Marine Pollutant Marking: When Is It Mandatory?

when is the marine pollutant marking required on a container

Marine pollutants are materials that pose a risk to aquatic ecosystems. The marking for a marine pollutant is required on a container when the container is transporting hazardous materials that are marine pollutants. The mark must be placed in association with the hazard warning labels or with the marked proper shipping name. The mark must be displayed on at least two opposing sides or two ends of the container 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 displayed on each end and each side of the container. The marking is not required when the container already bears a HazMat label or placard as required by the Hazardous Material Regulations.

Characteristics Values
When the marine pollutant mark is required When a packaging contains a marine pollutant and is transported by vessel
When the marine pollutant mark is not required When a bulk packaging, freight container or transport vehicle is already labelled or placarded in accordance with Subpart E or F of Part 172 of the HMR
Packaging capacity for the mark to be required Less than 3,785 L (1,000 gallons)
Packaging capacity for the mark to be required 3,785 L (1,000 gallons) or more
The mark's appearance Symbol (fish and tree): black on white or suitable contrasting background
The form of the mark Square-on-point

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Marine Pollutant Mark on packaging

Marine Pollutant Mark, or Marine Pollutant Placards, are required for substances that are deemed environmentally hazardous to aquatic ecosystems. The mark takes on two forms: the marine pollutant labels (for packages) and marine pollutant placards (for shipping containers).

The Marine Pollutant Mark is required for UN3077, UN3082, and environmentally hazardous substances meeting the classification criteria of Part 2.9.3 of the IMDG Code. Packages containing marine pollutants that meet the criteria of 2.9.3 should be durably marked with the Marine Pollutant Mark.

The Marine Pollutant Mark must be placed in association with the hazard warning labels required by subpart E or, in the absence of any labels, in association with the marked proper shipping name. A bulk packaging that contains a marine pollutant 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. If the packaging has a capacity of 3,785 L (1,000 gallons) or more, it should be marked on each end and each side.

The Marine Pollutant Mark must conform to the following: the symbol (fish and tree) should be in black on a white or suitable contrasting background. The marking must be in the form of a square-on-point, and the symbol and border must be black on a white or suitable contrasting background.

There are some exceptions to the requirement to display the Marine Pollutant Mark. For example, if a packaging of a marine pollutant or a transport vehicle containing one displays a HazMat label or placard as required by the Hazardous Material Regulations, it is not required to display the Marine Pollutant Mark. This exception does not apply to the transport of a marine pollutant by vessel.

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Marine Pollutant Placards on containers

Marine Pollutant Placards, or the Marine Pollutant mark, are required for substances that pose a risk to aquatic ecosystems and are deemed environmentally hazardous. The mark takes on two forms: the marine pollutant labels (for packages) and marine pollutant placards (for shipping containers). The former is required on each bulk and non-bulk packaging when transported by vessel, while the latter must be marked on all four sides of the container.

The Marine Pollutant mark must conform to the following: the symbol (a fish and a tree) must be displayed in black on a white or suitable contrasting background. The marking must be in the form of a square-on-point, with black lettering, and the symbol and border must be black on a white or suitable contrasting background. The mark must be clearly visible from the direction it faces.

There are some exceptions to the requirement to display the Marine Pollutant mark. If a package contains 5 litres or less for liquids or 5kg or less for solids, the package does not need to be marked. Additionally, if a transport vehicle or packaging containing a marine pollutant already displays a HazMat label or placard as required by the Hazardous Material Regulations, the Marine Pollutant mark is not required. This exception does not apply to the transport of marine pollutants by vessel.

The shipper of a hazardous material must determine the hazard class of the material, including its applicability as an "environmentally hazardous substance (aquatic environment)", assign a proper shipping name, and mark the material according to dangerous goods regulations.

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Transport vehicle requirements

The "Marine Pollutant" mark is required on each bulk packaging that contains a marine pollutant and each vehicle or freight container that contains a package requiring the mark. The mark must be displayed on at least two opposing sides or two ends, excluding the bottom, and must be visible from the direction it faces. The mark may be displayed in black lettering on a square-on-point configuration with the same dimensions as a placard. If the packaging has a capacity of 3,785 L (1,000 gallons) or more, it must be marked on each end and each side.

However, there are exceptions to the requirement to display the marine pollutant mark. If a transport vehicle is already labelled or placarded in accordance with Subpart E or F of Part 172 of the HMR, the mark is not required. Additionally, for domestic transportation, packaging marked before January 1, 2017, in conformance with the requirements in effect on December 31, 2014, may continue to be used until the end of its useful life.

For transportation by highway, rail, or air, the mark is required on bulk packaging containing marine pollutants if they are not already labelled or placarded. If the packaging is labelled or placarded, the mark is not required.

The mark consists of a black symbol of a fish and a tree on a white or suitable contrasting background, with a black border forming a square-on-point. Each side of the mark must be at least 100 mm (3.9 inches) as measured from the outside lines forming the border.

It's important to note that the technical name "Marine Pollutant" is specifically required by the IMDG code for transport by sea. When shipping marine pollutants by road or air, specific proper shipping names must be used, such as "UN 3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, n.o.s." or "UN 3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, n.o.s."

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Bulk packaging capacity rules

The Hazardous Materials Regulations (HMR) require that any non-bulk or bulk packaging containing a marine pollutant must display the marine pollutant marking. However, there are exceptions to this rule.

For non-bulk packages, the marking must be displayed near the hazard warning label and/or the proper shipping name. Non-bulk packages refer to packages with a maximum capacity of 450 L (119 gallons) or less for liquids, a maximum net mass of 400 kg (882 pounds) or less and a maximum capacity of 450 L (119 gallons) or less for solids, or a water capacity of 454 kg (1000 pounds) or less for gases.

For bulk packages, the marking requirements differ based on the package's capacity. If the package has a capacity of less than 3,785 L (1,000 gallons), the marking must be displayed on at least two opposing sides or two ends, excluding the bottom. The marking must be visible from the direction it faces. If the package has a capacity of 3,785 L (1,000 gallons) or more, the marking must be displayed on each end and each side, and it must be visible from the direction it faces.

Additionally, there are exceptions to the marking requirements for bulk packages based on the mode of transportation. When transported by highway, rail, or aircraft, a bulk package that displays a label or placard is exempt from displaying the marine pollutant marking. However, if the bulk package does not display a label or placard when transported by these modes, the marking is required. For vessel transportation, all packages containing marine pollutants, including bulk packages, must display the marine pollutant marking.

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Exceptions to the Marine Pollutant Mark

The Marine Pollutant Mark is required on a container that transports hazardous materials that pose a threat to aquatic life. The symbol, letters, and border must be black on a white background or be of a contrasting colour to the surface on which the marking is displayed.

However, there are exceptions to when the Marine Pollutant Mark is not required:

  • When the packaging of a marine pollutant displays a HazMat label or placard as required by the Hazardous Material Regulations.
  • When the marine pollutant is on board a road vehicle or railway vehicle on a ro-ro ship, or if it is contained in a small means of containment and is in a quantity that is less than or equal to 5 litres for a liquid marine pollutant or 5 kilograms for a solid marine pollutant.
  • When the marine pollutant is shipped in single or combination packaging containing a net quantity per single or inner packaging of 5 litres or less for liquids or having a net mass of 5 kilograms or less for solids.
  • When the marine pollutant is transported by motor vehicle, rail car, or aircraft.
  • When the marine pollutant is transported by vessel, and the packaging has a net quantity of 1.3 gallons (5 litres) or less for liquids or a net mass of 11 pounds (5 kilograms) or less for solids.
  • When the marine pollutant is transported by vessel, and the combination packaging contains a marine pollutant other than a severe marine pollutant, with each inner packaging containing 1.3 gallons (5 litres) or less net capacity for liquids.
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Frequently asked questions

When a container is transporting a marine pollutant, the Marine Pollutant mark must be displayed on each side and end of the container.

The Marine Pollutant mark is a symbol of a fish and a tree. The symbol and border must be black on a white or suitable contrasting background.

The Marine Pollutant mark must be at least 6mm wide and 50mm high for all large means of containment.

Yes, the marking is not required when marine pollutants are on board a road vehicle or railway vehicle on a ro-ro ship, or when the marine pollutant is in a small means of containment and is in a quantity less than or equal to 5L for a liquid or 5kg for a solid. Additionally, if a packaging of a marine pollutant or a transport vehicle containing one displays a HazMat label or placard as required by the Hazardous Material Regulations, the Marine Pollutant mark is not required.

The Marine Pollutant marking is required to identify and classify dangerous goods that are marine pollutants. This helps to ensure proper handling, transportation, and regulation of such substances to protect the aquatic environment.

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