The regulatory work now focuses on notification to the carrier so that containers containing plastic pellets can be identified quickly to aid recovery, packaging requirements for plastic pellets inside the freight container, and stowage requirements for containers containing plastic pellets in order to reduce the risk of large nurdle spills like those experienced in recent years, as reported by Gard.
Various proposals and approaches
Sri Lanka has proposed to classify plastic pellets or “nurdles” as dangerous cargo after a catastrophic spill in 2021. The International Maritime Organization’s Pollution Prevention and Response Sub-Committee discussed various proposals on regulating the carriage of nurdles at PPR 9 and sent them to a correspondence group for refinement. The group’s report outlines different approaches, including classifying nurdles as dangerous cargo subject to regulation or continuing voluntary industry-initiated programs. The pros and cons of each approach are discussed ahead of the PPR 10 meeting in April.
A brief refresher on nurdle spills
Nurdles, small plastic pellets used to make various plastic products, are transported by land and sea to manufacturers and distributors. While most end up in the ocean from land-based sources, spills from containers lost at sea also occur. Nurdle spills have serious environmental impacts, with the worst occurring in Sri Lanka in 2021, causing extensive damage to marine life and the coastline. Nurdles persist in the environment, making cleanup difficult and costly. Regulating carriage conditions to reduce the risk of spills is necessary to prevent further harm.
The work of the PPR Correspondence Group on plastic pellets
Norway led the Correspondence Group (CG) through three rounds of discussion and commentary. The main discussion points in the third round included:
- Refinement of the wording of packaging, notification, and stowage recommendations to be issued as a Circular by the Subcommittee on Carriage of Cargoes and Containers (CCC) as an immediate and interim measure.
- Whether to make carriage conditions mandatory and how to do so. Three options for mandatory regulation were discussed and participants were asked which option they favoured.
Draft interim guidelines – discussion of the elements of the proposed CCC Circular
The CG as a whole firmly backed proposals that would be implemented right away and only until necessary prerequisites were met. The IMO Subcommittee on Carriage of Cargoes and Containers intends to submit the proposals as a circular, and the CG’s task was to develop a draught for further discussion within a PPR 10 working group, subject to revisions that the CCC may make.
Following the first and second rounds, the primary measures to reduce the risk of spills were widdled down to:
- Packaging requirements/recommendations for plastic pellets within the freight container
- Requirements/recommendations for notifying the carrier so that containers containing plastic pellets can be identified quickly to aid in recovery
- Stowage requirements/recommendations for containers containing plastic pellets
First order of business – defining nurdles subject to the carriage recommendation
The European Chemical Industry Council (CEFIC) representing the European petrochemical segment proposed a definition of nurdles:
“Plastic pellets means [(a) solid polymeric substances, or blended mixtures (consisting of polymers and other substances of varying percentages), that are insoluble in water and transported in granule or nurdle form, or as powder or flakes; that (b) have a diameter of 5 mm or less. Plastic pellets include, but are not limited to, polymers such as polyethene, polypropylene, polystyrene, polyethene terephthalate, or polyvinyl chloride including a size limitation to 5 millimetres which is the boundary for microplastics.”
Participants in the Correspondence Group agreed to include a definition for nurdles, but disagreed with the proposed size limitation of 5mm, as spills of larger pellets could also cause environmental harm and be difficult to clean up. They also noted that a size limit could incentivize manufacturers to slightly increase the size of their nurdles to avoid regulation.
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