again on ENVIRONMENTALLY HAZARDOUS SUBSTANCES

Let us consider the case of the intermodal transport of dangerous substances and mixtures (such as wastes).
According to the future new provisions of ADR/RID 2009 it will be necessary to check if they need to be classified as environmentally hazardous substance and, if that is the case, the package need to be marked accordingly, while, according to IMDG Code, it is necessary to check if it is a marine pollutant and to mark accordingly the package (still it is not clear to me why it should be a mark and not a label).
Do we really think that all the European shippers will check every dangerous substance or mixture (which is not clearly mentioned in the European Directives 67/548/EEC and 1999/45/EC as environmentally hazardous one) to verify if indeed it is also an environmentally hazardous one ?

Another question: in the case of a mixture, it is really necessary to apply the quite complex summation method (developed by GHS) to establish if it is acute category I or chronic category I or chronic category II ?
What is the meaning of the 3 categories (and specifically the difference between chronic I and II) from the point of view of transport regulations, taking care that the same requirements apply irrespective of the category (which however is not true for sea transport where marine pollutants and severe marine pollutants are subject to different requirements, for instance concerning Limited Quantities) ?
And again it is not clear to me why chronic effects are relevant from the point of view of the environment, but not from the point of view of health (for instance, carcinogens are not considered dangerous in transport regulations).

A possible suggestion: complete revision of GHS, using for classifying environmentally hazardous substances a simpler approach, similar to what has been developed for acute toxicity, and revising transport regulations perhaps assigning different Packing Groups to different categories (if really necessary).

Another possibility is of course to wait the result of the implementation of the European REACH (and GHS) Regulation, which will allow thousands of substances and mixtures to be classified on the basis of GHS criteria.