Guest blogger Falco Martin, Fauna and Flora gives an update on the progress from the International Maritime Organisation to prevent pellet pollution
Falco Martin, Programme Officer, Marine Plastics and has been following discussions at the International Maritime Organization (IMO) and is advocating to stop this preventable pollution spilling into our ocean.
Following multiple maritime incidents that resulted in the spilling of billions of plastic pellets to the environment, the International Maritime Organization has begun a process to tackle this pervasive, but entirely preventable form of pollution, which we described in our previous blog.
Despite the current efforts, progress remains slow and the plastic pellet spill of December 2023 that impacted the Atlantic coast of the Iberian Peninsula highlighted once again that regulation is urgently needed to reduce the environmental risk associated with the maritime transport of plastic pellets.
Latest progress: Finalisation and adoption of voluntary recommendations on the carriage of plastic pellets at sea
The latest meeting of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR 11) in February, finalised recommendations for the carriage of plastic pellets by sea in freight containers. This circular, while voluntary, outlines measures to prevent loss at sea. Following its finalisation, the circular was submitted for urgent review and approval by the Marine Environment Protection Committee at their 81st session (MEPC 81) in March, which resulted in its adoption, a great win towards reducing this form of pollution.
A win for defining pellets to ensure it covers all forms and types of plastic
Despite the decision not to include a reference to the IMDG code (an international code system used in the transport of dangerous packaged goods at sea to ensure safety and prevent environmental pollution, detailing requirements such as how the goods should be packaged, stowed), in the circular with regards to the packaging of plastic pellets, which would have significantly strengthened the packaging requirements, the improvement of the definition used to define pellets ensured that all forms and type of pellets (regardless of their size, shape, type and source) are adequately captured.
The final definition adopted for plastic pellets, which mirrors language in the previously adopted OSPAR recommendation on the reduction of plastic pellet loss into the marine environment (OSPAR 2021/06), reads as follows "Plastic pellets means a mass of pre-formed moulding material, having relatively uniform dimensions, used as feedstock in plastic product manufacturing operations. Plastic pellets are transported in various forms, including flakes, granules and powders and can be referred to as resin or nurdles.”
Implementing pellet loss prevention
Implementing this voluntary guidance correctly will help prevent incidents like the devastating spill off the coast of Galicia, Spain, last December. We now look to both States and regions to incorporate this guidance into domestic laws and regulations and critically, await feedback and learnings from the implementation of the circular to further guide the development of much-needed mandatory IMO measures. In the meantime, the plastic industry should demonstrate their voiced support for ending pellet loss at sea by ensuring that the relevant preventative measures included in the circular – namely: improved packaging, stowage and shipping notifications – are put in place to ensure plastic pellets are not lost during shipping.
Recommendations from the pellets circular
The following actions are included in the recommendations for the carriage of plastic pellets by sea in freight containers:
- Plastic pellets should be packed in good quality packaging which should be strong enough to withstand the shocks and loadings normally encountered during transport. Packaging should be constructed and closed to prevent any loss of contents which may be caused under normal conditions of transport, by vibration or acceleration forces.
- Transport information should clearly identify those freight containers containing plastic pellets. In addition, the shipper should supplement the cargo information with a special stowage request requiring proper stowage.
- Freight containers containing plastic pellets should be properly stowed and secured to minimize the hazards to the marine environment without impairing the safety of the ship and persons on board. Specifically, they should be stowed under deck wherever reasonably practicable, or inboard in sheltered areas of exposed decks.
While it is a good first step to see these recommendations adopted, their effective implementation will be key to ensure they prevent plastic pellet spills from happening. Because of their voluntary nature, there is still a lot of concern on the level of impact they will have, and the feeling that more must be done to effectively prevent plastic pellet loss at sea, through the establishment of mandatory measures, was predominant during the MEPC circular adoption.
Clean-up guidelines
Separate to the circular, the IMO had also launched a process to develop clean-up guidelines to support member states in the case of plastic pellet spills happening. The drafting of those guidelines was finalised at the same time as the voluntary recommendations at the PPR 11 meeting.
The draft clean-up guidelines aim to offer practical advice for government authorities and other entities on developing both large-scale national strategies and smaller, site-specific response plans. The guidelines address contingency planning, response, post-spill monitoring and analysis, intervention, and cost recovery, and will be updated as the industry gains more experience in their application.
Often, authorities faced with acute pollution events have reported limited experiences and knowledge to support effective containment and clean-up of plastic pellets, highlighting the need for a standardisation of the response during spill event which is much needed to bring clarity on the procedures to follow to deal as best as possible with these pollution event.
These draft clean-up guidelines were submitted to MEPC 82 in October for consideration and the Sub-Committee has invited Member States to begin implementing the guidelines early, pending formal approval. It is great to see these guidelines developed as they will certainly help informing responses in the case of a pellet spill, however, to ensure effective response and preparedness to this pollution, agreed disaster response protocols must be produced from these guidelines and agreed globally. This would provide countries with a straightforward response mechanism in the case that spills happen and provide clarity to authorities on the responsibilities of the different stakeholders involved to contain and clean-up plastic pellet spills.
From voluntary recommendations to mandatory obligations
The adoption of the circular marked the completion of the first step of the agreed two stage approach, which consisted of:
- firstly, the development of a circular containing recommendations for the carriage of plastic pellets by sea in freight containers, addressing in particular packaging, notification and stowage; and
- at a later stage, the development of amendments to appropriate mandatory instruments, that could form a legal basis for mandatory provisions for the maritime transport of plastic pellets in freight containers
At the PPR 11 meeting, despite a broad support from member states to advance the discussions on the development of mandatory measures to effectively eliminate the risk of maritime plastic pellet loss, it was decided by the secretariat that this debate will have to wait until the next PPR meeting, expected a year later, in early 2025. It is unfortunate that these conversations could not go on at the last meeting, with time ticking and the current conditions of transport of pellets presenting a risk for every country. Ending maritime pellet pollution requires a coordinated, comprehensive approach that enforces mandatory changes in how pellets are handled and transported both on land and at sea.
Ahead of these discussions resuming, while we welcome the introduction of the MEPC circular, Fauna & Flora urges countries not to rely on voluntary initiatives to prevent this form of pollution as this has shown to be ineffective historically. The IMO must implement stricter regulations as soon as possible to eliminate the risk of chronic and acute pellet loss from ships at sea.