongoing operational research . 
Shifts in global shipping patterns due to  the ongoing impacts of COVID -19, such as 
congestion and increased shipping volumes , have impacted the length of stay of vessels in 
ports worldwide, including in New Zealand.  
To complete scheduled itineraries and fulfil contracts,  vessels have needed to stay longer  in 
NZTW  than in previous years. This has increased the overall itinerary of many visiting 
vessels. Some increases are in length of port visits;  however , most increases are due to 
increased time waiting for berth s, which results in vessels idling at anchor outside  ports but 
within NZTW.  
This was particularly apparent during a large -scale congestion event in New Zealand in mid -
2021 . As MPI  worked closely with vessel operators to maintain the movement of vessels , it 
became evident  that the definition of a short -stay vessel  would need to be revaluated  as the 
industry predicted no  improvement in logistic constraints . Throughout the process, MPI 
considered operational constraints and changes in the logistics chain (e.g. due to congestion 
and C OVID -19) as well as the data collected since the standard s were implemented. This is to 
ensure that requirements remain fit for purpose, feasible and continue to sufficiently manage 
biosecurity risk while still enabling trade. This information has contributed to our assessment 
of the vessel categories. The following explains the proposed amendments to the definitions 
for short - and long-stay vessels.    
MPI propose s amending  the short - and long -stay vessel categories  (as in the current standard 
Vessels ) to include the requirement from Biofouling that requires vessels to arrive in New 
Zealand with a clean hull as per the relevant section of “Biofouling thresholds ” in proposed 
Schedule 2. MPI also proposes extend ing the length of stay for short -stay vessels from 20 to 
25 consecutive days.   
MPI acknowledge s that the technical paper The Science  Underpinning the Thresholds  states  
“the longer a vessel remains in New  Zealand the greater the risk ”. However, this paper  also 
notes that a vessel that meets the short -stay thresholds should be able to remain in New 
Zealand for four weeks (less travelling time to New  Zealand) without posing a significant 
biosecurity risk  (Ministry for Primary Industries, 2014 ).   
Ministry for Primary Industries   Page 15 With the cha nges in global vessel movements, 20 consecutive days has become less feasible  
and is no longer considered fit for purpose . MPI considers t he science provide s sufficient 
evidence to enable a small extension in the number of days a short -stay vessel can remain in 
NZTW  before an unacceptable  increase in biosecurity risk  occurs . The measures that remain 
in place (detailed below) ensure that propagule pressure1 remains low .   
Taking into account  vessel movements in the past 12 months, MPI pro poses an extension of 
five days for short -stay vessels . This will enable vessels struggling to complete their 
commercially itineraries within 20 days to remain short stay  and continue to manage the 
biosecurity risk to the intended level . This will enable  approximately 100 additional  vessels 
per year to remain  short -stay and complete their commercial itineraries  (reducing costs and 
delays)  while still managing biosecurity risk.  
In addition, t he curren t 20 days includes allowance of a buffer for travel time. Due to the wide 
variety in travel times to New Zealand (from one to two  days to over a month), reducing the 
buffer time is unlikely to  significant ly increase the biosecurity risk to New Zealand.  
The clean hull requirements  sufficiently  mitigate the risk of organisms reproducing while the 
vessel is in NZTW , but as there is no accurate way of determining the age of any biofouling 
on a vessel  when they enter our waters , there remains a residual risk that some  organisms will 
reproduce in  our waters.  
The proposed extension  does not change the organisms  permitted under the short -stay 
thresholds or the ir overall abundance  of these organisms , so the threshold  remains the same. 
When kept to a low threshold, t he early -stage macrofouling species permitted under the short -
stay thresholds are  not likely to become highly damaging invasive species. They are globally 
common and likely vessel hitchhikers. Restrictions on the abundance and density of foulin g 
allowed ensures that propagule pressure remains low , as they  are less likely to breed in 
scattered and low -density aggregations.   
Species other than  those listed in the short -stay thresholds are not allowed in any number  
because  they are high risk and have the potential to cause biological and economic  damage to 
New Zealand ’s marine environment. MPI does not propose changing  the long-stay organism  
thresholds , and they  will remain at a “slime layer” level of fouling with allowance for goose 
barnacles.  The evidence needed to show compliance with long stay thresholds remains 
unchange d. 
In 2014 , MPI acknowledged the unknown impacts the standard  may have on industry and 
trade and MPI’s ability to enforce  them . With this in mind, MPI gave a  four-year lead -in 
period  before enforcing requirements , enabling industry to understand the requirements and 
begin to incorporate biofouling management into the vessel management. Since the standard 
was implemented, MPI ha s gradually been  moving vessels onto an audit schedule based on  
level of risk . This ensured that vessel movement continued and MPI managed fouled vessels 
appropriately . Currently , all vessels coming to New Zealand are audited regularly and are 
better aware of effective risk management practices.  
As such, MPI considers that extending the short stay thresholds will continue to manage the 
risk of biofouling on vessels with short stays in our waters to the same level intended by the 
 
1 Propagule Pressure: a measure of the number of individuals of a species released into a region to which they are not native .   
Ministry for Primary Industries   Page 16 Biofouling  standard and be more feasible for the global shipping movements and trade 
enabling . 
MPI has made m inor language amendments t o this section t o avoid  repetition and provide 
clarity. The text originally in clause 2.1(2) has now been moved to 2.1(1).  
MPI has also added a  guidance box under  section 2.1 “Short-stay vessels”. This guidance 
advises  an operator or person in charge of a vessel to notify MPI as soon as possible when a 
vessel w ishes to extend its stay past 2 5 days or visit places that are not places of first arrival. 
This reiterates that MPI must be notified in situations such as these.  
3.2.6 Addition of a requirement for cruise vessels  
When MPI reviewed all cruise vessel data, it bec ame apparent that neither the short -stay or 
long-stay requirements are fit for purpose for their unusual  operating profile . The operating 
profiles of a ll other vessel  types  fall within the existing short - and long -stay categories.   
Cruise vessels carry large numbers of passengers, high volumes of food and have other 
onboard structures such as gardens and golf courses , and none of these can be given 
biosecurity clearance . They  also often remain  in New  Zealand  longer than 20 days and visit 
areas that are not approved as places of first arrival , i.e. scenic areas such as the Bay of 
Islands and Fiordland. As a result, c ruise vessel s usually cannot meet either existing  
requirement . 
MPI proposes  new requirem ents specifically for cruise vessels  that will address this gap in the 
requirements.  The proposed requirements give cruise vessel operators two options  for 
managing the risks associated with their vessels . The first is to meet the current long -stay 
requirements . The second option is to operate under an MPI -approved system .  
While s ome cruise operators may be able to comply under option  1 (particularly th e smaller 
vessels  with less complicated schedules in New Zealand ), MPI anticipates that  most 
operators,  (particularly the larger companies ) will find it more feasible to operate under an  
MPI-approved system  (option 2) .  
MPI approved  system s will detail approved ways in which the operator s will manage the 
biosecurity risk of the ir vessel  or fleet of vessels and will encompass all existing approvals 
operators obtain from MPI, such as the Recognised Cruise Line Programme (formerly the 
Cruise Accredit ation Scheme) and Craft Risk Management Plans for Biofouling . Details of 
this system are dependent on the operator and cruises they will operate  in New Zealand  but 
will replace all existing approvals for management of biosecurity risk . With this proposed 
MPI Approved System, MPI will be streamlining the approvals needed as  cruise operators 
will only need to submit one document for approval to MPI to cover all biosecurity 
management processes.  
MPI has also  defined  ‘cruise vessel’ . The proposed definition has been written to accurately 
include the vessels that should be covered by this new requirement and exclude those that 
should not be covered .   
Ministry for Primary Industries   Page 17 3.2.7 Lymantria  com plex (formerly referred to as Asian gypsy moth (AGM) )  
Common name  
Curre ntly there is an international move , led by the Entomological Society of America,  to 
change the common names of species to reflect the visual appearance of the insect  rather than 
names that reflect regions, groups of people or individual people  (Osborne, 2022) . The 
Lymantria  species that have historically been managed by the standard Vessels  were 
previously referred to as  Asian gypsy moth (AGM).  This grouping of specie s will now  be 
commonly referred to as  the ‘flighted spongy moth complex’ .   
Alongside this change , MPI will only refer  to this species’ scientific name rather than its 
common name  within its standards and requirements . This will ensure that the requirements 
are clear and will not need future amendments if the common name change s again .  
The proposed change align s with other regulators, scientists and industry members who are  
also phasing out the current common name.  
It is proposed the scientific name is used  inside formal requirements as ‘species of the 
Lymantria  complex’ and that the common name ; ‘flighted spongy moth complex’ will be 
used in industry communication and public engagement.  MPI acknowledges that this is a 
significant change in language for industry. MPI will be working with other countries that 
regulate these species and all industry groups affected by this name change  to ensure this 
change is communicated effectively , and there will be a transition period as the old name is 
phased out.  
Risk periods and areas  
The proposed standard  also includes revised risk areas and risk periods that align with the 
changes  the North American Plant Protection Organi zation ( NAPPO ) recently made for the 
2022 Lymantria  comp lex season. NAPPO consulted on these changes  between May and July 
2021 and they came into effect for the 2022 flight season.  The new NAPPO  requirements  
combined  Western Japan and Eastern Japan into one risk area called Central Japan , because 
there is little environmental difference between the two  areas . The behaviour of Lymantria  
complex moths has changed, and the moths are flying earlier than in the past. This lead to 
NAPPO to changing  the risk periods for these moths  as follows  (NAPPO (2021)) : 
• Russian and Northern Japan risk period is now  15 June – 15 October ; 
• Southern Japan period is now  15 May – 31 August ; and  
• the Central Japan risk period is 1 June – 30 September.  
 The details for the NAPPO new risk areas and periods for Lymantria  species  can be found in 
Appendix 1 . 
To harmonise our requirements  for species of the Lymantria  complex with international 
requirements , MPI propos es adopt ing the NAPPO’s changes. This will reduce the impact on 
the movement o f vessels and international trade.  
The change in risk periods and risk areas for species of the Lymantria  complex will  alter the 
time period s that operators are obligated to  obtain  an inspection and certificate . Some  
Ministry for Primary Industries   Page 18 operators that previously didn’t require one will now require them . Many industry 
stakeholders have already adapted to the new risk periods and regions as other  countries  have  
already  implemented these regulatory changes . MPI does  not expect this  change to 
significantly impact industry . There will also be  a lead-in period  before the implementation of 
the new risk periods and r isk areas , and MPI will regularly engage with industry to ensure 
awareness  of the changes.   
3.2.8 Addition of ‘ niche area’ definition  
At the request of shipping industry stakeholders, MPI proposes the  addition of a definition for 
‘niche area’ . Niche areas are commonly referred to in the biofouling requirements and i t is 
important to have  a clear and  robust definition to ensure that operators have certainty about 
which areas of their vessels are considered niche areas for biosecurity management .  
3.2.9 Schedule s 2 and 3: Minimum Reporting Requirements  
Part 1.4(5)(d) of the proposed Vessels  (see section 3.2.2) references Schedule 2  and 3 . The 
proposed new schedule s outline the criteria and process es for  vessel biofouling inspections . 
A minimum requirement that all underwater inspection reports must follow will create 
consistency and reduce the biosecurity risk, operational delays and poor evidence being 
presented to MPI. It aims to foster better vessel management for the shipping indus try 
themselves as they will be better informed of a vessel’s biosecurity risk.  
Proposed Schedules 2 and 3  outline minimum information that must be provided in a vessel  
biofouling  inspection report for it to comply with the  proposed Vessels  evidence requirement. 
This will ensure that providers will have a clear standard of reporting to meet and will aid in 
improving their reporting . MPI considers that this will  reduc e low-quality reporting that 
currently hinders MPI’s compliance and risk ass essment abilities and causes delays for 
industry.   
MPI recognises that while the requirements of the proposed Vessels apply to vessel operators 
or persons in charge of a vessel, third -party service providers will need to access,  understand , 
and deliver re ports that meet the requirements. To make them more accessible, MPI has also 
proposed a Guidance Document: Vessel Biofouling Inspections . This contains proposed 
Schedule s 2 and 3 as well as additional  resources and supplementary information. This 
document can be found on the public consultation page. The intent of this is to make the 
applicable requirements more readily accessible for  providers.   
Alongside these changes, MPI also proposes an approval scheme for vessel biofouling 
inspection providers to voluntarily become MPI -approved. This will also provide vessel 
operators a list of providers they can use with the confidence that they will provide  
underwater inspection reports which align with the required information of the proposed 
Vessels .  
For further information on the approval scheme and the opportunity to provide feedback, see 
the proposed Operational Code: Vessel biofouling inspection provi der approval scheme. This 
document is out for public consultation at the same time as the proposed Vessels . 
MPI would like to receive feedback on whether the guidance is in a  usable form and format;  if 
not, then we welcome feedback on what  form and format would work better for industry .   
Ministry for Primary Industries   Page 19 3.2.10   Schedule 4: Biofouling thresholds  
Stakeholders  have often described the short -stay biofouling thresholds in the current standard 
Biofouling  as overly complicated and operationally unfeasible . At times, they are also difficult 
for MPI to enforce . MPI proposes simplify ing the thresholds to provide stakeholders with a 
clear er and more feasible  target to aim for while stil l managing biosecurity risk to the same 
level . The types of species permitt ed under the short -stay thresholds will not change, however 
we propose to slightly alter the  composition of how these can appear  on the vessel to provide 
clarity.   
The requirement s within the thresholds that the shipping industry found most confusing were  
the restrictions on the number of species permitted on hulls of short -stay vessels . Currently on 
the flat sides and flat bottom of a hull, biofouling  is limited to 1% coverage of only one 
species. A similar requirement exists for niche areas where 5% coverage of one species and 
1% coverage of a second species  is permitted . 
As an example, under the current Biofouling  standard , a vessel with a singl e barnacle and a 
singl e tubeworm on the flat side of a hull would not meet the short -stay thresholds , even 
though the overall risk of these two specimens can be considered  lower than  the risk of  a full  
1% coverage of a single species .   
MPI considers that v essels with very low quantities of biofouling of one or more types 
maintain low er propagule pressures  than vessel s that have higher  quantit ies of single species 
biofouling . The species allowed (barnacles, tubeworms and bryozoans ) are early -stage  
colonisers, and all tend to appear on vessel hulls around the same tim e. This contributes to the 
infeasibility of this threshold. As mentioned in section 3.2.5 above, the se species are 
permitted  on short -stay vessels due to their low likelihood of causing significant damage to 
New Zealand’s marine environment.  
As noted, MPI considers that changing the number of species that can  contribute to the total  
allowed  coverage for  a short -stay vessel  is unlikely to  significantly  increase the risk of new 
species establishment in New  Zealand . MPI proposes no change to the types of species within 
the short -stay threshold.  MPI also considers this proposed change to the threshold to be 
operationally more realistic for v essel operators  than the current requirements.    
 
 
 
 
 
 
 
  
Ministry for Primary Industries   Page 20 4 Feasibility of the proposed change to the standard  
The proposed standard does not fundamentally change the existing risk  setting s in place for 
international vessels arriving to New Zealand.  
With the proposed amendments to the existing requirements, MPI aims to streamline the 
process vessel operators must follow when bringing a vessel to New Zealand by formalising 
existing procedure s and making changes to ensure Vessels  remains fit for purpose and 
operationally feasible  while maintaining the same risk settings . Most vessel operators should 
find that the proposed standard Vessels  will simplify processes  and provide more flexibility.    
Ministry for Primary Industries   Page 21 5 References  
IMO (2011)  Guidelines for the Control and Management of Ships’ Biofouling to Minimize the 
Transfer of Invasive Aquatic Species.  International Maritime Organization. 
https://wwwcdn.imo.org/localresources/en/OurWork/Environment/Documents/RESOLUTIO
N%20MEPC.207%5b62%5d.pdf   
MAF; MFAT; FSA (2009) Balance in Trade.  Ministry of Agriculture and Forestry, Ministry 
of Foreign Affairs and Trade, New Zealand, Food Safety Authority; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/12576 -balance -in-trade  
MPI (2014) Science Underpinning the Thresholds Proposed in the CRMS: Biofouling on 
Vessels Arriving to New Zealand . Ministry fo r Primary Industries ; Wellington, NZ.  
https://www.mpi.govt.nz/dmsdocument/4148 -Science -underpinning -the-thresholds -proposed -
in-the-CRMS -Biofouling -on-vessels -arriving -to-New -Zealand   
MPI (2016) Risk Management Proposa l: Craft Risk Management Standard for Vessels . 
Ministry fo r Primary Industries ; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/12465 -risk-management -proposal -craft-risk-
management -standard -for-vessels   
MPI (2018) Craft Risk  Management Standard for Vessels . Ministry for Primary Industries; 
Wellington, NZ   
https://www.mpi.govt.nz/dmsdocument/19757 -Vessels -Craft -risk-management -standard   
MPI (2018) Craft Risk Management Standard for Biofouling on Vessels Arriving to New 
Zealand . Ministry fo r Primary Industries ; Wellington, NZ. 
https://www.mpi.govt.nz/dmsdocument/11668 -Biofouling -on-Vessels -Arriving -to-New-
Zealand -Craft -Risk-Management -Standard   
NAPPO (2021) Asian gypsy moth (AGM) specified risk periods in Japan, Russia, Republic of 
Korea, and China . North American Plant Protection Organisation; North Carolina, United 
States of America. 
https://nappo.org/applicat ion/files/3816/2068/9673/20210506_AGM_Position_document_For
_Country_Consultation -final-e.pdf   
Osborne M. (2022). Invasive Insect Gets a New Name: Spongy Moth . Margaret Osborne; 
Smithsonian Magazine. Accessed 21 June 2022.  
https://www.smithsonianmag.com/smart -news/invasive -moth -gets-a-new-name -spongy -moth -
180979680/    
Ministry for Primary Industries   Page 22 6 Appendix 1 : Change to Schedule 3 (Risk Areas and Risk 
Periods)  
 
 
 
 
 
 
 
 
 
 
