Helena Joyce
Marine pollutants are materials that pose a risk to aquatic ecosystems. When shipping these dangerous goods by sea, the technical name of the marine pollutant must be included in the description. For example, UN 1263, PAINT (triethylbenzene), Class 3 PG III (27 degrees Celsius), MARINE POLLUTANT. UN3077 and UN3082 are two other examples of marine pollutants. These numbers are also referred to as Environmentally Hazardous Substances.
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What You'll Learn
UN1673 is not listed as a marine pollutant
Marine pollutants are materials that pose a risk to aquatic ecosystems. 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 an "Environmentally Hazardous Substance (aquatic environment)".
The term "marine pollutant" is mainly used by the IMDG code, while the term "environmentally hazardous substances" is used by other dangerous goods regulations such as ADR and IATA. When shipping marine pollutants by sea, the proper shipping name shall be supplemented with the technical name of the marine pollutant, and the term "marine pollutant" shall be added to the end of the description.
There are some exceptions to the regulations regarding marine pollutants. For example, the marine pollutant mark is not required when marine pollutants are on board a road vehicle or railway vehicle on a ro-ro ship, or if it is contained in a small means of containment in quantities of 5L or less for liquids or 5kg or less for solids. Additionally, the placard and UN number are not required to be displayed for substances identified as marine pollutants in certain situations.
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Marine Pollutant (MP) criteria
Identification of Marine Pollutants:
A material is classified as a Marine Pollutant (MP) if it meets either of the following criteria:
- Listed in the IMDG Code Index: The IMDG Code, used primarily for transport by sea, provides a list of substances identified as marine pollutants.
- Environmentally Hazardous Substance (Aquatic Environment): This classification is determined using aquatic toxicity data, degradation data, and BCF data. It includes substances that are toxic to aquatic life.
Shipping and Packaging Requirements:
When shipping marine pollutants, specific procedures and markings are required to ensure compliance with regulations:
- Proper Shipping Name: The shipper must assign a proper shipping name that accurately describes the hazardous material. For example, "UN3077, Environmentally Hazardous Substance, Solid, n.o.s."
- Technical Name: When transporting by sea, the technical name of the marine pollutant must be included, along with the term "MARINE POLLUTANT" at the end of the dangerous goods description.
- Marking Requirements: Packages containing marine pollutants must be marked with the "MARINE POLLUTANT" label, typically displayed as a square-on-point configuration with a black symbol (fish and tree) on a white or contrasting background. This mark must be visible and placed on at least two opposing sides or ends of the package.
- Quantity and Capacity Regulations: The marking requirements may vary depending on the quantity and capacity of the package. For example, a combination packaging containing a non-severe marine pollutant with each inner packaging containing 5L or less for liquids or 5kg or less for solids is subject to specific marking rules.
- Bulk Packaging and Transport Vehicles: Bulk packaging and transport vehicles carrying marine pollutants must also be marked with the "MARINE POLLUTANT" label. The mark must appear on each side and end, ensuring visibility.
Exceptions and Special Provisions:
There are certain exceptions to the Marine Pollutant (MP) criteria, such as:
- Packaging Quantity Exemptions: According to 49CFR 171.4 (c) (2), marine pollutants packaged in single or combination packaging with a net quantity of 5L or less for liquids or 5kg or less for solids may be exempt from specific regulations if the packaging meets general requirements.
- Display of Marine Pollutant Mark: In certain cases, such as when marine pollutants are on board a road vehicle or railway vehicle, or when the quantity is below a certain threshold, the display of the "MARINE POLLUTANT" mark is not required.
- Transport Canada Special Provision (SP99): This provision exempts shipments of UN 3077 or UN 3082 by ground from some TDG regulations if the quantity is under 450 liters or 450 kg on a road or railway vehicle, provided that general packaging conditions are met.
It is important to note that these criteria and regulations may vary depending on the specific jurisdiction and hazardous materials regulations in place, such as the US DOT's Hazardous Materials Regulations or the international IMDG Code.
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Packaging and transportation regulations
Marine Pollutants (MPs) are materials that pose a risk to aquatic ecosystems. The term is primarily used by the IMDG Code, while other dangerous goods regulations, such as ADR and IATA, use the term "environmentally hazardous substances".
When it comes to packaging and transportation regulations, there are several key points to consider:
Identification of Marine Pollutants
Firstly, it is essential to identify if a material is a Marine Pollutant. This can be done by checking if the material 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 required for this determination.
Proper Shipping Name and Technical Name
When shipping MPs by sea, the proper shipping name must be supplemented with the technical name of the MP. The term "MARINE POLLUTANT" should be included at the end of dangerous goods descriptions. This requirement is specific to the IMDG code and is only applicable for transport by sea.
Marking and Labelling Requirements
The IMDG code and other regulations specify marking and labelling requirements for MPs. The "MARINE POLLUTANT" mark should be placed in association with hazard warning labels or the marked proper shipping name. Bulk packaging that contains an MP must be marked with the "MARINE POLLUTANT" mark on at least two opposing sides or ends, unless the packaging has a capacity of 3,785 L or more, in which case it should be marked on each end and each side.
Transport vehicles or freight containers carrying MPs must also be marked with the "MARINE POLLUTANT" mark on each side and end, and it must be visible from all directions. This mark typically consists of a black symbol (fish and tree) on a white or suitable contrasting background, in the form of a square-on-point configuration.
Quantity and Packaging Requirements
There are specific regulations regarding the quantity and packaging of MPs. For example, the 49CFR 171.4 (c) (2) states that MPs shipped in single or combination packaging with a net quantity of 5L or less for liquids or 5 kg or less for solids are exempt from certain requirements as long as the packaging meets the general requirements. Similar quantity exemptions are mentioned in TDGR section 4.22 (2) and Transport Canada's Special Provision (SP99).
Exceptions and Additional Hazard Classes
It is important to note that some exceptions exist for MPs that meet specific criteria. For instance, if an MP is also a Class 3 Flammable Liquid, it may be subject to the marine pollutant exception, but it must still be shipped and regulated as a Class 3 Flammable Liquid. Additionally, if an MP meets the criteria for inclusion in another hazard class, all provisions related to those additional hazards must still be followed.
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Hazardous substances
Marine pollutants are materials that pose a risk to aquatic ecosystems. 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".
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 an "Environmentally Hazardous Substance (aquatic environment)". Aquatic toxicity data, degradation data, and BCF data are used to determine if a material belongs to environmentally hazardous substances.
When shipping marine pollutants, the proper shipping name must be supplemented with the technical name of the marine pollutant, and the term "Marine Pollutant" must be included at the end of dangerous goods descriptions. The technical name and the term "Marine Pollutant" are only required by the IMDG code for transport by sea.
There are some exceptions to the regulations for shipping marine pollutants. For example, the marine pollutant mark is not required when marine pollutants are on board a road vehicle or railway vehicle on a ro-ro ship, or if the quantity is less than or equal to 5L for liquids or 5kg for solids. Additionally, Transport Canada has a special provision (SP99) for shipping UN 3077 or UN 3082 by ground, exempting shipments from TDG regulations except for Part 1 and Part 2 if the quantity is under 450L or 450kg.
Some examples of hazardous substances that are considered marine pollutants include acetaldehyde, alkylphenols, barium compounds, benzaldehyde, bromobenzene, butanedione, butyl mercaptans, camphor oil, cyanides, and dimethyl disulphide.
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Marine Pollutant exceptions
Marine Pollutants (MPs) are materials that pose a risk to aquatic ecosystems. The term is mainly used by the IMDG Code, while other dangerous goods regulations, such as ADR and IATA, use the term "environmentally hazardous substances". When shipping MPs by sea, the proper shipping name must be supplemented with the technical name of the MP, and the term "Marine Pollutant" must be included at the end of the description.
There are some exceptions to the regulations regarding MPs. For example, section 4.22 (2) states that the MP mark is not required when MPs are on board a road or railway vehicle on a ro-ro ship, or if it is contained in a small means of containment in quantities of 5L or less for liquids or 5kg or less for solids. Additionally, the placard and UN number are not required for substances identified as MPs in subparagraph 2.43 (b) (ii) when the MP mark is not required.
IATA's Special Provision A197 states that when these substances are transported in single or combination packaging containing a net quantity of 5L or less for liquids or 5kg or less for solids, they are not subject to any other provisions, provided the packaging meets general provisions. The IMDG code at 2.10.2.7 states something similar, with the exception of the packaging having to meet general provisions sections 4.1.1.1, 4.1.1.2, and 4.1.1.4 to 4.1.1.8.
Transport Canada's Special Provision SP99 exempts shipments of UN 3077 or UN 3082 by ground from TDG regulations except for Part 1 and Part 2 if shipped in quantities under 450L or 450kg on a road or railway vehicle, as long as general packaging conditions are met.
It is important to note that these exceptions only apply if the substance meets the criteria for a marine pollutant and do not exempt compliance with other regulations. For instance, if an MP is also a Class 3 Flammable Liquid, it would still need to be shipped as a Class 3 Flammable Liquid.
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