Annex-III :- Prevention of Pollution by Harmful Substances carried at Sea in Packaged Form

w.e.f- July, 1992

The International Convention for the Prevention Of Pollution from Ships is the main international convention covering the prevention of pollution of the marine environment by ships from operational or accidental causes.

Courtesy:- Knowledge Of Sea

The MARPOL Convention was adopted on 2nd November 1973 at the INTERNATIONAL MARITIME ORGANIZATION (IMO). The protocol of 1978 was adopted in response to a spate of tanker accidents in 1976-1977. The convention aims at preventing and minimizing pollution from ships- both accidental and routine operations. This currently includes six technical annexes. Special Areas with strict controls on operational discharges are included in most of them.

Marine pollution can be defined as, “the introduction of substances into the marine environment by man, directly or indirectly resulting in such deleterious effects as harm to living resources, hazards to human health, hindrance to marine activities including fishing, impairment of quality of use of sea water and reduction of amenities”.

Of the six annexes mentioned above the third annexure include: PREVENTION OF POLLUTION BY HARMFUL SUBSTANCES CARRIED BY SEA IN PACKAGED FORM It includes general requirements for the issuing of detailed standards on packing, marking, labelling, documentation, stowage, quantity limitations, exceptions and notifications.

The annexure 3 says “harmful substances” are those substances which are identified as marine pollutants in the International Maritime Dangerous Goods Code (IDMG Code). The MARPOL Annex III came into force on 1st July 1992 and comprised of two chapters containing eleven regulations.

Chapter One gives some general details on MARPOL ANNEX III and consists of nine regulations.

Regulations One and Two explains the “Definition” of different terminologies which are used in the chapter and the “Application” of this chapter in different types of ships which are carrying hazardous goods.

Regulations Three and Four lists the requirements of packaging and marking/labeling of the packages carrying IMDG cargoes.

Regulation Five provides the details of the documentation which are needed by the ship which is carrying hazardous material under MARPOL ANNEX 3 The storage requirement and quantity limitations for carrying harmful substances in bulk are provided under Regulations Six and Seven.

Regulation Eight underlays the exceptions which a ship carrying harmful cargo in bulk can have under various circumstances. The authorization of port-state control on the operational requirement of ships carrying such substance under MARPOL Annex III comes under the Regulation Nine.

CHAPTER 2 deals with the Verification of compliance with the provision of this convention providing details of the application and the process for verification of compliance under the Regulations Ten and Eleven.

Marine pollutants must be specially packaged, labelled and stowed on board to prevent their release into the marine environment. Special labeling also enables pollutants to be identified and separated from other cargoes during salvage operations after an accident. Any packaged cargo transported at sea which poses a threat to people, other living organisms, property or the environment should be listed on the manifests as “dangerous goods” and should display the appropriate hazard labels. It should have a “marine pollutant” label.



Goods that are carried in packaged form which can pose to be a threat to the environment, be it in solid form or in bulk are regulated by Part A of SOLAS Chapter VII: carriage of dangerous goods, known as the International Maritime Dangerous Goods (IMDG CODE). It was developed as an international code for the maritime transport of dangerous goods. In order to enhance and harmonize the safe carriage of these essential goods and to prevent pollution to the environment.


There are various dangerous goods that are essential in the manufacture of other products such as cars, plastics, electronics, and pharmaceuticals on which the progress and world trade depends.

For transport purposes, they are segregated into nine classes according to how treacherous they can be. The classes are as follows:

  • CLASS 1- Explosives
  • CLASS 2- Gases
  • CLASS 3- Flammable liquids
  • CLASS 4- Flammable solids and other similar substances
  • CLASS 5- Oxidizing substances
  • CLASS 6- Toxic and infectious substances
  • CLASS 7- Radioactive material
  • CLASS 8- Corrosive substances
  • CLASS 9- Miscellaneous dangerous substances and objects

Substances are termed as “dangerous goods” for transport only if they meet the criteria laid down by the IMDG code for all the classes.


According to MARPOL ANNEX 3 Reg. Four, whenever a marine pollutant is offered for transport by sea, the document must mention the words ‘marine pollutant’ after the description of dangerous goods. This can be supplemented with the words ‘environmentally hazardous’. Also if the cargo is under a generic or N.O.S. entry, then the proper shipping name shall be supplemented with the technical name. Every ship must have a special list, manifest or stowage location of marine pollutants loaded at each port. This must be revised at every load and discharge port. They should be handed to the person appointed  by the port authority. To prevent containers falling into the sea, carriers loading marine pollutant containers/ tanks loading the same normally prefer under-deck stowage, when permitted or will stow only on well protected decks. Jettisoning of harmful substances is prohibited except when it is needed to secure the safety of life on board vessels or for securing the safety of the vessel.

Jettisoning- The act of throwing cargo overboard during an emergency for the safety of ship and other cargo.

Hazardous and Noxious Substances

Noxious liquid substances and harmful substances carried by sea in packaged form also fall under the definition of hazardous and noxious substances. Issues related to the anticipation and rejoinder to incidents of pollution are covered by certain protocols formulated by IMO, considering HNS.

An HNS can be defined as any substance other than oil which, if introduced into the marine environment, is likely to create hazards in various aspects and also interfere in certain legitimate uses of sea.

HNS may be accidentally introduced into the sea by maybe containers having marine pollutants falling overboard during rough seas or if it is inadequately secured. Marine pollution caused by HNS may vary from oil pollution and also in the range of consequences. Even low HNS pollution can have a lethal aftermath producing long term damage to marine organisms.

Compensation for accidents involving such a virulent aftermath are covered by the HNS Convention 2010. Roughly 15% of the goods carried as cargo are dangerous goods hence in accordance to annex 3 the regulations set for prevention of marine pollution and transportation of packaged dangerous goods are followed for swift, unhindered shipping without harming the natural habitat of the marine residents.

Authored By:- Cdt. Resham Pandey, TMI

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