Clarity on Marine Pollutant Designation With Sulfuryl Fluoride and Chloropicrin in U.S.

In accordance with federal regulations, specifically Title 49 of the Department of Transportation (DOT), the substances chloropicrin and sulfuryl fluoride have been categorized as marine pollutants. Consequently, the current labeling for Vikane^® gas fumigant designates it as a marine pollutant, and when transported via waterways, it is mandatory to include this information on the shipping documents. However, under §171.4 of the DOT regulations, certain exceptions are granted for non-bulk small packages of chemicals, including chloropicrin and sulfuryl fluoride, when transported by vehicle to the continental 48 states. In such cases, there is no requirement to designate chloropicrin and sulfuryl fluoride as marine pollutants in shipping papers.

Our company has made the decision to utilize this exception when shipping our products to the continental 48 states. As part of this decision, we will employ a uniform label for all shipments, indicating Vikane as a marine pollutant. Consequently, shipments outside the continental 48 states will have shipping documents that reflect this classification. However, for products transported via road within the continental 48 states, the shipping papers will not identify Vikane as a marine pollutant, although the label will continue to do so. It is important to note that under §171.4, Subchapter C, of the DOT regulations, multiple chemical labels are not required for shipments falling within this exception.