The International Maritime Solid Bulk Cargoes Code (IMSBC Code) amendment 04-17 and supplement were adopted by the Maritime Safety Committee (MSC) 98th session and are set to enter into force on 1st January 2019. By going through the updates and comparing it with previous requirements, this article aims to bring to Members’ attention of the compliant carriage of cargo in bulk.

I.    Background

The prime hazards associated with the shipment of solid bulk cargoes are those relating to structural damage due to improper cargo distribution, loss or reduction of stability during a voyage and chemical reactions of cargoes. Back in 1960 at the SOLAS Conference, the delegates began drafting an internationally acceptable code of safe practice to address the problems involved in the shipment of bulk cargoes, which later became the 1965 Code of Safe Practice for Solid Bulk Cargoes (BC Code).

In 2008, amendments to the 1974 SOLAS Convention Chapter VI and VII were adopted at MSC 85^th session where the IMSBC Code was made mandatory to replace the BC Code and entered into force on 1 January 2011.

II.    Practice

The primary aim of the IMSBC Code is to facilitate the safe stowage and shipment of solid bulk cargoes by providing information on the dangers associated with the shipment of certain types of solid bulk cargoes and instructions on the procedures to be adopted when the shipment of solid bulk cargoes is contemplated. Since its entry into force in 2011, it has been amended by resolution MSC.318(89), MSC.354(92), MSC.393(95) and the most recent resolution MSC.426 (98). Addressing the emerging problems and risks regarding the practice of bulk cargo shipping, the IMSBC Code is amended on a biennial basis and is commended to Administrations, shipowners, shippers and masters and all others concerned with the standards to be applied in the safe stowage and shipment of solid bulk cargoes, excluding grain.

III.    New requirements

Rule 1.7 Bulk Cargo Shipping Name (BCSN)

l Previously: when the cargo is a dangerous good, as defined in the IMDG Code, as defined in regulation VII/1.1 of the SOLAS Convention, the Proper Shipping Name of that cargo is the BCSN and it shall be supplemented with the UN number.

l Now: Rule 4.1.1.2 provides that where the cargo is dangerous goods and not identified with a generic Proper Shipping Name, or not otherwise specified (N.O.S) in the IMDG Code, the BCSN shall consist of the Proper Shipping Name followed by the UN number. Then rule 4.1.1.3 provides that except for radioactive material, low specific activity, non-fissile or fissile-excepted UN 2912 and radioactive material, surface contaminated objects, non-fissile or fissile-excepted UN 2913, where the cargo is dangerous goods identified with a generic Proper Shipping Name and/or N.O.S in the IMDG Code, the BCSN shall consist of:

1.      a chemical or technical name of the material;

2.      a specific description to identify the properties of the material; and

3.      the UN number.

Apparently, stricter rules of identifying dangerous bulk cargoes are imposed on consignors to help recognize potential hazards and guarantee safe delivery of goods.

Rule 4.2 Provision of information

l Rule 4.2.2.16 newly added: the cargo information shall include whether or not it is classified as harmful to the marine environment in accordance with MARPOL Annex V as modified by the Protocol of 1978 and as amended.

The amendment, incorporating MARPOL Annex V, requires that if the cargo is harmful to marine environment, then the discharge of garbage including cargo residues, cargo hold washwater, cleaning agents, deck washwater containing cargo residues and sewage into sea are prohibited.

Rule 4.5 Interval between sampling/testing and loading for TML and moisture content determination

l Previously in 4.5.1: a test to determine the TML of a solid bulk cargo shall be conducted within six months to the date of loading the cargo. Notwithstanding this provision, where the composition or characteristics of the cargo are variable for any reason, a test to determine the TML shall be conducted again after it is reasonably assumed that such variation has taken place.

l Now in 4.5.1: the shipper shall be responsible for ensuring that a test to determine the TML of a solid bulk cargo is conducted within six months to the date of loading the cargo. Notwithstanding this provision, where the composition or characteristics of the cargo are variable for any reason, the shipper shall be responsible for ensuring that a test to determine the TML is conducted again after it is reasonably assumed that such variation has taken place.

l Previously in 4.5.2: sampling and testing for moisture content shall be conducted as near as practicable to the time of loading. If there has been significant rain or snow between the time of testing and loading, check tests shall be conducted to ensure that the moisture content of the cargo is still less than its TML. The interval between sampling/testing and loading shall never be more than seven days.

l Now in 4.5.2: the shipper shall be responsible for ensuring that sampling and testing for moisture content is conducted as near as practicable to the date of commencement of loading. The interval between sampling/testing and the date of commencement of loading shall never be more than seven days. If the cargo has been exposed to significant rain or snow between the time of testing and the date of completion of loading, the shipper shall be responsible for ensuring that the moisture content of the cargo is still less than its TML, and evidence of this is provided to the master as soon as practicable.

The update has made clear the responsibilities of the shipper in determining the TML and ensuring a proper interval between sampling and loading. The period requiring a check test was extended to the date of completion of loading, preventing finger-pointing between the shipper, the consignor and the carrier and mitigating cargo risks.

Rule 9.3.3 Segregation between bulk materials possessing chemical hazards and dangerous goods in packaged form

Segregation of substance which emit flammable gases in contact with water and IMDG Class 2.1 dangerous goods is updated from 1 to 2 – changing the segregation term from “away from” to “separated from”.

The IMDG Code poses different segregation requirements on dangerous goods as per their categories and the vessel types. The above two types of cargoes shall be in different holds when stowed under deck. Provided an intervening deck is resistant to fire and liquid, a vertical separation, i.e. in different compartments, may be accepted as equivalent, projecting a minimum horizontal separation of 6 meters. Previously, “away from” suggests that the goods shall be effectively segregated so that incompatible materials cannot interact dangerously in the event of an accident but may be carried in the same hold or compartment or on deck provided a minimum horizontal separation of 3 meters, projected vertically, is provided.

IV.    Advice to Members

As expressed, the IMSBC Code, amplifying the SOLAS provisions, now provides mandatory requirements on safe carriage of bulk cargoes and is used as the basis for national regulations. It has been updated to match the new amendments of other Conventions with the updated provisions specifying technical information about cargo transportation and helping to identify underlying risks. Owners and masters are advisable to operate cargo in compliance with the new requirements. Ask the consignor for more detailed cargo information and make sure of a standard cargo operation, especially regarding the discharge of cargo residues and stowage/segregation of dangerous goods.

For further information, please contact your manager at the Club.