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Marine pollutants are hazardous materials that pose a threat to aquatic life. These materials are regulated during transportation, especially when transported by water, regardless of packaging size. A material is identified as a marine pollutant 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 IMDG Code provides a list of marine pollutants, including acetaldehyde, mercury-based pesticides, and organotin compounds. When transporting marine pollutants, specific labelling requirements must be followed, such as marking the packaging with the Marine Pollutant symbol (a fish and tree in black and white) and providing proper shipping names. These regulations help prevent dangerous spills and accidents, ensuring the safety of our marshes and seas.
| Characteristics | Values |
|---|---|
| Definition | Materials that pose a risk to aquatic ecosystems |
| Identification | If listed in the IMDG Code Index or if it meets the criteria for classification as "Environmentally Hazardous Substance (aquatic environment)" |
| Marking | The symbol is a black fish and tree on a white or suitable contrasting background |
| Marking size | At least 100 mm (3.9 inches) for non-bulk packages |
| Marking exceptions | Non-bulk packages transported by motor vehicle, rail car, or aircraft; packages of limited quantity; packages under 5L for liquids or 5kg for solids; combination packaging containing a non-severe marine pollutant |
| Packaging capacity | If the packaging has a capacity of 3,785 L (1,000 gallons) or more, it must be marked on each end and side |
| Shipping papers | For materials that are marine pollutants, the words "Marine Pollutant" must be entered on the shipping paper |
| Severe marine pollutants | Materials are identified as severe marine pollutants (PP) in Appendix B to § 172.101 if they are packaged in a concentration that equals or exceeds 1% by weight of the solution or mixture |
| Examples | Acetaldehyde, mercury-based pesticides, organotin compounds, phenylmercuric compounds, etc. |
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What You'll Learn
Marine Pollutant Labels
The IMDG Code Index serves as the primary reference for identifying marine pollutants. If a substance is listed in this index or meets the aquatic environmental hazard criteria, it is designated as a marine pollutant. In some cases, additional guidelines, such as the General Introduction of the IMDG Code, provide supplementary criteria for classifying materials as marine pollutants.
The regulations specify that the name of the component responsible for making a material a marine pollutant must be marked on the package in association with the proper shipping name. If the shipping name explicitly identifies the component, adding it separately in parentheses is not necessary. However, if two or more components contribute to the marine pollutant designation, the names of at least two predominant components must be included in parentheses.
The "MARINE POLLUTANT" mark itself has specific design requirements. It must feature a symbol of a fish and a tree, with black colouring on a white or suitably contrasting background. The marking should be in the shape of a square-on-point, with each side measuring at least 100 mm (3.9 inches). This ensures visibility from the direction the mark faces.
Additionally, there are exceptions to the marine pollutant labelling requirements. Non-bulk packagings transported by motor vehicle, rail car, or aircraft are generally exempt from these requirements. Similarly, when transported by vessel, bulk packaging does not need to display the marine pollutant marking. Limited quantity materials marked accordingly are also exempt. Furthermore, when transported by vessel, single or combination packagings with a net quantity of 5 litres or less for liquids or 5 kg or less for solids are not required to bear the marine pollutant marking.
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Hazardous Materials
Marine Pollutants are hazardous materials that pose a threat to aquatic life. They are regulated during transportation, and these regulations may apply even if the hazardous material is not being transported by vessel. Marine Pollutants are typically referred to as 'Environmentally Hazardous Substances' in other dangerous goods regulations such as ADR and IATA.
The shipper of a hazardous material must determine the hazard class of the material, including its applicability as an "Environmentally Hazardous Substance (aquatic environment)". They must then assign a proper shipping name that best describes the material and mark the material accordingly.
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. A list of common environmentally hazardous substances or marine pollutants can be found in the IMDG Code Index.
For a mixture to be classified as a Marine Pollutant, GHS mixture classification principles or laboratory testing are usually applied. If a mixture is a marine pollutant and meets the classification criteria for inclusion in another hazard class, it should be declared under the most appropriate UN number and proper shipping name relevant for that hazard.
The MARINE POLLUTANT mark must conform to the following:
- The symbol (fish and tree) must be black on a white or suitable contrasting background.
- The marking must be in the form of a square-on-point.
- The width of the border forming the square-on-point marking must be at least 2 mm.
- Each side of the mark must be at least 100 mm (3.9 inches) as measured from the outside of the lines forming the border for non-bulk packages.
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Marine Pollutant Mark
The Marine Pollutant Mark is a widely recognised symbol that features a black "fish and tree" design on a white or suitable contrasting background. This symbol is enclosed within a square-on-point configuration, with each side measuring at least 100 mm (3.9 inches). The width of the border forming the square-on-point marking must be at least 2 mm.
The placement of the Marine Pollutant Mark depends on the mode of transportation and the type of packaging. For vessel transportation, the mark is generally not required on single or combination packagings with a capacity of 5 litres or less for liquids or 5 kg or less for solids. However, when the packaging has a capacity of 3,785 L (1,000 gallons) or more, the Marine Pollutant Mark must be displayed on each end and side of the packaging, with the mark visible from the direction it faces.
For bulk packaging, freight containers, or transport vehicles, the Marine Pollutant Mark is typically displayed on each side and end of the container or vehicle. This ensures that the mark is easily visible. The mark may be displayed in black lettering on a white square-on-point configuration, maintaining the same dimensions as a placard.
It is important to note that the regulations provided here may be subject to updates and changes over time. Therefore, it is always advisable to refer to the latest official guidelines and regulations for accurate and current information regarding the use of the Marine Pollutant Mark.
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Packaging Requirements
The International Maritime Dangerous Goods Code (IMDG Code) establishes regulations for the transportation of marine pollutants and environmentally hazardous substances. Marine pollutants are denoted with a "P" in the Dangerous Goods List of the IMDG Code.
If a package contains a marine pollutant, it must be marked with the "Marine Pollutant" label, except when displaying a HazMat label or placard as required by the Hazardous Material Regulations. The "Marine Pollutant" mark must feature a symbol of a fish and tree in black and white or another suitable contrasting colour combination. The mark must be in the form of a square-on-point and be visible from the direction it faces.
For non-bulk packages, the "Marine Pollutant" mark is required only if the package size can accommodate it. If the package is too small, the mark's dimensions and line thickness may be reduced, provided that the marking remains clearly visible.
For bulk packages, the "Marine Pollutant" mark is required if the packaging capacity is 3,785 L (1,000 gallons) or more. The mark must be displayed on each end and side of the packaging.
If a package contains a marine pollutant in quantities less than five litres or five kilograms, it is not regulated under the IMDG Code or ADR regulations. However, IATA regulations require Env Haz labels for UN Numbers UN3077 and UN3082, unless the package contains less than or equal to five litres or five kilograms.
For vessel transportation of non-bulk packaging containing a marine pollutant, the name of the component that makes the material a marine pollutant must be marked on the package in parentheses in association with the proper shipping name. If two or more components are present, the names of at least two of the predominant contributors to the marine pollutant designation must be included.
For combination packaging containing a marine pollutant, each inner packaging must have a net capacity of five litres or less for liquids or five kilograms or less for solids.
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Aquatic Ecosystems
Marine pollutants are materials that pose a risk to aquatic ecosystems. The US Department of Transportation (US 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 threshold for most materials is a 10% concentration of Appendix B chemicals, while "severe marine pollutants" are regulated at a 1% concentration.
The IMDG Code, a set of guidelines from the International Maritime Organization, is used by international authorities to identify marine pollutants. 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 of the IMDG Code. 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 contains a designated marine pollutant, the material must be evaluated according to IMDG 2.9.3. This evaluation helps determine if the substance meets the criteria for classification as an "Environmentally Hazardous Substance (aquatic environment)." Aquatic toxicity data, degradation data, and BCF data are crucial for this classification.
To ensure compliance with regulations, shippers offering hazardous materials for transport must determine the hazard class of the material, including its applicability as an "Environmentally Hazardous Substance (aquatic environment)." They must then assign a proper shipping name and mark the material accordingly. The marking requirements for marine pollutants are specified in 49 CFR 172.322. For example, the MARINE POLLUTANT mark, featuring a fish and tree symbol, is required on packages with a capacity of 3,785 L (1,000 gallons) or more. However, if a package or transport vehicle displays a HazMat label as required by the Hazardous Material Regulations, it is exempt from displaying the marine pollutant mark.
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