Q.01

What is MARPOL?

MARPOL is the International Convention for the Prevention of Pollution from Ships. The International Maritime Organization (IMO) describes it as "the main international convention covering prevention of pollution of the marine environment by ships from operational or accidental causes." It was adopted at the IMO on 2 November 1973. According to the IMO, it applies to 99% of the world's merchant tonnage.

Approach: The regulatory datasets I can search don't include the MARPOL convention text, so this comes from the IMO's official convention pages.

How it developed (per the IMO)

  • 1973: the Convention is adopted.
  • 1978 Protocol: adopted after a series of tanker accidents in 1976-1977. The Convention and the Protocol came into force together as one instrument on 2 October 1983.
  • 1997 Protocol: added Annex VI, which came into force on 19 May 2005.

The six technical Annexes

AnnexSubjectIn forceKey points (IMO wording)
IOil2 Oct 1983Covers both operational and accidental discharges; requires double hulls for tankers
IINoxious liquid substances in bulk2 Oct 1983 (provisions effective 6 Apr 1987)About 250 substances evaluated; "no discharge of residues containing noxious substances is permitted within 12 miles of the nearest land"
IIIHarmful substances carried by sea in packaged form1 Jul 1992Standards for packing, marking, labelling, documentation and stowage of marine pollutants
IVSewage27 Sep 2003Discharge is prohibited unless it goes through an approved treatment plant or happens "more than three nautical miles from the nearest land"
VGarbage31 Dec 1988Sets distances from land and the allowed ways of disposal; "complete ban imposed on the disposal into the sea of all forms of plastics"
VIAir pollution19 May 2005Limits on sulphur oxide and nitrogen oxide emissions; energy-efficiency measures to cut greenhouse gases

If you work in chemicals or product stewardship, Annex II (bulk liquid cargoes) and Annex III (packaged marine pollutants) are the parts most likely to apply to you. MARPOL is a shipping and transport instrument, so it is separate from supply classification rules such as CLP/GHS. I can look up a specific Annex in more detail if that helps.

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Q.02

What do its annexes cover?

MARPOL has six technical Annexes, each covering one type of pollution from ships: oil (I), noxious liquid substances carried in bulk (II), harmful substances in packaged form (III), sewage (IV), garbage (V) and air pollution (VI). Each one sets its own discharge or emission rules. The detail below is from the IMO's official MARPOL page.

Approach: None of the regulatory datasets I can search hold the MARPOL text, so this comes from the IMO's convention page. That page summarises each Annex; it does not reproduce the full regulations.

Annex I: Oil (in force 2 October 1983)

  • Covers oil pollution from routine operations and from accidental discharges.
  • The 1992 amendments made double hulls "mandatory for new oil tankers." They also set a phase-in schedule for existing tankers, which was revised in 2001 and 2003.

Annex II: Noxious liquid substances in bulk (in force 2 October 1983; provisions took effect 6 April 1987)

  • Sets the discharge criteria and pollution controls for noxious liquids carried in bulk. Some 250 substances were evaluated and included.
  • Residues may be discharged "only to reception facilities until certain concentrations and conditions (which vary with the category of substances) are complied with."
  • In any case, "no discharge of residues containing noxious substances is permitted within 12 miles of the nearest land."

Annex III: Harmful substances in packaged form (in force 1 July 1992)

  • Contains general requirements for issuing detailed standards on packing, marking, labelling, documentation, stowage, quantity limits, exceptions and notifications.
  • "Harmful substances" means substances identified as marine pollutants in the IMDG Code, or that meet the criteria in the Appendix to Annex III.

Annex IV: Sewage (in force 27 September 2003)

  • Discharging sewage into the sea is prohibited, with two exceptions:
    • the ship has an approved sewage treatment plant in operation; or
    • the sewage has been comminuted (ground up) and disinfected using an approved system, and is discharged more than three nautical miles from the nearest land.
  • Sewage that is not comminuted or disinfected "has to be discharged at a distance of more than 12 nautical miles."

Annex V: Garbage (in force 31 December 1988)

  • Covers the different types of garbage and sets how far from land, and in what way, each may be disposed of.
  • The IMO calls its most important feature "the complete ban imposed on the disposal into the sea of all forms of plastics."

Annex VI: Air pollution (in force 19 May 2005)

  • Limits sulphur oxide (SOx) and nitrogen oxide (NOx) emissions from ship exhausts.
  • Prohibits deliberate emissions of ozone-depleting substances.
  • In designated emission control areas, stricter standards apply to SOx, NOx and particulate matter.
  • A chapter adopted in 2011 added mandatory technical and operational energy-efficiency measures to cut greenhouse gas emissions from ships.

For chemicals work, Annex II applies to bulk liquid cargoes. Annex III applies to packaged goods and relies on the IMDG Code's marine-pollutant identification, which is a transport classification and separate from CLP/GHS supply classification.

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Q.03

When are garbage placards required?

Under MARPOL Annex V, regulation 10.1 says that every ship of 12 m or more in length overall, and every fixed or floating platform, "shall display placards which notify the crew and passengers of the discharge requirements" of regulations 3, 4, 5 and 6 of the Annex, as applicable. Ships under 12 m length overall are outside this requirement. The US applies a stricter rule of its own (33 CFR 151.59), with lower length thresholds.

Approach: The regulatory datasets I can search don't cover MARPOL or shipping garbage rules, so this comes from IMO resolutions and the US eCFR. I read the Annex V text as revised by resolution MEPC.201(62), which entered into force on 1 January 2013, not a consolidated text with later amendments. The IMO's current garbage page gives the same placard trigger.

MARPOL Annex V, regulation 10.1 (mandatory)

  • Who: every ship of 12 m or more in length overall, and fixed or floating platforms.
  • Content: the discharge requirements of regulations 3 to 6. These cover the general prohibition, the plastics and cooking oil bans, discharges outside special areas, discharges from platforms (and within 500 m of them), and discharges within special areas.
  • Language: the working language of the crew. Ships on voyages to ports or offshore terminals of other Parties "shall also" have them in English, French or Spanish (reg. 10.1.2).

IMO 2017 implementation guidelines (resolution MEPC.295(71), recommended practice: "should")

  • Wording: a summary of the prohibitions and restrictions on discharging garbage, plus the possible penalties for not complying (para 4.4).
  • Size and material: at least 12.5 cm by 20 cm, durable, and replaced when damage or wear makes them hard to read (4.4.1).
  • Where: places where crew work and live, and where garbage bins are. Examples given are the galley, mess room(s), wardroom, bridge and main deck. They should be at line-of-sight height (4.4.2).
  • Passenger ships: also in cabins and in all recreational deck areas open to passengers (4.4.3).

United States (33 CFR 151.51(e) and 151.59)

Placards are required on:

  • manned US ships 26 feet or more in length (other than drilling rigs or platforms);
  • manned floating drilling rigs or other platforms in transit under US jurisdiction;
  • manned foreign ships 40 feet or more in length while in US navigable waters or the US Exclusive Economic Zone.

The requirements:

  • Display: the master or person in charge "shall ensure" placards are displayed in prominent locations, in enough numbers for crew and passengers to read them. The Captain of the Port may require more placards and specify where they go.
  • Size: each placard "must" be at least 20 cm (8 in) wide by 12½ cm (5 in) high, durable and legible.
  • Content: each placard must cover the operating requirements of §§ 151.67 to 151.73 that apply to the ship. It should also state four things:
    • discharging garbage is prohibited except where specifically allowed;
    • discharging any form of plastic into any waters is prohibited;
    • violators face civil and/or criminal penalties;
    • regional, state and local restrictions may also apply.
  • Great Lakes: ships operating there may instead use the alternative Great Lakes wording in § 151.59(d).

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Q.04