Meghan Hodges
Marine pollutants, also known as environmentally hazardous substances, are materials that pose a risk to aquatic ecosystems. When shipping these substances, the proper shipping name should be supplemented with the technical name of the marine pollutant. UN3082 is a classification for environmentally hazardous substances that are in liquid form and do not meet the classification criteria for inclusion in any other hazard class. Calcium sulfonate is a substance that can be classified as UN3082, but it is not always considered a marine pollutant. To be considered a marine pollutant, it must be listed in the IMDG Code Index or meet the criteria for classification as an Environmentally Hazardous Substance (aquatic environment). While calcium sulfonate may fall under the UN3082 classification, it is important to determine if it meets the criteria for being a marine pollutant according to the IMDG Code.
| Characteristics | Values |
|---|---|
| UN Number | UN3082 |
| Description | Environmentally Hazardous Substance, Liquid, n.o.s. |
| Marine Pollutant Mark | Required if packaging capacity exceeds 3,785 L (1,000 gallons) |
| Mark Description | Black lettering on a square-on-point configuration with a white or suitable contrasting background |
| Marking Exemptions | Marine Pollutants on a road or railway vehicle on a ro-ro ship with a quantity of 5 L for liquids or 5 kg for solids or less |
| IATA Requirements | IATA does not require the "fish and tree" mark |
| Shipping Name | Proper shipping name must be supplemented with the technical name when shipped by sea |
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What You'll Learn
UN3082 is an environmentally hazardous substance
Marine pollutants are materials that pose a risk to aquatic ecosystems. A material is identified as a marine pollutant if it is listed in the IMDG Code Index or if it meets the classification criteria for "Environmentally Hazardous Substance (aquatic environment)".
UN3082 is a classification for environmentally hazardous substances that are liquids and do not meet the classification criteria for inclusion in any other hazard class. This classification is used when a material does not fit into the other eight hazard classes but still requires a basic shipping description. For example, a package that exceeds the hazardous substances limit but whose contents are not listed as a proper shipping name in the Hazardous Materials Table (HMT).
UN3082 is used for the transportation of environmentally hazardous substances by sea, road, or air. When shipping by sea, the technical name of the marine pollutant and the term "marine pollutant" are required by the IMDG code. For instance, "UN 1263, PAINT (triethylbenzene), Class 3 PG III (27 degrees Celsius), MARINE POLLUTANT". When shipping by road or air, the proper shipping name shall be used, for example, "UN3082, Environmentally hazardous substance, liquid, n.o.s".
UN3082 shipments are subject to marking requirements. For example, if the packaging has a capacity of 3,785 L (1,000 gallons) or more, it must be marked on each end and side with the "marine pollutant" mark. The mark must be visible from the direction it faces and may be displayed in black lettering on a square-on-point configuration with the same outside dimensions as a placard. Transport vehicles or freight containers carrying UN3082 substances must also be marked on each side and end with the "marine pollutant" mark.
There are some exceptions to the marking requirements for UN3082. For instance, if marine pollutants are transported in single or combination packaging containing 5 L or less for liquids or 5 kg or less for solids, they are not subject to the marking requirements. Additionally, if UN3082 is shipped by ground in quantities less than 450 L or 450 kg, it is exempt from TDG regulations except for Part 1 (General Provision) and Part 2 (Classifications).
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Marine pollutants are materials that pose a risk to aquatic ecosystems
Marine pollution is a pressing issue that threatens the health of aquatic ecosystems and organisms worldwide. Marine pollutants are materials that pose a risk to these ecosystems, and they can be categorised as either chemicals or trash.
Chemicals, such as nitrogen and phosphorus, enter the ocean through human activities like the use of fertilisers on farms. These chemicals promote the growth of algal blooms, which can be toxic to marine life and harmful to humans. This is known as nutrient pollution and is a significant concern for environmental, health, and economic reasons.
Trash, particularly plastic waste, is another major contributor to marine pollution. Plastic items can take hundreds of years to decompose and pose dangers to both humans and animals. Marine animals can become entangled or injured by debris, and some may even ingest plastic items or microplastics, absorbing toxic chemicals into their tissues. Plastic waste often originates from land sources and accumulates in large "patches" in ocean gyres, such as the Pacific Garbage Patch, which spans an area of about 1.6 million square kilometres.
The distinction between a material being classified as a "Marine Pollutant" (MP) or an "Environmentally Hazardous Substance" (EHS) is important in the context of transportation and shipping regulations. The term "Marine Pollutant" is primarily used by the IMDG Code, while other dangerous goods regulations, such as ADR and IATA, use the term "Environmentally Hazardous Substance." A shipper offering a hazardous material for transport must determine its hazard class, including its potential impact on the aquatic environment, and mark the material accordingly.
UN3082 is a classification for "Environmentally Hazardous Substance, Liquid, n.o.s." It is used when a material does not fit into the other hazard classes but still requires a basic shipping description. This classification is distinct from UN3077, which refers to solid substances.
While I cannot definitively state if calcium sulfonate UN3082 is specifically classified as a marine pollutant, it falls under the broader category of environmentally hazardous substances, indicating its potential to pose a risk to aquatic ecosystems.
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Marine Pollutant (MP) identification criteria
Marine Pollutant (MP) is a term mainly used by the IMDG code, while the term "environmentally hazardous substances" is used by other dangerous goods regulations such as ADR and IATA. A shipper who offers a hazardous material for transport must determine the hazard class of the material, including its applicability as an "environmentally hazardous substance (aquatic environment)", and assign a proper shipping name that best describes it.
A material is identified as an MP if it is listed in the IMDG Code Index or if it meets the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)". Aquatic toxicity data, degradation data, and BCF data are needed to determine if a material belongs to environmentally hazardous substances. For mixtures, it is more difficult to check if it is an MP, and usually, GHS mixture classification principles or laboratory testing are applied.
When shipping MPs by sea, the proper shipping name shall be supplemented with the technical name of the MP, and the term "MARINE POLLUTANT" shall be put at the end of dangerous goods descriptions. The technical name of the MP and the term "MARINE POLLUTANT" are only required by IMDG code (transport by sea). When shipping MPs by road or air, the following proper shipping name shall be used: "UN3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, n.o.s." or "UN3082 ENVIRONMENTALLY HAZARODUS SUBSTANCE, LIQUID, n.o.s.".
For a proper shipping name used to describe a hazardous material that is an MP and assigned the letter “G” in column (1) of the § 172.101 hazardous materials table or that contains the text “n.o.s.”, the name of the component that makes the material an MP must be marked on the package in parentheses in association with the marked proper shipping name. Where two or more components that make a material an MP are present, the names of at least two of the components that most predominantly contribute to the MP designation must appear in parentheses in association with the marked proper shipping name.
The MARINE POLLUTANT mark shall be placed in association with the hazard warning labels required by subpart E of this part or, in the absence of any labels, in association with the marked proper shipping name. A bulk packaging that contains an MP must be marked with the MARINE POLLUTANT mark on at least two opposing sides or two ends other than the bottom if the packaging has a capacity of less than 3,785 L (1,000 gallons). The mark must be visible from the direction it faces. This mark may be displayed in black lettering on a white square-on-point configuration having the same outside dimensions as a placard.
In summary, to identify if a material is an MP, one must refer to the IMDG Code Index and the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)". When shipping MPs, specific markings and labels are required, including the proper shipping name, technical name, and the term "MARINE POLLUTANT".
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Marine Pollutant mark and its usage
Marine Pollutant (MP) is a term used by the IMDG code to refer to materials that can pose a risk to aquatic ecosystems. These materials are listed in the IMDG Code Index and are classified as "Environmentally Hazardous Substances (aquatic environment)".
When shipping these materials, the proper shipping name must be supplemented with the technical name of the marine pollutant, with the term "MARINE POLLUTANT" at the end of the description. This is only required by the IMDG code for transport by sea. For example, "UN 1263, PAINT (triethylbenzene), Class 3 PG III (27 degrees Celsius), MARINE POLLUTANT".
If a substance does not meet the classification criteria for inclusion in any other hazard class, it shall be declared under either UN 3077 or UN 3082 as an environmentally hazardous substance, solid or liquid, respectively. These UN numbers are used when a material does not fit into the other hazard classes but still needs a basic shipping description. IATA requires the "fish and tree" mark for these UN numbers, although this is not mandatory for air transport.
The MARINE POLLUTANT mark must be placed in association with the hazard warning labels or with the marked proper shipping name. The mark must be clearly visible and may be displayed in black lettering on a square-on-point configuration, with a white or suitable contrasting background. For non-bulk packages, each side of the mark must be at least 100 mm or 3.9 inches, although this may be reduced if the size of the package requires it, as long as the marking remains clearly visible. For bulk packaging with a capacity of 3,785 L (1,000 gallons) or more, the mark must be displayed on each end and each side. For bulk packaging with a capacity of less than 3,785 L, the mark must be displayed on at least two opposing sides or two ends other than the bottom.
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UN3082 and UN3077 are used when a material doesn't fit in other hazard classes
Marine pollutants are materials that pose a risk to aquatic ecosystems. When shipping marine pollutants by sea, the proper shipping name is supplemented with the technical name of the marine pollutant, followed by the term "MARINE POLLUTANT". This term is only required by the IMDG code (transport by sea).
UN3082 and UN3077 are used for environmentally hazardous substances in Class 9 and Packing Group III. They are used when a material does not fit into the other eight hazard classes but still needs a basic shipping description. For example, a package that contains 12 pounds of lead has exceeded the hazardous substances limit, but lead is not listed as a proper shipping name in the Hazardous Materials Table (HMT). In this case, UN3077 would be used. Similarly, if a package contained more than 10% Acroleic Acid, it would be considered a marine pollutant, but again, as this material is not listed in the HMT, UN3082 would be used.
The IATA only requires the "fish and tree" mark for the UN numbers UN3077 and UN3082. The marine pollutant mark is accepted by the IATA for air transport, although it is not required. The mark must be visible from the direction it faces and may be displayed in black lettering on a square-on-point configuration with the same outside dimensions as a placard.
When a substance, mixture, or article is a marine pollutant and does not meet the classification criteria for inclusion in any other hazard class, it shall be declared under either UN3077 or UN3082.
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Frequently asked questions
UN3077 and UN3082 are codes for environmentally hazardous substances.
Environmentally hazardous substances are materials that can pose a risk to aquatic ecosystems.
UN3077 is for solid substances, while UN3082 is for liquid substances.
No, a substance that does not meet the provisions of section 2.9.3 of the IMDG Code but is transported under UN3077 or UN3082 is not considered a marine pollutant.
The marking for marine pollutants is a square-on-point configuration with a fish and tree symbol in black on a white or suitable contrasting background.
