US and international shipping regulations require that shippers determine if shipments contain marine pollutants and, if so, comply with additional safeguards. Manufacturers and importers of chemical substances often need to determine if they products are regulated as marine pollutants for the purposes of preparing Safety Data Sheets (SDS). Information on transportation regulations applicable to a product are found in Section 14 of a standard SDS.
For shippers in the US, Marine Pollutants are listed chemicals or materials found in the U.S. Hazardous Materials Regulations (49 CFR Parts 100-180) promulgated by the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Marine pollutant is a material which is listed by PHMSA and, when in a solution or mixture of one or more marine pollutants is packaged in a concentration which equals or exceeds:
(1) 10% by weight of the solution or mixture for materials listed as marine pollutants; or
(2) 1% by weight of the solution or mixture for materials that are identified as severe marine pollutants.
Outside the US, the International Maritime Dangerous Goods Code requires that shippers determine whether a chemical or material is a marine pollutant based on its classification in the Dangerous Goods List, or the IMDG Code Index, or that if meets the criteria for classification as an “Environmentally Hazardous Substance (aquatic environment). A substance is classified as a Marine Pollutant if it meets the criteria for acute and/or chronic toxicity thresholds for aquatic life.
Caltha LLP provides technical support to shippers, and to manufacturers and importers of chemical substances to determine applicable regulations and to prepare cost effective compliance management programs. Caltha also prepares Safety Data Sheets for clients to comply with new OSHA Globally Harmonized Standard (GHS) format for evaluating, classifying, and communicating hazards associated with chemical substances.