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Explanation of Annex III      

Annex III applies to all ships to which MARPOL applies which carry harmful substances in packaged form. Harmful substances are those identified as marine pollutants in the International Maritime Dangerous Goods (IMDG Code). Packaged form means any form of containment other than the structure of the ship and includes packaging, freight containers, portable tanks and road and rail tank wagon as identified or specified in the IMDG Code.

Annex III prohibits the carriage of harmful substances except in accordance with the conditions laid down in the Annex. These include requirements on packaging, making, labeling, documentation and stowage and quantity limitations and exceptions relations to the safety of the ship or saving life at sea.

Empty receptacles, freight containers, portable tanks, and road and rail wagons which have been used previously for the carriage of harmful substances shall themselves be treated as harmful substances unless adequate precautions have been taken to ensure that they contain no residue that is hazardous to the marine environment.

HARMFUL SUBSTANCES: For the purposes of Annex 3, harmful substances are identified by any of the following:

a)    identified as MARINE POLLUTANT 

b)    identified as SEVERE MARINE POLLUTANT


MEANS substances which because of their potential to bio accumulate in sea food or because of their high toxicity to aquatic life are subject to Annex 3 and are identified in column 4 of the dangerous cargo manifest or in the index of the IMDG code by the column listed as MP by

-P    (marine pollutant)

-PP  (severe Marine pollutant)

Packaging : Packaging, freight containers, portable tanks and road and rail tank wagons shall be adequate to minimise the hazard to the marine environment having regard to their specific contents.

Markings and Labelling : The package containing harmful substance shall be marked with the correct technical name with distinctive label or stencil of label, indicating that the contents are MARINE POLLUTANTS.. The identification can be supplemented by other means example U.N. Number. .Markings should be able to survive  at 3 months immersion in water

Documentation: In all documents, relating to the carriage of harmful substances, the correct technical name shall be used further identified by addition of the words ”MARINE POLLUTANTS”.

  • The shipping document supplied by the shipper shall include a certificate or declaration that the shipment offered for the carriage is properly packed, marked and labelled, placarded and in the proper condition for the carriage to minimize the hazard to the marine environment.
  • Each ship carrying harmful substances shall have a special list or manifest  setting forth the harmful substances on board and the location thereof. A detailed stowage plan which sets out the location of all harmful substances on board may be used in place of such special list or manifest. Copies of such documents shall also be retained on shore by the owner of the ship or his representative until the harmful substances are unloaded.
  • The documents required for this annex can be combined with the special list or manifest or stowage plan of  Dangerous goods required as per SOLAS. A clear distinction shall be made between dangerous goods and other harmful substances.

Stowage : Harmful substances shall be properly stowed and secured as to minimize the hazards to marine environment without impairing the safety of the ship and persons on board.

Quantity Limitations : Certain harmful substances which are very hazardous to marine environment may, for sound scientific and technical reasons need to be prohibited for carriage or be limited to the quantity which may be carried aboard any one ship. In limiting the quantity, due consideration shall be given to size, construction and equipment of the ship as well as the packaging and the inherent nature of the substance.

Exceptions : Discharge by jettisoning of harmful substances carried in packaged forms, freight containers, portable tanks, or road and rail wagons shall be prohibited, except where necessary for the purpose of securing the safety of the ship or saving life at sea.

Subject to the provisions of the present convention, appropriate measures based on physical, chemical and biological properties of harmful substances shall be taken to regulate the washing of leakages overboard, provided that compliance with such measures would not impair the safety of the ship and persons on board.

Notification : With respect to certain harmful substances as may be designated by the government of a party, to the Convention, the master or owner of the ship or his representative shall notify the appropriate port authority of the intent to load or unload such substances at least 24 hours prior to such action.

Implementation by means of the IMDG code :

This annex makes reference to the IMDG code for detailed requirements on the carriage of harmful substances, and the code has been adapted so that it can used as the practical means of implementing Annex III. This is because the majority of harmful substances in packaged form (known as “marine pollutants”) are already classified as dangerous goods in the code.

The IMDG code consists of general requirements and schedules under each class of substance for individual substances or materials. Dangerous goods which are also marine pollutants will have this fact clearly stated on the relevant schedule. Shippers will therefore have to declare their shipment as a marine pollutant and comply with the Code’s requirements. This will usually mean adding a special marine pollutant mark to the package.

These pollutants will need to be declared under the proper shipping name and the packaging will have to conform to the requirements of  the IMDG code and be marked with the proper shipping name, the UN Number and the pollutant mark.

Full details of these requirements will be found in the latest editions of the IMDG code 

No survey or certification of the ship is required under Annex III of MARPOL 73/78 (although it is under SOLAS, for dangerous goods which is known as DOCUMENT OF COMPLIANCE and a format of same is available in the IMDG CODE).

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