General information:

• White spirit or mineral spirits, also known as mineral turpentine, turpentine substitute, petroleum spirits, solvent naphtha, Varsol, Stoddard solvent, or, generically, “paint thinner”.

USDOT/PHMSA:

• To be a marine pollutant per USDOT/PHMSA regulations it must be each of the following:
  • Identified by name as a marine pollutants (appendix B to Hazardous Materials Table at 49 CFR 172.101).
  • 10% or more in solution if marine pollutant.  1% or more in solution if a severe marine pollutant (identified by ‘PP’ in column 1 of list).
  • Transported in any size packaging by vessel or transported in a bulk packaging by highway, rail, or air.
• White Spirit, low (15-20%) aromatic is identified by name as a marine pollutant.
• Turpentine is identified by name as a marine pollutant.
• Read:  What is a Marine Pollutant?

It is impossible to determine if your product is a marine pollutant per USDOT/PHMSA regulations without first identifying exactly what it is and its concentration, packaging, and mode of transport.

• To be a marine pollutant per the IMO dangerous goods code (IMDG), it must be one of the following:
  • Display a ‘P’ in the ‘MP’ column for its entry in the Index.
  • Display a ‘P’ in column 4 of the Dangerous Goods List (DGL) for its entry.
  • Meet the criteria of the UN Recommendations (2.9.3) for an Environmentally Hazardous Substance (aquatic environment).
• If identified as a marine pollutant in either the Index or the DGL it is not subject to regulation as a marine pollutant if it does not meet the UN criteria.
• If not identified as a marine pollutant in either the Index or the DGL it is subject to regulation as a marine pollutant if it is proven to meet the UN criteria.
• White Spirit, low (15-20%) aromatic, white spirit, & TURPENTINE are all identified as a marine pollutant in the Index.

Unless the shipper has data to indicate it does not meet the criteria for an environmentally hazardous substance (aquatic environment), then the above identified substances must be shipped as a marine pollutant when subject to the IMDG Code.

• 49 CFR 172.101, Appendix B (4):  if not listed as a marine pollutant but meets criteria for marine pollutant per IMDG, then may be transported as marine pollutant within U.S.
• 49 CFR 172.101, Appendix B (5):  if listed as a marine pollutant but does not meet criteria for marine pollutant per IMDG, then may be excepted from transport as marine pollutant within U.S. with approval from PHMSA/USDOT.
• The International Air Transport Association (IATA) uses the same UN criteria as the IMO for classifying a marine pollutant.

• Q&A:  Marine Pollutant and the exception from regulation if <5 L / 5 kg
• When the Marine Pollutant Mark is not Required

I hope this helps.

Please contact me with any other questions.

Conclusion:

The classification of a marine pollutant is complicated.  It is made more so by the fact that the classification of a marine pollutant of USDOT/PHMSA within the U.S. differs from the international regulations of IATA & IMO. That means the requirements for transport of a HazMat within the U.S. may differ from those outside of the U.S.  Make certain you determine the applicable regulations and them comply with them.