Marine Pollutants: Hazardous Or Not?

Marine pollutants are hazardous materials that pose a risk to aquatic ecosystems, including marine mammals, fish, crustaceans, and algae. The transportation of these materials is strictly regulated by the Department of Transportation (DOT) and the International Maritime Organization (IMO), which have specific guidelines for identifying and classifying marine pollutants. These regulations ensure that shippers correctly identify and label marine pollutants to comply with the relevant dangerous goods regulations. The criteria for classifying a substance as a marine pollutant vary depending on the mode of transport, with different rules for ground, air, and sea shipments. The proper shipping name and hazard class of the material are crucial for accurate identification and compliance with the applicable regulations.

Marine Pollutants vs Environmentally Hazardous Substances

Marine Pollutants (MPs) are materials listed in the IMDG Code Index or those that meet the criteria for classification as "Environmentally Hazardous Substance (aquatic environment)". The IMDG Code refers to the International Maritime Dangerous Goods Code, which is a set of guidelines for the safe transportation of dangerous goods by sea. MPs are substances that can pose a risk to aquatic ecosystems. They include a variety of chemicals and compounds, such as acetaldehyde, alkylphenols, benzaldehyde, bromobenzene, and more. The classification of MPs is important for the proper transportation and handling of these substances to prevent spills and accidents.

Environmentally Hazardous Substances (EHSs) are materials that are identified as posing a risk to the aquatic environment. The classification of EHSs is based on aquatic toxicity data, degradation data, and BCF (Bioconcentration Factor) data. These data help determine the potential impact of a substance on aquatic life and ecosystems. EHSs can include a range of chemicals, materials, and mixtures that can have harmful effects on the environment.

The main difference between MPs and EHSs lies in their classification criteria and the regulatory frameworks that apply to them. MPs are specifically identified in the IMDG Code, while EHSs are classified according to criteria such as aquatic toxicity and degradation data. MPs are often subject to additional regulations and requirements during transportation, such as specific labelling and packaging guidelines. For example, if a substance meets the criteria for both MP and another hazard class, it shall be declared under the most appropriate UN number and proper shipping name relevant for that hazard.

In terms of transportation, there are some exemptions for certain types of packaging. For instance, if a package contains a marine pollutant in quantities of less than five litres or five kilograms, it is not regulated. On the other hand, if a substance is classified as an EHS, transport units and freight containers are typically required to be marked with the "fish and tree" symbol to indicate their hazardous nature. This marking is recognised by organisations such as IATA (International Air Transport Association), even though it is not mandatory for them.

In summary, while all marine pollutants may not be hazardous materials in general, when transported in commerce within the US, they are regulated as hazardous materials by the USDOT. The classification of MPs and EHSs is crucial for ensuring the safe handling and transportation of these substances to protect the environment, particularly aquatic ecosystems. Proper labelling, packaging, and compliance with regulations are essential to prevent accidents and minimise risks associated with these hazardous materials.

Marine Pollutant identification

Marine Pollutant (MP) identification is a critical aspect of environmental protection and safe transportation of hazardous materials. Here is a guide to understanding and identifying marine pollutants:

Definition and Criteria:

A material is identified as a Marine Pollutant (MP) if it meets specific criteria. According to the IMDG Code Index, a substance is considered an MP if it is listed in the index and/or meets the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)." This classification is based on aquatic toxicity data, degradation data, and BCF (Bioconcentration Factor) data.

Identification and Classification:

Identifying marine pollutants involves understanding their classification and associated regulations. Here are some key points:

• Severe Marine Pollutants (SMP): These are identified in the first column of the IMDG Code's appendix, denoted by the letters "PP." They represent the most harmful substances.
• Marine Pollutant Marking: When transporting marine pollutants, specific markings are required. The "Marine Pollutant" mark must be placed on the packaging, transport vehicles, and freight containers. This ensures compliance with hazardous materials regulations.
• Concentration Levels: For a solution or mixture to be considered a marine pollutant, it must have a concentration of ≥10% for listed materials or ≥1% if it is a severe marine pollutant.
• Shipping and Packaging Requirements: When shipping marine pollutants, the proper shipping name and technical name of the pollutant must be used. The term "Marine Pollutant" should be included in dangerous goods descriptions. Specific packaging requirements, such as marking and labelling, vary based on the quantity and type of packaging.

Examples of Marine Pollutants:

According to the List of Marine Pollutants in the eCFR, here are some examples of substances classified as marine pollutants:

• Acetaldehyde
• Alkylphenols (liquid and solid)
• Azinphos-methyl
• Benzaldehyde
• Bromobenzene
• Butanedione
• Butyl mercaptans
• Camphor oil
• Cyanides, inorganic
• Dimethyl disulphide
• Iron sponge, spent
• PAINT (triethylbenzene)

Regulations and Training:

The safe transportation of marine pollutants is regulated by organizations such as PHMSA (Pipeline and Hazardous Materials Safety Administration) and USDOT (United States Department of Transportation). These organizations have guidelines and training programs to ensure compliance with hazardous materials regulations during transportation.

In summary, identifying marine pollutants involves understanding their definition, criteria, and classification. Proper marking, labelling, and shipping procedures are essential to comply with hazardous materials regulations and minimize environmental impact.

Marine Pollutant labelling and marking

Marine pollutants are hazardous materials that pose a risk to aquatic ecosystems. These materials are regulated by the USDOT when transported in commerce within the US. The term "marine pollutant" is mainly used by the IMDG Code, while other dangerous goods regulations, such as ADR and IATA, use the term "environmentally hazardous substances".

To identify a marine pollutant, one can refer to the IMDG Code Index or the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)". Aquatic toxicity data, degradation data, and BCF data are required to determine if a material falls into this category. Additionally, the material should be listed in Appendix B of the Hazardous Materials Table and meet certain concentration criteria for solutions or mixtures.

The labelling and marking of marine pollutants are crucial for safe transportation and compliance with regulations. Here are the key guidelines for labelling and marking:

• The proper shipping name used to describe a hazardous material that is a marine pollutant should include the component that makes it a marine pollutant. This component must be marked in parentheses in association with the shipping name unless the shipping name already identifies the component.
• When two or more components contribute to the marine pollutant designation, the names of at least two of the most predominant components must be included in parentheses alongside the shipping name.
• For materials described as "UN3077, Environmentally hazardous substance, solid, n.o.s." or "UN3082, Environmentally hazardous substance, liquid, n.o.s.", refer to special provisions for additional instructions.
• The "Marine Pollutant" mark is required on the packaging. For packaging with a capacity of less than 1,000 gallons, the mark must appear on at least two opposing sides. For packaging with a capacity of 1,000 gallons or more, the mark must be displayed on each end and each side.
• The "Marine Pollutant" mark consists of a symbol (fish and tree) in black on a white or suitable contrasting background. The marking must be in the form of a square-on-point, with each side measuring at least 3.9 inches.
• The "Marine Pollutant" mark must also be displayed on transport vehicles or freight containers carrying packages that are subject to the marking requirements.
• IATA requires the "fish and tree" mark for UN-numbers UN3077 and UN3082, but the marine pollutant mark is accepted for air transport.
• If a material does not meet the classification criteria for any other hazard class, refer to the marking examples provided for guidance.

Marine Pollutant transportation

Marine Pollutants (MPs) are substances, materials, or articles that can cause harm to the aquatic environment. The transportation of these hazardous materials is strictly regulated to prevent accidental releases and mitigate potential environmental impacts.

Identification of Marine Pollutants

A material is identified as an MP if it is listed in the IMDG Code Index or meets the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)." Aquatic toxicity data, degradation data, and BCF data are used to determine if a substance belongs to this category. The IMDG Code also provides guidelines for identifying harmful substances in packaged form.

Transportation Regulations

The transportation of MPs is subject to various regulations, which can differ depending on the mode of transport and the jurisdiction. In the United States, the Department of Transportation (DOT) has specific rules for highway and rail shipments, while air and vessel shipments are governed by the International Air Transport Association's Dangerous Goods Regulations (IATA DGR) and the International Maritime Dangerous Goods Code (IMDG Code), respectively.

Marking and Labelling

Proper marking and labelling of MPs during transportation are crucial. For bulk packaging by motor vehicle, rail car, or aircraft, the presence of an MP must be communicated on shipping papers and packaging. The "MARINE POLLUTANT" mark must appear on at least two opposing sides if the packaging capacity is less than 1,000 gallons and on all four sides if it exceeds 1,000 gallons. The mark consists of a black "fish and tree" symbol on a white or suitable contrasting background, forming a square-on-point configuration.

Packaging Requirements

The regulations specify packaging requirements for MPs. For example, a single package or combination packaging containing liquids of 5 litres or less or solids of 5 kg or less is exempt from marking requirements. However, transport units for freight containers containing MPs are not exempt and must be marked accordingly.

Classification and Hazards

When classifying MPs, it is important to determine if they meet the criteria for any other hazard class. If an MP falls into another hazard class, it must be declared under the appropriate UN number and proper shipping name relevant to that hazard. In cases where the MP is not identified by name in the shipping name, its name must appear in parentheses near the basic description.

In summary, the transportation of MPs is strictly regulated to ensure safety and environmental protection. Proper identification, marking, labelling, and compliance with applicable regulations are essential to prevent incidents and mitigate potential impacts on the aquatic environment.

Marine Pollutant regulations

Identification and Classification:

A material is identified as a Marine Pollutant (MP) if it meets specific criteria outlined in the IMDG Code Index or is classified as an "Environmentally Hazardous Substance (aquatic environment)" based on aquatic toxicity, degradation, and BCF data. The identification process can be more complex for mixtures, often requiring laboratory testing or GHS mixture classification principles.

Transportation and Labelling:

The transportation of hazardous materials, including marine pollutants, is strictly regulated. The PHMSA/USDOT Hazardous Materials Regulations outline specific requirements for shipping marine pollutants. Proper labelling and marking are crucial, with the "Marine Pollutant" mark or the "fish and tree" symbol being mandatory on shipping papers and packaging. The presence of two or more marine pollutants in a material necessitates listing the most hazardous ones.

Severity of Marine Pollutants:

Marine pollutants are further classified into severe and non-severe categories. Severe marine pollutants are denoted by the letters "PP" in column 1 of Appendix B of the Hazardous Materials Table. These substances are subject to stricter regulations, with lower concentration thresholds (≥1%) triggering their classification as marine pollutants.

Packaging and Container Markings:

The packaging and containers of marine pollutants must adhere to specific regulations. Bulk packaging requirements vary based on capacity. For capacities under 1,000 gallons, the "Marine Pollutant" mark must be displayed on two opposing sides, while capacities exceeding 1,000 gallons require the mark on all four sides. The markings must be visible and may be displayed in black lettering on a square-on-point configuration.

Training and Compliance:

Understanding and complying with Marine Pollutant regulations are essential. Organisations like Daniels Training Services offer training programmes to educate individuals about the Hazardous Material Regulations of the PHMSA/USDOT. Non-compliance with these regulations can result in violations, emphasising the importance of proper training and adherence to the rules.

Frequently asked questions