Guest blogger Falco Martin, Fauna and Flora explores if the International Maritime Organisation will 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.

Every day, millions of plastic pellets are pouring into our ocean, spilling from ships transporting them around the world. It is a scandal that these pellets are being allowed to pollute our ocean, especially when it is entirely preventable.

The International Maritime Organization (IMO) is the United Nations agency responsible for the safety and security of shipping and the prevention of pollution from ships. Following several pellet pollution disasters at sea in recent years, such as the MV X-Press Pearl in 2021, (where approximately 1,680 tonnes of plastic pellets were spilled along the coast of Sri Lanka), many delegations at the IMO called for urgent action and supported proposals to classify plastic pellets to make them subject to much stricter shipping regulations.

IMO members are broadly in agreement that mandatory measures are required to eliminate the risk of future chronic and acute pellet loss from ships but navigating IMO processes is a slow process.

What has happened so far?

The Sri Lankan Government submitted a formal request to the IMO after the largest plastic pellet spill from a cargo ship impacted the country (Figure 1). After agreeing action was needed, an IMO subcommittee correspondence group explored policy reform options to reduce the environmental risk of plastic pellets cargoes transported by ships.



Figure 1. Timeline of progress and committees involved in reducing the environmental risk associated with the transportation of plastic pellets by ships

Despite the positive work to tackle plastic pellet loss at sea, the process to implement efficient and mandatory regulations remains slow. IMO groups have now agreed to the adoption of an interim circular on voluntary action in 2024, but this will only be the first step of a process to implement mandatory measures. To date, three options for mandatory measures have been identified, including:

  1. an amendment to the appendix to MARPOL Annex III that would recognize plastic pellets as a "harmful substance";
  2. a new chapter in MARPOL Annex III that would prescribe requirements for the transport of plastic pellets in freight containers without classifying the cargo as a harmful substance/dangerous goods; and
  3. an assignment of an individual UN number (class 9) for plastic pellets transported at sea in freight containers.

Significant changes won’t happen without the implementation of mandatory regulations. There is a clear need for the IMO to act as soon as possible, as the risk of pellet loss remains omnipresent, putting coastal communities and ecosystems at risk.

In the meantime, the circular will be finalised as a voluntary measure to enter into force in 2024 and the experience gained from the circular should be used to inform the development of mandatory measures. A key decision in finalizing the draft circular on voluntary measures, was if reference should be made to the Code and, if any, what reference would be most appropriate. By classifying pellets as dangerous goods with an IMDG code means they will be stowed below deck and if there is a maritime incident the likelihood of pellets spilling into the environment is significantly reduced. Further to this, in an event of cargo loss the relevant authorities would need to be informed which would help environmental clean-up.

The Sub-Committee decided that the draft MEPC circular on voluntary measures should be retained and that text specific to packaging of pellets should not be amended and that a reference to the IMDG Code should not be included. It is disappointing that no reference to the IMDG Code or to specific packaging requirements was included in the circular at this stage. This will make it more challenging to include ambitious and effective language in the development of mandatory measures later.


A need for clarity to break the stalemate

Over the course of the committee ping pong, it became clear progress had plateaued. Support for mandatory measures was clear but there seemed to be a lack of clarity on which was the most effective mandatory measures to tackle the problem. As a result, Fauna & Flora commissioned consultants CE Delft to conduct a feasibility study to compare and contrast how regulatory options identified by IMO groups would achieve the necessary changes in reality, with a particular focus on the packaging, notification and stowage requirements of plastic pellets.

The CE Delft study highlighted:

  • The options to apply for a new UN number or recognize pellets as a harmful substance by amending Appendix I of MARPOL Annex III would require better packaging of pellets, thus reducing the risk of chronic losses of pellets from containers and would reduce the risk of acute losses and dispersion of pellets in the marine environment if the container is lost overboard.
  • Both of these options would trigger a preference for either below-deck stowage or stowage in a sheltered location above deck but would require a further amendment to the language of the International Maritime Dangerous Goods (IMDG) Code to mandate safe stowage.
  • Classifying pellets as a harmful substance would improve disaster response and pollution preparedness.
  • The option to add a chapter to MARPOL Annex III could include mandatory requirements for safe stowage, thus reducing the risk that containers with plastic pellets are lost at sea, but the drafting seen so far did not require improved packaging requirements for plastic pellets being transported by sea.
  • The additional costs of all options appear to be manageable

Achieving multiple layers of protection with preventative action

Fauna & Flora believes that tackling pellet loss requires a coordinated, comprehensive approach that will bring about mandatory changes in the way that pellets are handled and transported on land and at sea. Multiple layers of protection in the form of preventative action are required to effectively reduce the risk of loss of pellets to the environment: a focus on pollution clean-up and mitigation alone are ineffective strategies. These layers of preventative action fall into four key areas:

  • classification considering the dangers posed by pellet pollution;
  • stringent packaging requirements;
  • safe stowage below deck or in sheltered areas;
  • and pollution preparedness.

Fauna & Flora urges the IMO to bring in stricter regulations as soon as possible, to eliminate the risk of future chronic and acute pellet loss from ships at sea.