The carriage of nurdles by sea – packaging requirements to be regulated

In June 2021, the life of X-Press Pearl, a 2-3 month old 1,400+ TEU vessel came to a fiery end when it caught fire off the coast of Sri Lanka and sank in those waters..

The sinking of the Singapore flagged 36,150 DWT container ship attracted a lot of attention especially due to concerns over the environmental damage the loss of 81 containers of hazardous goods, 25 tonnes of nitric acid, 348 tonnes of oil, and upto to 75 billion small plastic pellets known as nurdles that were on board the ship..

Nurdles, made from oil and gas by petrochemical companies, are small pieces of plastic building blocks used to make almost all plastic products like bags, packaging, and even airplane interiors.. Nurdles are transported from factories to distributors across the globe by truck, train, or ship, often in containers..

When they end up in the ocean, nurdles, like polypropylene and polyethylene float and spread out carried by wind and currents.. They can harm marine life through ingestion, releasing harmful additives, or carrying pollutants and invasive organisms..

The spillage of nurdles from the X-Press Pearl is said to have been dispersed over 300 kms across the Sri Lankan coastline and many dead fish and turtles washed up on the shores of Negombo beach in Sri Lanka with bloated bellies and the plastic pellets stuck in their gills and bodies sparking environmental concerns and also concerns about the livelihood of fishermen in the area..

IMO on nurdle transportation

The X-Press Pearl issue along with the loss of around 13 tonnes of nurdles in 2020 in Norway/Sweden and the loss of 6 containers off the Cape Agulhas in South Africa led the IMO to agree to a draft MEPC circular on recommendations for the carriage of plastic pellets by sea in freight containers..

The draft text is expected to be presented to the Sub-Committee on Carriage of Cargoes and Containers (CCC 9, meeting from September 20-29) for review.. The draft suggests using high-quality packaging for plastic pellets to prevent losses during transport due to vibrations or other forces..

It also states that freight containers carrying plastic pellets should be clearly labeled and properly stowed to minimize environmental risks while ensuring ship and crew safety..  Ideally, these containers should be stowed under the deck or in sheltered areas of exposed decks..

The PPR Sub-Committee has asked Member States and international organizations to submit packaging information to the CCC Sub-Committee..

It was agreed that plastic pellets should not be shipped in bulk, and the Sub-Committee encourages the submission of proposals for necessary regulatory changes to future sessions..

Furthermore, the Sub-Committee approved the development of a draft guide for addressing plastic pellet spills from ships by a correspondence group, which will be considered at the PPR 11 session..

Regulatory options for nurdle transportation

As per a report detailing a feasibility analysis of regulatory options for preventing spills of plastic pellets, The Correspondence Group on marine plastic litter from ships has explored three regulatory options to reduce environmental risks tied to the maritime transport of plastic pellets:

1. Assigning a new UN number for plastic pellets transported in freight containers at sea.
2. Amending Appendix I of MARPOL Annex III to classify plastic pellets as a “harmful substance,” subjecting their transport to the IMDG code.
3. Creating a new chapter in MARPOL Annex III, specifying requirements for plastic pellet transport in freight containers without classifying them as harmful substances or dangerous goods.

None of these options entirely eliminate the risks of containers with pellets falling overboard or pellets being released into the marine environment.. A new chapter, as proposed, would reduce the risk of containers falling overboard by requiring their stowage in lower-risk slots, provided this new legal instrument can be enforced..

The other two options address the risk of pellet release during routine operations and after incidents, with a higher likelihood of enforcement as they build upon existing legal instruments..

Assigning a new UN number is likely to take longer than the other options, potentially taking five years or more after IMO approval, whereas the other options could be enforced in under two years.. All options are feasible to implement with manageable impacts throughout the transport chain..

While increased costs for notification, packaging, and stowage are expected, they will be offset by reduced cleanup costs, lower insurance premiums, and decreased environmental damage.. The feasibility of these options depends on their consequences on packaging, stowage, and landside operations (i.e., handling, storage, and transport)..

An amendment to Appendix I of MARPOL Annex III has limited packaging requirements and no mandatory stowage requirements.. As a result, the additional costs to comply with the amendment are expected to be the least of the regulatory options considered in the report..

Introducing a new UN number is expected to require the most significant changes in the transport chain, affecting both maritime and land transport and involving more supply chain players, making it more difficult and costly..