You may have read our previous blog post with regards to the new exception for goods contained in packages and inner packagings of 5 L or 5 kg or less, to no longer require shipping as a marine pollutant or as environmentally hazardous.
This effectively means, that substances and mixtures which display no other hazards and therefore classed as UN 3082 for liquids, or UN 3077 for solids, are no longer treated as dangerous goods. This is subject to certain provisions being met, outlined in each applicable set of regulations for the relevant mode(s) of transport.
What may not be immediately clear, however, is how these changes apply to other parts of the transport operation, such as the marking and placarding of Cargo Transport Units (CTUs).
The IMDG Code Amendment 37-14, which is currently voluntary and becomes mandatory from 1st of January 2016, applies the new marine pollutant rule as a specific provision in 184.108.40.206.
This means that even ‘fully regulated’ packages, with other hazards, will no longer be required to display marine pollutant marks or be described as such in the dangerous goods note, when presented in packages or inner packagings of 5 L or 5 kg or less.
Because the inner packagings of limited quantity packages are always 5 L or 5 kg or less, this effectively means that limited quantity goods, even those displaying other hazards, will no longer be considered to be marine pollutants. This has required some ‘tidying up’ of the limited quantity provisions in Chapter 3.4, including the deletion of provision 220.127.116.11.3 that required the marine pollutant placard to be displayed on CTUs.
We hope you find the following video useful to clarify and explain the placarding requirements for CTUs, as currently applicable voluntarily and mandatory from 1st January 2016.
This video has been taken from our IMDG General Awareness e-Learning Course.