Tag: MARINE POLLUTANT

UN 3077, 3082 – Always Marine Pollutant?

Question asked by many is

  1. Whether UN 3077, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. & UN 3082 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S. can only be used for marine pollutants?
  2. or Why there is no letter P in dangerous goods list identifying these entries as marine pollutant?

 

MARINE POLLUTANT/ENVIRONMENTALLY HAZARDOUS SUBSTANCE
MARINE POLLUTANT/ENVIRONMENTALLY HAZARDOUS SUBSTANCE

For guidance

  • If a substance meet the provisions of section 2.9.3, of IMDG Code, then it is a marine pollutant
  • If a substance do not meet the provisions of section 2.9.3, of IMDG Code, but transported under 3077 or 3082 then it is not a marine pollutant.
  • If a substance is identified as marine pollutant by IMDG Code but no longer meets the provisions of classification as per section 2.9.3, of IMDG Code, then it can be transported as non-marine pollutant with the approval of competent authority.
  • Basel waste which does not meet any criteria of IMDG Code can also be transported under UN 3077 or 3082

 

 

MARINE POLLUTANTS

IMDG Code identifies a substance, material or article as MARINE POLLUTANT with the criteria based on those developed by the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), as amended. This criteria is listed in Appendix to Annex III of MARPOL.

Marine pollutants are identified with letter “P” in column 4 of dangerous goods list in chapter 3.2

MARPOL Annex III deals with ‘Regulations for the Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form’. This regulation deals with Application, Packing, Marking and labelling, Documentation, Stowage, Quantity limitations, Exceptions & Port State control on operational requirements. In this article we will look at Annex III requirement for, Marking and labelling and Documentation; regulations 3 & 4 respectively.

Marking and labelling

Every package containing marine pollutant shall be marked with correct technical name and marine pollutant mark. These marks and label shall be so durable that information will still be identifiable on packages surviving at least three months’ immersion in the sea.

Symbol (fish and tree): black on white or suitable contrasting background

Dimensions at least 100 mm × 100 mm

Exception: for packages, single packagings and inner packagings of combination packagings containing

– a net quantity of 5 l or less for liquids; or a net mass of 5 kg or less for solids.

Documentation

If the cargo is a marine pollutant Dangerous Goods Declaration must indicate this with words ““MARINE POLLUTANT”. Also if the cargo is under a generic or N.O.S. entry then proper shipping name shall be supplemented with technical name.

Examples for technical name supplementing proper shipping name for N.O.S. and Generic entries:-

“UN 1993, FLAMMABLE LIQUID, N.O.S. (propyl acetate, di-n-butyltin-di-2-ethylhexanoate), class 3 PG III (50 °C c.c.) MARINE POLLUTANT”

“UN 1263, PAINT (triethylbenzene), class 3 PG III (27 °C c.c.) MARINE POLLUTANT”

Globally Harmonized System of Classification a...
Globally Harmonized System of Classification and Labelling of Chemicals (GHS) pictogram for environmentally hazardous substances (Photo credit: Wikipedia)
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MARPOL

International Convention for the Prevention of Pollution from Ships (MARPOL), 73/78, is a combination of two treaties adopted in 1973 and 1978 by International Maritime Organisation.

This convention includes regulations to prevent and minimize pollution from ships. It has six annexes as below.

Annex I   

Regulations for the Prevention of   Pollution    by Oil

Annex II    

Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk

Annex III   

Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form

Annex IV   

Prevention of Pollution by Sewage from Ships

Annex V 

Prevention of Pollution by Garbage from Ships

Annex VI    

Prevention of Air Pollution from Ships

IMDG Code 35-10 & MARPOL

MARPOL Annex III , Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form,  is reproduced in IMDG Code 35-10 section 1.1.2.2.  Annex III has 8 regulations and an Appendix as below

Regulation 1       = Application

Regulation 2       = Packing

Regulation 3       = Marking and Labelling

Regulation 4       = Documentation

Regulation 5       = Stowage

Regulation 6       = Quantity Limitation

Regulation 7       = Exceptions

Regulation 8       = Port State control and operational  requirements

Appendix

CRITERIA FOR THE IDENTIFICATION OF HARMFUL SUBSTANCES IN PACKAGED FORM

For the purposes of this Annex, substances identified by any one of the following criteria are harmful substances:

Section 2.9.3 of IMDG Code 35-10 sets out the classification criteria for Environmentally hazardous substances (aquatic environment)

Chapter 2.10 defines Marine pollutants as “substances which are subject to the provisions of Annex III of MARPOL 73/78, as amended”

Index of IMDG Code 35-10 and Column 4 in Dangerous Goods Lists in chapter 3.2 identifies Marine Pollutants with symbol P.

However when a substance, material or article possess the properties of  marine pollutant but not identified in IMDG Code as such it shall be transported according to the relevant provisions for carriage of marine pollutants.

Packages containing marine pollutants must be marked with the recognized chemical name of the marine pollutant and bear the Marine Pollutant mark set out in section 5.2.1.6.3 of IMDG Code 35-10 which is shown below

dimensions shall be at least 100 mm × 100 mm, except in the case of packages of such dimensions that they can only bear smaller marks.

However single packagings and combination packagings  having :
– a net quantity of 5 l or less for liquids; or
– a net mass of 5 kg or less for solids

need not be marked.

Containers containing marine pollutants must be marked with marine pollutant mark having minimum dimensions of 250 mm x 250 mm one on each side and one on each end of the container even if the container contains packages not required to bear the marine pollutant mark