Alignment of Marine Pollutants and Environmentally Hazardous for Transport
Environmentally Hazardous for Transport has been based on GHS criteria for some time now with a product classification of Environmental Hazard Chronic Category 1 or 2, or Acute Category 1 meaning the product is environmentally hazardous for transport: Class 9 (if not meeting other transport hazard criteria which overides or modifies this Class).
In most cases the terms Marine Pollutant and Environmentally Hazardous are used interchangeably (which can be a bit confusing!). There is one specific area of difference to draw attention to. It’s a hang over from previous regulation in the IMDG code relating to substances marked with ‘P’ in Annex III of Marpol. Such substances are also considered to be environmentally hazardous for transport, even if they do not meet GHS criteria of EH C1, EH C2 or EH A1. The list of materials is no longer being extended and, with approval of the competent authority, substances which no longer meet the criteria for environmentally hazardous but remain on the list need not be transported as marine pollutants.
The change to Formpak transport classification methods for mixtures is that the assignment of phrase ‘MP’ = Marine Pollutant to ingredients of the mixture will no longer impact the transport classification of a mixture (previously >10% of MP caused a classification of environmentally hazardous). However, if ‘MP’ is assigned to a substance, it will still impact the transport classification in the way it always has which is to make the substance Environmentally Hazardous for transport.