Kiera Jefferson
Marine pollution is a pressing issue that poses a threat to the aquatic environment and the various life forms that inhabit it. Marine pollutants are classified as substances that are toxic to aquatic life and ecosystems. The criteria for classifying a substance as a marine pollutant vary between different regulatory bodies and countries. For instance, the US DOT defines marine pollutants based on the concentration of specific chemicals listed in their hazardous materials regulations, while the International Maritime Organization (IMO) uses the IMDG Code, which evaluates aquatic toxicity through specific test methods. Proper identification and classification of marine pollutants are crucial for implementing effective regulations and safeguarding the health of the public and the environment.
| Characteristics | Values |
|---|---|
| Listed in the IMDG Code Index | N/A |
| Meets criteria for "Environmentally Hazardous Substance (aquatic environment)" | Aquatic toxicity data, degradation data, and BCF data |
| Meets criteria for Hazard Classes 1-8 | Classify under the appropriate hazard class |
| Not meeting criteria for Hazard Classes 1-8 | Classify under Class 9 Packing Group III |
| Shipping name | Must be supplemented with the technical name of the marine pollutant |
| Shipping mark | "Marine Pollutant" on two opposing sides or two ends of the packaging |
| Shipping mark size | At least 100 mm or 3.9 inches |
| Shipping mark colour | Black lettering on a white square-on-point configuration |
| Shipping mark capacity | Less than 3,785 L or 1,000 gallons |
| Shipping in bulk | Regulated as marine pollutants by the US DOT |
| Marine Pollutant threshold | 10% concentration of Appendix B chemicals |
| Severe Marine Pollutant threshold | 1% concentration of Appendix B chemicals |
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What You'll Learn
Toxicity to aquatic life
Marine pollutants are substances that are toxic to aquatic life. The US DOT defines marine pollutants as materials that contain elevated concentrations of one or more of the chemicals listed in 49 CFR 172.101, Appendix B. The threshold for most materials is a 10% concentration of Appendix B chemicals, while "severe marine pollutants" are regulated at a 1% concentration.
The International Maritime Organization (IMO) uses a different set of criteria for classifying marine pollutants. According to the IMO's Dangerous Goods Code, also known as the IMDG Code, a substance is a marine pollutant if it is toxic to the aquatic environment when evaluated using the test methods outlined in Chapter 2.9.3.
Known and suspected marine pollutants are indicated by the symbol "P" in Column 4 of the Dangerous Goods List in Chapter 3.2 of the IMDG Code or in the MP column of the Code Index. When a substance's effect on the aquatic environment is unknown, or when a mixture or solution containing a designated marine pollutant is offered, the material must be evaluated according to IMDG 2.9.3.
When shipping marine pollutants, proper marking and labelling are crucial. The term "MARINE POLLUTANT" must be included in the dangerous goods descriptions, and the technical name of the pollutant must be provided. Additionally, the packaging must be marked with the "MARINE POLLUTANT" mark on at least two opposing sides or ends, excluding the bottom. This marking requirement ensures that transport vehicles or freight containers carrying such packages are also appropriately marked.
Various substances and human activities contribute to the toxicity of the aquatic environment. Oil spills release toxic substances such as benzenes, toluene, and poly-aromatic hydrocarbons, which contaminate water supplies and harm aquatic life. Pesticides and fertilizers used in agriculture can also wash into aquatic ecosystems, introducing carcinogens and poisonous substances that threaten aquatic organisms. Furthermore, certain textiles may contain substances like nonylphenol ethoxylates (NPEs), which are released during washing and pose a risk to aquatic species in surface water.
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Shipping name and markings
Marine Pollutants (MPs) are substances that are toxic to aquatic life. The US Department of Transportation (DOT) defines MPs as materials containing elevated concentrations of the chemicals listed in 49 CFR 172.101, Appendix B. The threshold for most materials is a 10% concentration, while "severe marine pollutants" are regulated at 1%.
Internationally, the criteria for classifying MPs are outlined by the International Maritime Organization (IMO) in its Dangerous Goods Code (IMDG Code). A substance is an MP if it is toxic to the aquatic environment when evaluated using the test methods in Chapter 2.9.3 of the IMDG Code.
When shipping marine pollutants, the proper shipping name and markings are crucial to ensure compliance with transportation regulations. Here are the key considerations for shipping name and markings:
- Proper Shipping Name: When assigning a proper shipping name to an MP, refer to the guidelines provided by the relevant regulatory bodies. For example, in the US, the DOT's Hazardous Materials Regulations (HMR) and the Electronic Code of Federal Regulations (eCFR) provide specific instructions for proper shipping names. The UN numbers UN 3077 and UN 3082 are commonly used for solid and liquid environmentally hazardous substances, respectively.
- Technical Names: According to the IMDG Code, when shipping MPs by sea, the proper shipping name should be supplemented with the technical name of the MP. This requirement is specific to sea transport and does not apply to road or air shipments.
- Marking Requirements: MPs typically require specific markings on the packaging and transport vehicles. The "MARINE POLLUTANT" mark is often required on at least two opposing sides or ends of the packaging, depending on its capacity. This mark usually consists of a black "fish and tree" symbol on a white or suitable contrasting background, displayed within a square-on-point configuration.
- Visibility: The markings must be visible from the direction they face. For transport vehicles or freight containers, the "MARINE POLLUTANT" mark is required on each side and end, ensuring compliance with IMDG Code requirements.
- Quantity and Packaging Considerations: Marking requirements may vary depending on the quantity and type of packaging. For small quantities (less than 5 litres or 5 kilograms), different regulations, such as IATA DGR and IMDG Code, may exempt certain packages from regulation. Always refer to the specific regulations for detailed guidance on quantity and packaging thresholds.
- Component Disclosure: When a hazardous material is assigned the letter "G" in the hazardous materials table, the name of the component that makes it an MP must be marked on the package in parentheses, unless the proper shipping name already identifies that component. If multiple components contribute to the MP designation, at least two of the most predominant components must be listed.
It is important to consult the specific regulations, such as the IMDG Code, 49 CFR, and IATA DGR, to ensure compliance with the most up-to-date requirements for shipping name and markings when dealing with MPs.
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US vs international criteria
Marine pollutants are substances that are toxic to aquatic life. The criteria for classifying a substance as a marine pollutant vary between the US and international standards.
US Criteria
The US Department of Transportation (DOT) defines marine pollutants as materials that contain an elevated concentration of one or more of the chemicals listed in 49 CFR 172.101, Appendix B. The marine pollutant threshold is a 10% concentration of Appendix B chemicals for most materials. However, some substances, known as "severe marine pollutants," are regulated at a 1% concentration.
When shipped by ground or air within the US, marine pollutants require additional communications only when shipped in bulk packages (greater than 119 gallons/882 pounds). The DOT does not have specific tests to determine if a substance is a marine pollutant but provides a list of marine pollutants in 49 CFR 172.101, Appendix B.
International Criteria
Internationally, the criteria for marine pollutants are set by the International Maritime Organization (IMO) in its Dangerous Goods Code, also known as the IMDG Code. According to the IMDG Code, a substance is considered a marine pollutant if it is toxic to the aquatic environment when evaluated using the test methods outlined in Chapter 2.9.3. Known and suspected marine pollutants are indicated by the symbol "P" in Column 4 of the Dangerous Goods List in Chapter 3.2 or in the MP column of the Code Index.
Differences in Classification
The differences in classification between the US and international criteria can lead to variations in the regulation of substances as marine pollutants. For example, the DOT regulations may include fewer chemicals as marine pollutants compared to the IMDG regulations. Additionally, the DOT allows shippers to classify a substance as a marine pollutant if it meets the IMDG definition, providing consistency in the classification across different modes of transport.
Marking and Shipping Requirements
Both the US and international regulations have specific marking and shipping requirements for marine pollutants. The US regulations, such as 49 CFR 172.203(l), 172.322, and 171.4, outline the marking requirements, including the placement and visibility of the "MARINE POLLUTANT" mark on packages, transport vehicles, and freight containers.
Similarly, the IMDG Code provides guidelines for the marking and shipping of marine pollutants, including the use of the "fish and tree" mark for UN-numbers UN3077 and UN3082. These marks are accepted by the IATA for air transport, although specific packaging rules must be met.
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Hazard classes
Flammable solids and hazardous substances: This class includes substances that can easily catch fire or contribute to fires at sea. Examples include flammable gases, such as propane and butane; flammable liquids, such as petrol and diesel; and
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Packaging rules
Marine pollutants are materials that pose a risk to aquatic ecosystems. The International Maritime Dangerous Goods Code (IMDG Code) establishes regulations for the transportation of marine pollutants and environmentally hazardous substances. The US Department of Transportation (DOT) defines marine pollutants as materials that contain an elevated concentration of one or more of the chemicals listed in 49 CFR 172.101, Appendix B.
DOT Regulations
DOT only requires marine pollutants to be regulated as such if they are shipped in bulk size packaging (greater than 119 gallons/882 pounds) or when shipped by vessel. When shipped by ground or air in the US, marine pollutants require additional communications only when shipped in bulk packages. Unlike IATA and IMDG, DOT does not have any tests to determine if something is a marine pollutant. Instead, it provides a list of marine pollutants in 49 CFR 172.101, Appendix B.
IATA Regulations
IATA regulations refer to air shipments only, so they do not regulate marine pollutants. However, the Env Haz labels are required for UN Numbers UN3077 and UN3082, unless they contain less than or equal to 5 L or 5 kg per inner or single package. IATA does permit the classification of marine pollutants as environmentally hazardous substances when shipped to/from a country that regulates these materials, or if it is in a transport chain involving water.
IMDG Regulations
IMDG regulations state that all marine pollutants must be identified with the Environmentally Hazardous Substance Mark, unless the package contains less than, or equal to, 5 L or 5 kg per inner or single package. When dealing with marine pollutants, IMDG regulations are more encompassing than DOT rules. They have specific chemicals that are identified as marine pollutants, indicated with a “P” in Column 4 of the Dangerous Goods List in Chapter 3.2 of the IMDG Code or in the MP column of the Code Index.
Marking Requirements
The MARINE POLLUTANT mark must be displayed in black lettering on a square-on-point configuration with a white or suitable contrasting background. The mark must be visible from the direction it faces and must be 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). If the packaging has a capacity of 3,785 L (1,000 gallons) or more, the mark must be on each end and each side. The name of the component that makes the material a marine pollutant must be marked on the package in parentheses in association with the marked proper shipping name.
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Frequently asked questions
A marine pollutant is a substance that is toxic to aquatic life.
A substance is classified as a marine pollutant if it meets the criteria for inclusion in the IMDG Code Index, or if it meets the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)".
The substance must be toxic to the aquatic environment when evaluated by the test methods given in Chapter 2.9.3 of the IMDG Code.
When shipping marine pollutants, the proper shipping name shall be supplemented with the technical name of the marine pollutant. The term "MARINE POLLUTANT" shall be put at the end of dangerous goods descriptions. The packaging must also be marked with the "MARINE POLLUTANT" mark on at least two opposing sides if the packaging has a capacity of less than 1,000 gallons, or on all four sides if greater than 1,000 gallons.
