Marine plastic pollution – will nurdles be classified under the IMDG code?

By Jens Jaeger, Policy Forum Liaison, German Insurance Association (GDV) and member of the IUMI Policy Forum and Loss Prevention Committee

This article highlights the spill risk of plastic resin pellets, so called “nurdles”, and work at the IMO to mitigate this risk.

Plastic resin pellets are small granules generally in the shape of a cylinder or a disk with a diameter of a few millimeters. These plastic particles are industrial raw material transported to manufacturing sites where "user plastics" are made by re-melting and molding them into the final products. These pellets - commonly referred to as nurdles - can be unintentionally released into the open environment, both during manufacturing and transport, creating pollution in the oceans and on beaches. The released resin pellets are carried by surface run-off, stream, and river waters eventually to the ocean. Resin pellets can also be directly introduced to the ocean through accidental spills during shipping.

Because of their environmental persistence, a growing production of plastic leads to a measurable increase in plastic pollution in the ocean. Due to the longevity and very slow decomposition rate of plastics, it can take centuries for the material to be broken down by physical, chemical and biological processes in the oceans. How long plastic pellets really linger in the environment is not known. However, due to physical conditions such as wind, waves and currents, plastic pellets can be transported and dispersed over long distances from the point of entry.

In recent years, there has been an increase in shipping accidents involving the release of plastic resin pellets into the marine environment. This has been caused by containers that went overboard during bad weather (e.g. MSC ZOE), losses due to leaking containers (e.g. TRANS CARRIER) as well as ship accidents (e.g. RENA). As a result of these events, the affected states have campaigned in vain to create binding rules for the carriage of nurdles because of their negative effect on the environment. The issue was also raised in the IUMI Political Forum, with the discussion supporting regulatory action.

However, it was the X-Press Pearl accident that provided a new impetus for regulatory action on pellets. On May 20, 2021, the X-Press Pearl caught fire and after 12 days sank off the coast of Sri Lanka. All of the containers were lost or damaged, several of them containing low-density polyethylene (LDPE) pellets which ruptured and coated nearby beaches.

Following the accident, Sri Lanka submitted a paper to the Marine Environment Protection Committee (MEPC 77/8/3) recommending that MEPC consider “the need to amend classification of all pellets, flakes and powders under MARPOL Annexes III and V and the International Maritime Dangerous Goods (IMDG) Code to improve labeling, loading, stowage and handling practices of all ship-bound pellets.” The submission was referred by MEPC to the sub-committee on Pollution Prevention and Response (PPR).

Norway also submitted a proposal to the same sub-committee which enhanced the Sri Lanka submission. That proposal was to amend the criteria for the identification of harmful substances in MARPOL Annex III and to ensure that nurdles are identified as a harmful substance and classified as a Marine pollutant according to the IMDG Code. Norway proposed to transport nurdles under the entry code UN 3077 – environmentally hazardous substance, solid, not otherwise specified (n.o.s.). Such a designation would impact how nurdles are packed within a container by the shipper and where the container is placed within the stow to minimize the risk that if the container is lost or damaged in rough seas and if, damaged, the packaging in the container is robust enough to resist wide disbursement so common in these spills. Critics of the Norwegian proposal argued that classification under the IMDG code would not have prevented the X-Press Pearl spill. Furthermore, the proposal to include nurdles within UN 3077 upsets the harmonized classification scheme for identifying and categorizing dangerous goods.

The PPR Sub-Committee discussed the submitted proposals in the 9th session (4-8 April 2022) and instructed the Correspondence Group on Marine Plastic Litter from Ships to further consider the options for reducing the environmental risk associated with the maritime transport of plastic pellets and to advise the Sub-Committee on the best way forward. The group comprises more than 100 participants from all interested sectors. According to the draft time table the results of the Correspondence Group will be submitted to the sub-committee PPR in January 2023 for its 10th session in April 2023.

The author of this article will participate for IUMI in the Correspondence Group representing the interests of marine insurers.