Preventing spills of plastic pellets: a feasibility analysis of regulatory options

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. [...] Note that not all the details of the three options are presented in the report of the Correspondence Group, so that the authors had to interpret the options. [...] All the options would result in similar notification requirements for the consignor, but the options to apply for a new UN number and the option to amend the Appendix of MARPOL Annex III also require that information is immediately available in case of an incident or accident, which is not required in the proposed new chapter of MARPOL Annex III. [...] Given the weight distribution stacking the containers with pellets on the sides and/or at the bottom of the stack is not a preferred option as it would influence the stability of the ship. [...] In addition to the cost difference between the standard and UN certified big bags, the crucial step in the packaging of the products is whether the bags are closed according to the requirements to contain the product as required, such as that they should be sift-proof.