ENVIRONMENTALLY HAZARDOUS SUBSTANCES

The existing provisions in UN Model Regulations, in IMDG Code, in ICAO T.I., in ADR/RID/ADN are not harmonized.
Main problems are related to criteria for classification, subdivision into categories in GHS and into severe and non severe marine pollutants in IMDG Code, requirements for labelling and marking.

Taking also care of the future implementation of GHS in other sectors, a possible solution (for all the modes of transport) could be:
1) to implement GHS criteria (as in UN Model Regulations)
2) to recognize the environmental hazard as a subsidiary risk also for substances which meet the criteria of other classes/divisions
3) to split the existing UN numbers into “severe aquatic pollutants” and “aquatic pollutants”, respectively for category “acute 1 and chronic 1” and category “chronic 2” (in view of future development in GHS concerning terrestrial environment, it seems appropriate to change the proper shipping name)
4) to require the GHS pictogram as the label (not as a mark) for aquatic pollutant (and not the class 9 label), also for substances which meet the criteria of other classes/divisions

In implementing GHS in transport regulations there was a large consensus on the decision that classification of substances will be revised if necessary, according to the GHS criteria, on the basis of case by case proposals. The same principle could be adopted here, but the starting point could also be the provisional adoption of the IMDG Code classification as aquatic (marine) pollutant.