Our online hazmat training specialists are often asked if marine pollutants in non-bulk packaging are regulated as hazardous materials. The answer is not so simple: it depends:
The regulation of a marine pollutant depends on the mode of transport used. In addition, it depends on the net capacity of the packaging the material is offered in. Therefore, under certain conditions, marine pollutants are unregulated by the 49 CFR and international regulations. By all modes, there are exceptions for shipping smaller amounts of marine pollutants.
So, let’s start by defining a couple of terms.
What is a Marine Pollutant?
Marine pollutants are a bit tricky to define. PHMSA defines marine pollutants in 49 CFR by providing a list of substances in Appendix B, the Hazardous Materials Table.
Solutions or mixtures with 10% concentration of a listed substance (1% concentration for severe marine pollutants) are defined as marine pollutants. Therefore, IMO defines a marine pollutant in the List of Dangerous Goods in the IMDG Code or a substance that meets the classification criteria in IMDG 2.9.3. IATA defines a marine pollutant as a substance that meets the classification criteria in the UN Model Regulations 2.9.3.
What is a Non-Bulk Packaging?
Non-bulk packaging is defined as packagings with a maximum mass/capacity. For liquid, that maximum is 450 L (119 gallons) or less, and 400 kg (882 lbs) or less for solids. Online hazmat training teaches us that marine pollutants are shipped in all types of packagings including combination packagings, drums, bags, and small tanks.
What Are The Exceptions?
No matter the regulations used when offering a shipment for transport, marine pollutants are excepted from the hazardous material regulations when offered in the following formats:
- Single or combination packagings containing a net quantity per single or inner packaging of 5 L or less for liquids
- Single or combination packagings containing a net quantity per single or inner packaging having a net mass of 5 kg or less for solids
These exceptions are found in 49 CFR §171.4, IMDG 2.10.2.7, and IATA special provision A197. Furthermore, 49 CFR §171.4(c) states that non-bulk packages are unregulated unless offered for vessel transport.
Packagings used for the 5L/5kg exception must meet some of the general packing requirements:
- Firstly, the packaging must be of good quality that is strong enough to withstand the normal conditions of transport.
- Secondly, The substance must be compatible with all parts of the packaging. Otherwise, no labels, markings, or hazmat shipping papers are required for these shipments.
Interested in Learning More About Marine Pollutants And Packaging? Contact Hazmat University Today!
Hazmat University offers a full line of online hazmat training courses taught by the most experienced industry professionals. If you are interested in becoming a certified hazmat employee or simply want to learn more about online hazmat training, contact us today at (844) 329-5618 or visit our contact page. Our dangerous goods specialists are ready to help you be confident, competent, and compliant.
