What does the ‘Non-HME’ classification mean?
HME stands for „Harmful to the Marine Environment“ – a classification under international dangerous goods legislation for substances that pose a risk to aquatic ecosystems during transport or use. If a substance or mixture does not meet the specified limit values for toxicity, degradability and bioaccumulation potential, it is classified as Non-HME – i.e. as not harmful to the marine environment. „Non-HME“ is therefore not a ‘label’ in its own right, but the result of a structured assessment based on internationally recognised criteria.
Who sets the non-HME criteria?
The assessment is based on several interlinked sets of regulations: the IMDG Code (International Maritime Dangerous Goods Code) governs the safe transport of dangerous goods by sea; the MARPOL Convention (in particular Annex III) protects the marine environment from pollution caused by ships; and GESAMP (Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection) draws up the scientific hazard profiles on which the classification of individual substances is based. The underlying toxicity criteria follow the internationally harmonised GHS system (Globally Harmonised System of Classification and Labelling of Chemicals).
What limit values must be met for a non-HME classification?
Three factors are particularly decisive: Acute aquatic toxicity – if the concentration at which half of the test organisms are harmed (LC50 for fish, EC50 for Daphnia) exceeds 100 mg/l, the substance is not considered to require classification in relation to aquatic organisms under the GHS. Bioaccumulation – the substance must not accumulate in organisms or in the food chain. Biodegradability – the substance should be „readily biodegradable“ within the meaning of OECD Test Guideline 301, i.e. it should be largely degraded within 28 days. Only when all three criteria are met can a product be classified as non-HME.
Do FMO Road and FMO Water meet the non-HME criteria?
Yes. FMO Road and FMO water bodies With an LC50 value (fish toxicity) and an EC50 value (Daphnia toxicity) of over 100 mg/l in each case, they are well below the threshold at which a risk to aquatic organisms would be expected. The surfactants contained in the products are biodegradable – biodegradation within 28 days has been demonstrated – and the ingredients do not accumulate in organisms or the food chain. Both products therefore meet all three criteria for non-HME classification.
Is „Non-HME“ the same as ‘not hazardous to water’ under the AwSV?
No, even though both classifications point in the same direction. The AwSV (Ordinance on Installations for the Handling of Substances Hazardous to Water) is a piece of German water legislation and assesses how a substance affects groundwater and surface water. Non-HME, on the other hand, stems from international dangerous goods and maritime law (IMDG/MARPOL) and specifically assesses the risk to the marine environment. FMO Road and FMO Waterways meet both classifications – and are therefore classified as „not hazardous to water“ and is classified as „Non-HME“ under international dangerous goods legislation.
Why is the ‘Non-HME’ classification particularly important when using the product near or on bodies of water?
A cleaning agent designed to remove oil films from water bodies Any product used in this way inevitably comes into direct contact with the aquatic ecosystem. A product that itself posed a risk to aquatic organisms would be unsuitable for this purpose – the treatment would cause further environmental damage rather than remedying existing damage. The Non-HME classification ensures that FMO Gewässer can be applied directly to water surfaces without itself becoming a threat to fish, daphnia or other aquatic organisms.
What does the ‘non-HME’ classification mean in practice?
For fire brigades, municipal works departments, water authorities and other emergency services, the ‘Non-HME’ classification means: FMO Road and FMO Water meet the requirements for use even in direct contact with surface waters – for example, when clearing oil spills along riverbanks or on bodies of water. The products are formulated so as not to harm aquatic organisms. The competent authority decides whether specific conditions or authorisation are required in individual cases.