Kiera Jefferson
Marine pollutants are materials that pose a risk to aquatic ecosystems, including marine mammals, fish, crustaceans, and algae. The International Maritime Dangerous Goods code (IMDG) uses the term marine pollutant, while other dangerous goods regulations such as ADR (road transport) and IATA (air transport) use the term environmentally hazardous substance (EHS). To comply with regulations, shippers must determine the hazard class of the material, assign a proper shipping name, and mark the material accordingly. The Environmentally Hazardous Substance Mark, which became mandatory on January 1, 2009, is required for certain UN numbers, such as UN3077 and UN3082, and for environmentally hazardous substances meeting specific criteria. This mark typically consists of a black symbol of a dead tree and fish on a white or contrasting background, displayed in a square-on-point or diamond-shaped configuration. While IATA does not require this mark, it is accepted for air transport.
| Characteristics | Values |
|---|---|
| Identification | A material is identified as a Marine Pollutant (MP) if it is listed in the IMDG Code Index, or if it meets the criteria for classification as "Environmentally Hazardous Substance (aquatic environment)" |
| Shipper's Responsibility | A shipper offering a hazardous material for transport must determine the hazard class of the material, including "environmentally hazardous substances (aquatic environment)" applicability, assign a proper shipping name, and mark the material according to dangerous goods regulations |
| Classification | Marine Pollutants are classified as UN 3077 (solid) or UN 3082 (liquid) |
| Marking | The Environmentally Hazardous Substance Mark became mandatory on 1st January 2009. It must be placed on all four sides of the shipping container and must be visible from the direction it faces. |
| Symbol | The symbol is a dead tree and fish, in black on a white or suitable contrasting background. |
| Shape | The mark must be in the form of a square-on-point or a diamond shape. |
| Size | The minimum label dimensions must be 100mmx100mm, and the border line forming the diamond shall be no less than 2mm wide. |
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What You'll Learn
Marine Pollutant Labels and Placards
The International Maritime Dangerous Goods code (IMDG) uses the term "Marine Pollutant," while other dangerous goods regulations, such as ADR (road transport) and IATA (air transport), use the term "Environmentally Hazardous Substance (EHS)." The actual term "Marine Pollutant" is a supplementary classification requirement that applies only to transport by sea.
The Marine Pollutant mark has two forms: labels for packages and placards for shipping containers. The labels and placards must comply with IATA, ICAO, IMDG, UN, and DOT regulations for shipping marine pollutants and environmentally hazardous substances. The universal symbol, a dead tree and fish, notifies everyone of the potential impact of a spill on wildlife, seas, and marshes.
For packages, the Environmentally Hazardous Substance Mark became mandatory on January 1, 2009. It is required for combination packages where the inner package or single package contains more than 5 litres (1.32 gallons) of liquid or 5 kilograms (11 pounds) of solid material. The EHS package labels must be diamond-shaped, with the symbol in black on a white or suitable contrasting background. The minimum label dimensions are specified as 100mm by 100mm, with a border line no less than 2mm wide.
For shipping containers, the Marine Pollutant Placard must be displayed on all four sides. The placard must be visible from the direction it faces and can be displayed in black lettering on a white square-on-point configuration, having the same dimensions as a placard. The IMDG Code specifies that packages containing marine pollutants must be "durably marked" with the Marine Pollutant mark.
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Shipping names
Marine Pollutants (MPs) are materials that pose a risk to aquatic ecosystems, including marine mammals, fish, crustaceans, and algae. The International Maritime Dangerous Goods (IMDG) code uses the term "Marine Pollutant", while other dangerous goods regulations, such as ADR (road transport) and IATA (air transport), use the term "Environmentally Hazardous Substance" (EHS).
When offering a hazardous material for transport, shippers must determine the hazard class of the material, including its potential impact on the aquatic environment, and assign a proper shipping name. This name must be marked on the package in association with any required hazard warning labels.
For example, a solid hazardous substance might be assigned the shipping name "UN3077, Environmentally Hazardous Substance, Solid, n.o.s.", while a liquid substance might be labelled "UN3082, Environmentally Hazardous Substance, Liquid, n.o.s.", In both cases, the component responsible for the material's hazardous nature, such as "cadmium sulfide", must be included in parentheses after the shipping name.
In addition to the shipping name, packages containing hazardous materials must be marked with the appropriate symbol to indicate their environmental hazard. This symbol, consisting of a dead tree and fish, is known as the Environmentally Hazardous Substance Mark or the Marine Pollutant Mark. It must be displayed on all four sides of the package or shipping container, with black lettering or symbol on a white or suitably contrasting background, and in the form of a square-on-point or diamond shape.
The Marine Pollutant Mark is required for certain UN numbers, specifically UN3077 and UN3082, and any environmentally hazardous substances meeting the classification criteria of Part 2.9.3 of the IMDG Code. This mark ensures that shipping personnel are aware of the potential toxic impact of the contents on the marine environment and its ecosystems.
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Packaging requirements
The packaging requirements for environmentally hazardous substances or marine pollutants are stringent and detailed. These requirements are in place to ensure the safe transportation of such materials and to notify shipping personnel of the potential risks to aquatic ecosystems.
Firstly, it is important to determine the hazard class of the material being shipped. This involves identifying the specific type of environmentally hazardous substance and whether it falls under the category of a marine pollutant. The IMDG Code Index is a key reference for this, as it lists all marine pollutants. Additionally, the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)," should be consulted, which involves assessing aquatic toxicity data, degradation data, and BCF data.
Once the hazard class is determined, the shipper must assign a proper shipping name that best describes the material. This name is crucial for accurate identification and compliance with dangerous goods regulations. The name of the component that makes the material a marine pollutant must be included in the shipping name, unless the component is already explicitly mentioned in the name. If multiple components contribute to the marine pollutant designation, at least two of the most predominant ones must be listed.
The packaging requirements vary depending on the form of the hazardous substance, whether it is a solid or a liquid, and the quantity being transported. For combination packaging containing a marine pollutant, the inner packagings must not exceed a net capacity of 5 L (1.3 gallons) for liquids or 5 kg (11 pounds) for solids. These quantities also apply to single packagings.
The marking and labelling requirements are a critical aspect of the packaging. The "Environmentally Hazardous Substance Mark" or the "Marine Pollutant Mark" must be displayed on packages, transport vehicles, freight containers, and shipping containers. This mark includes the universally recognised symbol of a "dead tree and fish" or a "fish and tree", which indicates the potential harm to aquatic life and ecosystems. The mark should be displayed in black on a white or suitable contrasting background, forming a square-on-point or diamond shape. The minimum label dimensions are specified as 100mmx100mm, with a border line no less than 2mm wide.
For bulk packaging, the requirements differ based on capacity. If the packaging has a capacity of less than 3,785 L (1,000 gallons), the mark must be displayed on at least two opposing sides or ends, excluding the bottom. If the capacity is 3,785 L (1,000 gallons) or more, the mark must be displayed on each end and each side. These markings must be clearly visible from a distance and may be displayed in black lettering on a square-on-point configuration with the same dimensions as a placard.
It is important to note that the IMDG Code has specific provisions for packages and cargo transport units. Packages containing marine pollutants that meet the criteria of IMDG Code Part 2.9.3 shall be durably marked with the marine pollutant mark. Additionally, cargo transport units must display the marine pollutant placard as indicated in IMDG Code Part 5.3.1.1.4.1.
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IATA and IMDG Code
Marine pollutants or environmentally hazardous substances are materials that pose a risk to aquatic ecosystems, including marine mammals, fish, crustaceans, and algae. The term "marine pollutant" is mainly used by the IMDG Code, while "environmentally hazardous substances" is used by other dangerous goods regulations such as ADR and IATA.
The IMDG Code, or the International Maritime Dangerous Goods Code, was first introduced in 1965 as an international code for the maritime transport of dangerous goods in packaged form. The Code sets out detailed requirements for the safe carriage of dangerous goods and to prevent environmental pollution. It covers aspects such as packing, container traffic, stowage, and the segregation of incompatible substances. Amendments to the IMDG Code are made every two years to keep up with industry changes and transport developments. The IMDG Code is considered an extension of the provisions outlined in the International Convention for the Safety of Life at Sea, 1974 (SOLAS), specifically Chapter VII, which deals with the mandatory provisions for the carriage of dangerous goods.
IATA, or the International Air Transport Association, recognizes the classification of marine pollutants as environmentally hazardous substances under certain conditions. IATA requires the "fish and tree" mark for UN-numbers UN3077 and UN3082. While IATA does not require a specific mark for marine pollutants, it accepts the use of the marine pollutant mark for air transport.
The Environmentally Hazardous Substance Mark, which became mandatory on January 1, 2009, is required for combination packages where the inner package or single package exceeds 5 liters (1.32 gallons) for liquids or 5 kilograms (11 pounds) for solids. This mark consists of a black symbol of a dead tree and fish on a white or suitable contrasting background, set within a square at a 45-degree angle (diamond-shaped). Shipping containers and cargo transport units containing marine pollutants must be marked on all four sides with this EHS Mark, even if the individual packages meet the exception size.
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Hazardous substances
Marine pollutants, or environmentally hazardous substances, are materials that can harm aquatic ecosystems, including marine mammals, fish, crustaceans, and algae. The term "marine pollutant" is used in the International Maritime Dangerous Goods code (IMDG), while "environmentally hazardous substances" is used in other dangerous goods regulations such as ADR (road transport) and IATA (air transport).
When it comes to shipping, anyone intending to transport hazardous materials by road, rail, sea, or air must determine the hazard class of the material, assign a proper shipping name, and establish whether it is an environmentally hazardous substance for the aquatic environment. This involves identifying the specific component or components within the material that make it a marine pollutant.
The Environmentally Hazardous Substance Mark, also known as the Marine Pollutant Mark, is used to indicate that a material is toxic to the marine environment and its ecosystems. This mark became mandatory on January 1, 2009, and is required for combination packages where the inner package or single package exceeds 5 litres (1.32 gallons) for liquids or 5 kilograms (11 pounds) for solids. The mark consists of a dead tree and fish symbol in black on a white or suitable contrasting background, enclosed within a square-shaped border.
Packages containing marine pollutants must be labelled and marked according to relevant dangerous goods regulations. For example, the IMDG Code specifies that packages meeting the classification criteria of Part 2.9.3 must be marked with the Marine Pollutant Mark. Additionally, the IATA permits the classification of marine pollutants as environmentally hazardous substances when shipped to or from a country that regulates these materials or when water is involved in the transport chain. In such cases, the more stringent IMO regulations for labelling and marking must be followed.
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Frequently asked questions
Marine pollutants are materials that can pose a risk to aquatic ecosystems, including marine mammals, fish, crustaceans, and algae.
The Environmentally Hazardous Substance Mark is used to notify shipping personnel that the material being transported is toxic to the marine environment and its ecosystems. It is required for packages and shipping containers that contain environmentally hazardous substances.
The environmentally hazardous mark is required for all marine pollutants that are being shipped. The mark must be placed on packages and shipping containers that contain environmentally hazardous substances. The specific placement of the mark depends on the type of packaging and the capacity of the packaging.
