Requirements for Marine Pollutants
Pipeline and Hazardous Materials Safety Administration · Dec 29, 1993 · Reference No. 93-0146
Reggie’s quick take
Someone asked how marine pollutant rules apply under the Hazardous Materials Regulations. For a bulk packaging that already bears a label or placard required by Subparts E or F, the marine pollutant mark is not needed unless the shipment goes by vessel. The words "marine pollutant" must still go on the shipping paper next to the basic description. For non-bulk packages sent by any mode other than vessel, the marine pollutant requirements do not apply. The agency said the asker's understanding was correct.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter dated August 18, 1993 regarding requirements for marine pollutants under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Your understanding of the requirements applicable to marine pollutants is correct. The marine pollutant mark is not required on a bulk packaging that bears a label or placard specified in Subparts E or F of the HMR unless transported by vessel. The words marine pollutant must be entered on the shipping paper in association with the basic description. Lastly, requirements for marine pollutants do not apply to non-bulk packages transported by a mode of transportation other than vessel.
If we can be of further assistance, please contact us.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.