International community must act on plastic pellet pollution from maritime transportation

Next week is the much-anticipated tenth session of the International Maritime Organization (IMO) Pollution Prevention and Response Sub-Committee (PPR 10). Among many pressing topics up for consideration are the terms of reference for work on plastic pellets and fishing gear. The Clean Shipping Coalition (CSC) has been actively participating in intersessional work, and PPR 10 is a significant opportunity for tangible action and, if done properly, can have a huge potential benefit for the marine environment.

Building on the main discussions, on Monday, April 24, from 13:20 to 13:50 BST, CSC will host a side event – co-chaired by Amy Youngman, legal and policy specialist at the Environmental Investigation Agency and Tanya Cox, Senior Technical Specialist, Marine Plastics at Fauna & Flora – which will take a deep dive into how we can advance action to address plastic pellet pollution during maritime transport.

What is plastic pellet pollution?

Plastic pellets, or ‘nurdles’, are lentil-sized pieces of plastic that manufacturers melt together to create almost all plastic items used day-to-day. Pellets are a significant source of microplastic pollution; they spill on land and at sea in staggering numbers, especially in transit. It is estimated that billions of individual pellets enter the ocean every year.

Plastic pellets increasingly litter beaches worldwide, smother the seabed and are mistaken for food by marine life. When eaten or ingested, they fill the stomachs of fish and animals, leading to starvation.

Pellets are inherently hazardous due to the chemical additives they contain and leak during degradation in the marine environment. They act like sponges, absorbing and accumulating bacteria and persistent environmental pollutants in seawater. They then serve as vectors for those toxic and chemical contaminants and are carried by tides around the globe. Once those pellets come into contact with or marine animals eat them, the toxins, chemicals, and bacteria can be transferred to the animal, effectively acting as a poisoned pill for marine life, which can travel up the food chain and harm human health.

What can be done to stop the issue?

While the scale and impact of plastic pellet pollution is severe, the reality is the issue is entirely preventable. We know there are a number of measures that countries could take to prevent nurdle pollution. Unfortunately, intervention to date has been ineffective with limited impact due to it being entirely voluntary and focused on land-based sources of pollution.

Earlier this year, the international nature conservation charity, Fauna & Flora, commissioned a feasibility study of the regulatory options. The study proved that the path to zero pellet loss at sea is not that far out of reach. Some of the key findings included:

• Both options to apply for a new UN number or amend Appendix I of MARPOL Annex III to classify pellets as a harmful substance would require better pellet packaging – hence reducing the risk of chronic losses of pellets from containers, as well as acute losses of pellets if the container is lost overboard.
• Both the UN number and amending Annex III options would trigger a preference for either below-deck stowage or stowage in a sheltered location above dec. However, they would require a further amendment to the language of the IMDG Code to mandate safe stowage.
• Classifying pellets as a harmful substance in Annex III would improve disaster response and pollution preparedness.
• Adding a new chapter to MARPOL Annex III could include mandatory requirements for safe stowage, reducing the risk of containers with plastic pellets being lost at sea.
• Additional costs of all options appear manageable, based on feedback from interviewees.

As detailed above, the study found that all options would be feasible for actors in the transport chain, regulators and inspectors to implement and that mandatory measures for packaging and stowage of plastic pellets on ships – in addition to measures that support pollution preparedness and disaster response – will be the most effective.

Amending MARPOL Annex III to classify pellets as harmful substances would achieve three of these four changes (packaging, pollution preparedness and disaster response). Therefore, decision-makers should make this option a priority at PPR10.

Where are discussions currently?

During PPR 9, the IMO instructed the Correspondent Group on Plastics (CG), in which CSC participated, to consider the options for reducing the environmental risk associated with the maritime transport of plastic pellets. The CG agreed “there was a need to develop mandatory requirements for the transport of plastic pellets, but, at this stage, it was not in a position to conclude on the most appropriate instrument.”

Given the significant contribution of plastic pellets as a source of plastic pollution in the marine environment and the significant global momentum to create binding measures to address plastic pollution with the adoption of UNEA 5/14, we are urging IMO Members at PPR 10 to reflect on the important contributions made during the CG, offer a clear direction forward, and advance regulations on plastic pellets.

Ahead of the second round of negotiations for the global plastics treaty in May, the Secretariat produced an Options for Elements Paper to help members negotiate a zero-draft treaty text. The Paper gave the option to regulate the production, handling and transport of plastic pellets. To ensure a coordinated approach governing maritime transportation, IMO regulations on plastic pellets must move forward clearly and swiftly to ensure synergy with the new global instrument and to maximise effective governance on plastic pellet pollution by 2024.

The next significant meeting after PPR 10 is the July Marine Environmental Protection Committee (MEPC 80). While there is momentum to tackle plastic pellet pollution from maritime transportation, countries must take ambitious steps forward to determine the best path forward. In the interim, we must adopt an ambitious Circular that temporarily reduces the risk associated with the maritime transport of plastic pellets. A Circular with robust provisions on packaging, notification and stowage will prove that pellet pollution is preventable and feasible in future binding measures.

We must urge all national MEPC representatives to support stricter shipping regulations for plastic pellets – both at PPR 10 and, critically, at MEPC 80 in July.

How can you help?

Fauna & Flora has launched a petition calling on national representatives of the MEPC at the IMO to do everything in their power to end plastic pellet pollution and push for IMO Members to legally classify as marine pollutants at the MEPC 80 meeting in July.

Every signature will be added to a letter urging the IMO to act quickly and decisively to bring in stricter regulations around plastic pellet pollution, ensuring this severe pollution issue does not continue longer than it needs to.

Time is running out to put a halt to plastic pollution – you can help speed up the process by signing the petition here:  https://bit.ly/StopNurdlePollution.

For further reading about CSC’s position at PPR 10 please read our comment papers on the Correspondence Group report, submitted with Friends of the Earth International – PPR 10/13/5 on plastic pellets and PPR 10/13/6 on fishing gear.