Underwater Cleaning in Indonesian Waters: Navigating Regulations and Best Practices

Underwater cleaning in Indonesian waters is governed by a structured regulatory framework that reflects both operational efficiency considerations and environmental protection priorities. While hull maintenance remains essential for preserving hydrodynamic performance and fuel efficiency, the activity is subject to oversight due to its potential impact on marine ecosystems. Biofouling removal, antifouling coating integrity, and waste management must therefore be approached with procedural discipline and regulatory alignment. For vessels operating within Indonesian jurisdiction, underwater cleaning requires careful planning supported by legal compliance and technical competence.

The Regulatory Rationale Behind Hull Cleaning Controls

Hull fouling directly influences vessel performance. Accumulated marine growth increases surface resistance, which may elevate fuel consumption and associated emissions. However, uncontrolled cleaning activities can release invasive aquatic species and coating residues into surrounding waters. These risks have led to the development of international guidance aimed at balancing operational efficiency with environmental protection.

The International Maritime Organization introduced biofouling management guidelines to minimise the transfer of invasive species through hull maintenance practices. Although initially advisory in nature, these guidelines have shaped national regulatory approaches and encouraged structured inspection and maintenance regimes.

The International Convention on the Control of Harmful Anti-Fouling Systems further prohibits the use of toxic antifouling substances, including tributyltin. This prohibition has influenced coating technology and cleaning methodologies across the maritime sector. In addition, MARPOL Annex V regulates ship generated waste, which includes residues associated with hull cleaning activities. Together, these instruments form the broader international framework within which underwater cleaning in Indonesian waters must be considered.

Indonesian Legal Framework for Underwater Works

Under Indonesian shipping legislation, underwater works encompass activities involving inspection, maintenance, repair, or construction conducted beneath the water surface. Hull cleaning falls within this category and is therefore subject to specific licensing and permit requirements.

Business entities performing underwater cleaning must obtain appropriate authorisation, including a Business Identification Number and a standard certificate reflecting compliance with technical and administrative requirements. Regulations classify underwater activities as medium to high risk operations, necessitating qualified personnel, certified divers, specialised equipment, and suitable support vessels.

Each underwater cleaning activity also requires a project specific permit issued by the Ministry of Transportation. Applications must include contractual documentation, vessel details, work methods, geographic coordinates of the activity area, and confirmation of compliance with safety standards. Activities are subject to reporting obligations to the Harbour Master and must adhere strictly to the approved scope of work. Non compliance may result in administrative sanctions ranging from formal warnings to suspension or revocation of licensing.

Environmental Oversight and Port Specific Considerations

Indonesia’s maritime environment includes sensitive coastal ecosystems, high traffic commercial ports, and offshore industrial zones. Environmental oversight is therefore central to underwater cleaning operations. Port authorities may impose additional conditions depending on local ecological considerations and traffic density.

Open water cleaning without effective control measures may be restricted or subject to heightened scrutiny. In certain cases, authorities may encourage cleaning within dry dock facilities to prevent the release of residues into port waters. Consequently, vessel operators must evaluate port specific regulations prior to scheduling underwater maintenance.

Technical and Operational Best Practices

Compliance in underwater cleaning is supported by disciplined preparation and controlled execution. Pre arrival assessment of antifouling coating condition, maintenance history, and intended cleaning methodology allows alignment with regulatory expectations.

Use of approved equipment and certified personnel is essential. Controlled cleaning systems designed to minimise coating damage and manage debris release contribute to environmental compliance. Proper documentation of work scope, method statements, and post activity reporting further reinforces regulatory alignment.

Engagement with port authorities prior to commencement ensures transparency and allows clarification of any procedural requirements. Clear communication of activity timelines and operational zones supports orderly execution and reduces the potential for interruption.

Strategic Maintenance Planning and Long Term Compliance

Underwater cleaning should be integrated into broader maintenance strategy rather than treated as an isolated intervention. Coordination between antifouling coating selection, inspection intervals, and regulatory conditions allows operators to maintain efficiency while reducing environmental exposure.

Although regulatory compliance may introduce additional administrative preparation, it also promotes structured maintenance planning and environmental stewardship. Investment in advanced antifouling systems and responsible cleaning methodologies supports long term operational stability.

Aligning Operational Efficiency with Environmental Responsibility

Underwater cleaning in Indonesian waters is not solely a technical undertaking. It represents a regulated maritime activity requiring alignment between operational objectives and environmental safeguards. Licensing discipline, project permitting, and adherence to approved methods are fundamental components of compliance.

When conducted within the established legal framework, underwater cleaning supports vessel efficiency while maintaining ecological protection. For vessels trading within Indonesian jurisdiction, regulatory awareness and procedural precision remain central to responsible and effective hull maintenance.

References:

• metodius, g. (2025, March 14). Regulasi Internasional tentang Hull Cleaning dan Dampaknya bagi Industri Maritim. Retrieved from SCM: https://scm-underwaterwork.com/regulasi-internasional-tentang-hull-cleaning-dan-dampaknya-bagi-industri-maritim/
• Noor, A. D. (n.d.). Legal Framework for Underwater Works in Indonesia. Retrieved from JASL Law Firm: https://www.riverhopelawfirm.com/news/detail/legal-framework-for-underwater-works-in-indonesia#:~:text=According%20to%20Ministry%20of%20Transportation,marked%20with%20geographic%20coordinates;%20and