Liquefaction of Solid Bulk Cargoes Dust

A selection of articles previously Liquefaction of published by Gard AS solid bulk cargoes

3 Contents

Liquefaction of unprocessed mineral ores - Iron ore fines and nickel ore...... 4 Intercargo publishes guide for the safe loading of nickel ore...... 8 Shifting solid bulk cargoes...... 9 The carriage of nickel ore from the Philippines and Indonesia - The insurance position...... 11 Cargo liquefaction - An update...... 12 Cargo liquefaction problems – sinter feed from Brazil...... 16 Liquefaction of cargoes of iron ore...... 17 India - Safe Shipment of Iron Ore Fines from Indian Ports...... 18 Indonesia and the Philippines – Safe Carriage of Nickel Ore Cargoes...... 20 Dangers of carrying Nickel Ore from Indonesia and the Philippines – Mandatory Notification Requirements...... 23 New BIMCO Charterparty clause for solid bulk cargoes that may liquefy...... 24 IMSBC Code amendments regarding cargoes that may liquefy...... 25 Brazil - liquefaction of bauxite cargoes...... 26 Bar, Montenegro - zinc concentrate liquefaction risk...... 26

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The information contained in this publication is compiled from material previously published by Gard AS and is provided for general information purposes only. Whilst we have taken every care to ensure the accuracy and quality of the information provided at the time of original publication, Gard AS can accept no responsibility in respect of any loss or damage of any kind whatsoever which may arise from reliance on information contained in this publication regardless of whether such information originates from Gard AS, its shareholders, correspondents or other contributors.

Gard News 197, Liquefaction of February/April 2010 unprocessed mineral ores - Iron ore fines and nickel ore By Dr Martin Jonas, Brookes Bell, Liverpool.

Dr Martin Jonas considers some of the technical issues behind the casualties involving the carriage of unprocessed natural ores from India and nickel ore from Indonesia, the Philippines and New Caledonia.

Introduction Liquefaction of mineral ores, resulting in cargo shift and loss of stability, has been a major cause of marine casualties for many decades. Recent Figure 1: Liquefaction as a result of cargo compaction. In the solid state (left), the shear problems, already leading to several strength of the cargo is provided by the direct contact between the cargo particles. total losses this year, have primarily There are sufficient interstitial spaces to accommodate the inherent moisture and a proportion of interstitial air. As the cargo compacts under the influence of the ship’s involved the carriage of unprocessed motions, the volume between the particles reduces and interstitial air is expelled. natural ores such as iron ore fines from Eventually, the water pressure resulting from compaction presses the particles apart, India and nickel ore from Indonesia, potentially leading to them losing direct contact and a resulting sudden loss of shear the Philippines and New Caledonia. strength, i.e., a fluid state (right). The main cause of casualties and near misses is the poor compliance (see Figure 1). This suddenly reduces The lowest moisture content at which of shippers with the testing and the friction between particles, and thus liquefaction can occur is called the Flow certification requirements that are the shear strength of the cargo. Moisture Point (commonly abbreviated designed to ensure that cargoes are FMP). Its numerical value can vary loaded only if the moisture content is The effect of this process is a transition widely even for cargoes with the same sufficiently low to avoid liquefaction from a solid state to a viscous fluid description. It is not possible to predict occurring during the voyage.1 state in which all or part of the cargo the FMP of a given cargo from its can flatten out to form a fluid surface. description, particle size distribution Principles of liquefaction In this condition, cargo may flow to or chemical composition and the FMP Cargoes that are at risk of liquefaction one side of the ship with a roll one way therefore needs to be determined by are those containing at least some but not completely return with a roll laboratory testing separately for each fine particles and some moisture, the other way, progressively leading cargo provided by each shipper. although they need not be visibly to a dangerous list and potentially the wet in appearance. The most widely- sudden capsizing of the vessel. In cargoes loaded with a moisture known cargoes with this hazard are content in excess of the FMP, mineral concentrates, although many Cargo liquefaction will not occur liquefaction may occur unpredictably other cargoes can also liquefy, such as if the cargo contains a sufficiently at any time during the voyage. Some fluorspar, certain grades of coal, pyrites, low inherent moisture content and cargoes have liquefied and caused millscale, sinter/pellet feed, etc. sufficiently high interstitial air that, even catastrophic cargo shift almost in its most compacted state, there immediately on departure from the Although they often look dry in are still sufficient interstitial spaces to load port, some only after several appearance at the time of loading, accommodate all of the moisture so weeks of apparently uneventful sailing. these cargoes contain moisture in that the increase in water pressure is While the risk of liquefaction is greater between the particles. At the time of inhibited. during heavy weather, in high seas, and loading, the cargoes are usually in their while under full power, there are no solid state, where the particles are in direct contact with each other and, therefore, there is physical strength of resistance to shear strains. During ocean transport, cargoes are exposed to agitation in the form of engine vibrations, ship’s motions and wave impact, resulting in compaction of the cargo. This leads to a reduction of the spaces between the particles. If compaction is such that there is more water inside the cargo than there are spaces between the particles, the water pressure inside the cargo can rise sharply and press the particles apart Iron ore fines before and after liquefaction.

© Gard AS, January 2014 5 safe sailing conditions for a cargo with unsafe moisture content. Liquefaction can occur unpredictably even in relatively calm conditions on a vessel at anchorage or proceeding at low speed.

It is for these reasons that SOLAS and the IMSBC Code incorporate provisions intended to ensure that only cargoes with sufficiently low inherent moisture content to avoid liquefaction are loaded. Strict adherence to these provisions is the only safe way of carrying these types of cargoes.

SOLAS/IMSBC Code Regulations SOLAS requires that the shippers of bulk cargoes provide the Master in writing sufficiently in advance of loading with information on any special properties of the cargo, including the likelihood of shifting, and for concentrates or other cargoes which may liquefy additional information in the form of a certificate on the Flow table test. moisture content of the cargo and its Transportable Moisture Limit (commonly abbreviated to TML).2 whether or not the cargo offered for the moisture content of the test sample Cargoes which may liquefy shall only loading is a cargo that may liquefy.6 is truly the average moisture content of be accepted when the actual moisture This is a very important part of the the entire consignment.10 content is less than the TML.3 shippers’ obligation to provide appropriate cargo information, as it is Sampling for moisture content must Unlike the FMP, which can be not necessarily obvious from the cargo take place not more than seven days determined in the laboratory, the TML name or from a visual inspection of the prior to loading. Additional check is a parameter that is calculated, rather cargo whether the cargo may liquefy, tests should be conducted if there is than measured, as 0.9 times the FMP. and thus whether the Master should significant rainfall between sampling Thus, for example, a cargo with an FMP insist on a declaration of moisture and and loading.11 of, say, 10 per cent (as determined in TML prior to allowing the cargo to be the laboratory) has a corresponding loaded. In principle, any bulk cargo Shippers must declare the moisture TML of 9 per cent, this being 0.9 times that contains at least some moisture content separately for each cargo 10 per cent. and at least some fine particles is at hold of the vessel, unless sampling risk of liquefaction. The IMSBC Code has shown that the moisture content Thus, the maximum allowed moisture specifies that all such cargoes should is uniform throughout the entire content of a cargo at the time of be submitted for laboratory testing to consignment.12 In concentrates, the loading (the TML) is lower than the establish whether or not they possess moisture content is often sufficiently moisture content at which liquefaction flow properties.7 If such testing uniform, but in unprocessed ores such actually occurs (the FMP). This shows that the cargo possesses a flow as iron ore fines and nickel ore, the difference between the TML and the moisture point, then shippers must moisture content can vary significantly FMP is intended to provide a safety provide a certificate of moisture and throughout the consignment and margin to protect against variations of TML prior to loading, regardless of thus separate hold-by-hold moisture in moisture or FMP throughout the whether or not the cargo is specifically declaration is required. In actual cargo and to allow for measurement listed by name in the IMSBC Code as a shipping practice, few if any shippers uncertainties in the laboratory cargo that may liquefy. do declare a hold-wise moisture determination of moisture and FMP. content even in highly non-uniform It is essential that this safety margin 2) Certification of moisture content cargoes, and this is a cause for concern. is always preserved and thus cargoes The declaration of moisture content should never be accepted if the must contain a statement from shippers If more than one distinct type of cargo moisture content exceeds the TML, that this is the average moisture content is loaded commingled in the same regardless of by how much.4 of the cargo at the time the declaration cargo hold, e.g., if loading is from is handed to the Master prior to different stockpiles from a different Full details on the underlying testing start of loading.8 One important source of supply or with different and sampling procedures for shippers’ consequence of this is that the entire exposure to rain, then shippers must certification obligations under SOLAS cargo must already be available at the provide separate certificates for each are given in the IMSBC Code 2009 (and load port to be sampled prior to start type of cargo in each cargo hold. previously in effectively identical form of loading, rather than be delivered Similarly, shippers must carry out in its predecessor, the BC Code 2004)5. piecemeal throughout a protracted separate sampling and certification for In brief, the IMSBC Code specifies the loading process. The moisture content each substantial portion of material following: determination must be carried out on which appears to be different in truly representative test samples of characteristics or moisture content 1) Identification of hazard the entire cargo.9 This is an elaborate from the bulk of the consignment. The Prior to start of loading, the shipper process requiring full access to the moisture content must be below the must declare to the Master in writing cargo and careful planning to ensure respective TML separately for each

© Gard AS, January 2014 6 distinct parcel of cargo. Any portions requirements of the IMSBC Code indeed acknowledge that the cargo that are shown to have a moisture is essential in order to ensure that is a liquefaction hazard by supplying content above the TML should be only cargoes that are safe for ocean a moisture and TML certificate, albeit rejected as unfit for shipment.13 Thus, transport are loaded. The IMSBC Code frequently flawed, some shippers do if cargo is loaded from more than places the burden of certification on not, and without expert knowledge one source, it is not sufficient for the shippers, not on the Master. Without it is difficult for the Master to know average moisture content of all of the accurate information and certification that he should insist on a declaration cargo in each hold to be below the being provided by shippers, the Master of moisture and TML before allowing TML. One important consequence can not independently assess whether loading to commence. of this is that it is not possible to or not the cargo offered for loading compensate for the loading of a batch is safe to carry. This is because it is Implementing a sampling and of excessively wet cargo by then impossible to determine from a visual testing regime that complies with the loading additional drier cargo into the inspection or from ad hoc sampling provisions of SOLAS and the IMSBC same cargo hold. of cargo being delivered to the vessel Code, as summarised above, is a whether or not the moisture content technically much more demanding 3) Certification of TML of a cargo is below the TML. Cargoes task for unprocessed ores than it is As discussed above, the TML is derived with moisture above the TML typically for concentrate cargoes. The IMSBC mathematically from a laboratory look much the same as cargoes with procedures were designed with determination of the FMP. In principle, moisture below the TML. Clearly concentrates in mind and therefore there are several different alternative discernible alarm signals, such as have an implicit assumption of uniform test methods to determine the FMP: separation of free water on the cargo particle size and reasonably uniform three of them are described in full surface or muddy appearance of the moisture distribution throughout the detail in Appendix 2 of the IMSBC cargo, are only visible during loading entire cargo. Neither of these applies Code and the competent authority when cargoes have a grossly excessive to unprocessed ores. of the exporting county may approve moisture content. additional test procedures.14 In It is an unfortunate combination actual shipping practice, the only test Unprocessed ores - Iron ore fines that although sampling and testing method that is in widespread use is and nickel ore cargoes of unprocessed ores is a the flow table method, as described in There is a wide range of mineral technically more demanding task than paragraphs 1.1.1 to 1.1.4 of Appendix cargoes that may liquefy, and they for concentrate cargoes, the shippers 2. While the test method is not difficult, vary in their appearance and physical of these cargoes are typically relatively it contains a subjective element properties. One sub-group of small operators often lacking in the and needs to be carried out by an cargoes has a particularly dangerous knowledge, expertise and technical experienced analyst who is familiar with combination of risk factors, and infrastructure, and sometimes the the early signs of liquefaction in a test accounts for a large proportion of will, to comply with their SOLAS and sample. The critical part is the ability to recent casualties, near misses and IMSBC Code obligations. Because of reliably identify a flow state in the test contentious load port disputes during the unprocessed nature of the cargo, sample using the criteria given in the carriage of cargoes that may liquefy. shippers have only very limited control Code.15 It is a matter of some concern over moisture content and some that laboratories testing iron ore fines The cargoes in question are shippers may not actually be able to in India and nickel ore in Indonesia unprocessed ores, the most widely- supply cargoes that meet the SOLAS and the Philippines depart in many encountered of which are iron ore fines, requirements. important respects from the IMSBC mainly exported from India, and nickel Code test procedure without approval ore, mainly exported from Indonesia, Following are some of the technical from the respective competent the Philippines and New Caledonia. issues that need to be considered authorities and without conducting Unlike concentrates, these are simply by shippers when designing their systematic inter-laboratory comparisons dug out of the ground in open-cast certification procedures. to establish consistency of their results mines in mineral-rich, and often remote, with laboratories using the unmodified locations and are presented for ocean The physical composition of IMSBC Code method. transport with little or no processing. unprocessed ores varies significantly Thus, where concentrates have a highly even within a single open cast pit, For most processed ores, such as uniform particle size and physical and even more so as most cargoes concentrates, the TML depends consistency, unprocessed ores are very are mixtures of material dug out mainly on the technical details of the heterogeneous, consisting of a mixture from several, and sometimes very concentration process and does not of fine-grained ore, clay-like material, many, individual pits, which may be vary significantly between shipments. pebble-sized stones and the occasional distributed over a wide geographical For these cargoes, it is sufficient if larger lump. area. As a result, the TML may vary shippers carry out a TML test once greatly from one part of the cargo to every six months. However, if the For shipowners contemplating carriage another, but in an unsystematic and composition or characteristics of the of these cargoes, and for Masters unpredictable manner, which does cargo are variable between successive instructed to load them, a major not allow to simply test each source of shipments for any reason, then a difficulty is that neither iron ore fines material separately. new TML test is required each time.16 nor nickel ore have a specific listing Unprocessed ores such as iron ore in the IMSBC Code and thus it is not The moisture distribution throughout fines and nickel ore vary greatly in immediately obvious from consulting each cargo is typically highly non- composition not only from shipment to the Code that these are indeed uniform. The material is already shipment but also within each individual cargoes that may liquefy. Unless variable in moisture at the time it is shipment. Thus, for these cargoes, he is already aware of the potential dug out of the ground. Most mining shippers must carry out a new TML test hazards from other sources, the Master locations are in tropical countries with for every single cargo being loaded. is dependent on shippers correctly frequent heavy rainfall and the cargoes declaring the cargo as a liquefaction are typically transported in open lorries/ Close adherence to the above hazard. Although most shippers do wagons and stored in open stockpiles

© Gard AS, January 2014 7 leading to unpredictable increases in In India, shippers of iron ore fines used but you break the law if you drive faster moisture. to ignore their SOLAS obligations to than the speed limit. provide a TML certificate until quite 5 The IMSBC Code may be applied The IMSBC Code specifically states recently. Independent laboratories voluntarily from 1st January 2009 and that the ubiquitous test method for offering TML testing have only started will become mandatory under the TML determination, the flow table to operate in the country after the provisions of SOLAS from 1st January method, is unsuitable for materials 2007 monsoons. Although there are 2011. containing particles above 7mm in now many laboratories in India, all 6 IMSBC Code, Para. 4.2.2.2. The size.17 This creates a dilemma for of them were started quite recently IMSBC Code classifies cargoes that may laboratories testing unprocessed and therefore there is little or no liquefy in cargo group A and requires cargoes, which frequently contain experience data available to assess shipper to declare the cargo group. pebble-like stones above that size. their reproducibility and consistency 7 IMSBC Code, Appendix 3, Para. 2.1. Nickel ore, in particular, often has a with leading international laboratories. 8 IMSBC Code, Para. 4.3.2. very high proportion of lumps above To date, there has been no centralised 9 IMSBC Code, Para. 4.4.1 to 4.4.4. 7mm. Iron ore fines are generally accreditation or inter-laboratory testing 10 IMSBC Code, Para. 4.4.4. somewhat finer, but some cargoes effort to establish the soundness of Paras. 4.6.1 to 4.6.6 give a set of also have a significant proportion of the test procedures used by Indian recommendations for concentrate lumps above 7mm. The most frequent laboratories. stockpiles that specify the minimum workaround to avoid this problem is number of sub-samples to be taken to screen out all particles above 7mm In Indonesia, the Philippines and to make up the representative prior to analysis and to conduct the New Caledonia, mining locations sample. For a cargo of (say) 40,000 TML test only on the proportion that is are typically very remote indeed, MT a minimum of 160 sub-samples is below 7mm in size. When doing so, it is and loading takes place at natural required. For cargoes that are more essential that the particles above 7mm anchorages close to the mines, inhomogeneous than concentrates, are removed from both the sample well away from any sophisticated including iron ore fines and nickel ore, submitted for TML testing and the infrastructure. The mines therefore collecting a sufficiently large number samples used to certify the moisture generally operate their own flow of sub-samples is even more important content of the cargo. Failure to do so table for TML testing in their in- than for concentrates. will systematically overstate the safety house laboratories rather than using 11 IMSBC Code, Para. 4.5.2. of the cargo and may therefore lead independent laboratories. On closer 12 IMSBC Code, Para. 4.3.3. to cargoes being accepted for loading scrutiny, many of these in-house 13 IMSBC Code, Paras. 4.3.3 and 4.4.3. that are actually unsafe. laboratories have been found to 14 IMSBC Code, Paras. 4.1.4 and 8.3. be poorly equipped and to depart Appendix 2 contains the actual test Because of the non-uniform nature significantly, and sometimes grossly, procedures to determine the FMP and of unprocessed ore cargoes, samples from the test procedures set out in the TML, including the flow table method in from every single cargo need to IMSBC Code. Paras. 1.1.1 to 1.1.4. be submitted for laboratory TML 15 IMSBC Code, Appendix 2, Paras. testing. Shippers therefore need Footnotes 1.1.4.2.3 and 1.1.4.3. to have a suitably equipped and 1 See article “Carriage of dangerous 16 IMSBC Code, Para. 4.5.1. qualified laboratory close at hand for cargo - Questions to ask before you 17 IMSBC Code, Appendix 2, Para. TML testing to achieve acceptable say yes” elsewhere in this issue of Gard 1.1.1. turnaround times between sampling News. and certification. This differs from 2 SOLAS, Chapter VI, Regulation 2, shippers of concentrate cargoes, Para. 2.2. who only need to submit one sample 3 SOLAS, Chapter VI, Regulation 6, every six months, and therefore do Para. 2. not find it onerous to courier samples 4 The difference between moisture to reputable laboratories overseas. content and TML is a frequent source TML testing is a specialised task, and of confusion, leading to nonsensical there are few laboratories worldwide statements such as “The TML of the who have a track record of obtaining cargo increased because of rainfall”. reproducible results and participating in The TML of a cargo depends on the inter-laboratory comparisons over many type and composition of the cargo, but years. None of these are in the main is not affected by whether the cargo is exporting countries of unprocessed wet or dry. The TML is similar to, say, a ores. speed limit on a road. The speed limit does not depend on how fast you drive,

Gard Alert, Intercargo publishes February 2012 guide for the safe loading of nickel ore

The International Association of Dry protect cargo on barges from any Cargo Shipowners (Intercargo) has precipitation and water ingress. recently published the “Guide for the Safe Loading of Nickel Ore”, which • Responsible shipowners must check aims to explain, through use of a flow- that the cargo documentation is chart, how nickel ore can be safely provided as required in the IMSBC shipped, within limitations, whilst raising Code. awareness of the serious problem of cargo liquefaction. It is targeted at the • Before fixing, chartering widest possible audience within the departments should refer to their industry, including shippers, shipowners own internal procedures regarding and masters. the acceptance of nickel ore cargoes. In addition to a chart describing what to look for when loading nickel ore, the Intercargo also points out that the so- guide recommends that: called “can test” is insufficiently robust as a means of checking cargo safety on • Responsible shippers must not its own. misrepresent cargoes. In order to provide accurate cargo declarations A copy of the guide can be found shippers should have in place here: http://www.gard.no/webdocs/ procedures for sampling, testing Intercargo_Nickel_Ore.pdf. We are and controlling moisture content grateful to Intercargo for their kind of cargoes including procedures to permission to reproduce the document.

Gard News 150 Shifting solid bulk 1998 cargoes

An explanation of the processes of that described above. The gravest Cargo Code referred to above adopts dangers consequence of shifting is capsize of what is known as the Transportable Solid bulk cargoes can shift by sliding the vessel, and this can happen when Moisture Limit (TML), and this is the or liquefying, and whilst the factors multiple shifts occur with little return maximum moisture content of a cargo involved in each of these processes of cargo to original positions. This deemed safe for carriage by sea in are different, the potentially disastrous process can be very quick and obviously ships other than “specially designed consequences are the same – listing or disastrous. ships”. It is defined as 90 per cent of capsizing and/or structural damage. the FMP. Cargoes prone to liquefaction Sliding occurs when the cohesive are those with a small particle size and Dense cargoes, e.g. ore concentrates, strength, or “stickiness” of the cargo, those which contain moisture as a result have by definition a relatively high mass is insufficient to withstand the effects of the way they are processed before to volume ratio, so even a small amount of rolling. Cohesive strength varies loading, e.g. iron ore concentrates and of shifted cargo can have a large according to moisture content and coal slurry or duff4. mass. Coupled with the momentum the height of the stockpile. A good generated by a moving vessel illustration of this is provided by sand. It is perhaps worth mentioning here considerable forces can act upon the Wet or dry there is a limit on the height that solid bulk cargoes are increasingly ship’s structure. This force will be even of a pile of sand, but damp sand tends being carried in Intermediate Bulk greater when the cargo level within the to permit a higher sand pile. A common Containers (IBC)5. The Association’s hold is above the sea level outside the example of a cargo prone to sliding is experience with this type of carriage hold, so that the counter-acting force grain2, which is particularly free flowing. suggests that the dangers of shifting of buoyancy is absent. Add to this the The International Maritime Organisation cargo can be just as real. Solid bulk frequent occurrence of multiple or (IMO) Code of Safe Practice for cargoes which are prone to sliding have repetitive shifts and the result can be Solid Bulk Cargoes 1991 states (at been known to force the sides of even excessive plate flexing increasing the para 5.2.4.2) that “non-cohesive bulk rigid IBC’s to move and if there are risk of cracking and failure. cargoes having an angle of repose3 gaps within the stow, or the sides of the less than or equal to 30 degrees flow stow are insufficiently shored, a general In terms of stability1, shifting cargo can freely like grain and should be carried collapse of the stow can occur. have numerous consequences. The according to the provisions applicable shift in cargo will cause a list if the cargo to the stowage of grain cargoes”. A case example – Liquefaction of does not return to its original position The stowage and carriage of grain is scale dust with subsequent vessel movement. governed by the IMO Grain Rules 1982 An increasingly common solid bulk Apart from increased draft concerns, which set out a number of requirements cargo is dust, commonly originating the angle at which the vessel is listed including specific stability criteria. from industrial chimneys. Industry has will, if uncorrected, become that about There is also some industry authority to for some time been required to limit which the vessel rolls. This will usually support a theory that sliding can also the pollutants discharged into the mean that the righting lever for angles occur when, due to downward moisture environment and to this end chimneys of heel towards the side the vessel migration, a saturated base layer can be installed with filters. The material is listed will be less than that when (which need not be liquefied) is formed collected by these filters is generally the vessel is heeled from her upright allowing the upper, relatively drier layer, termed filter dust; material which builds position, which in turn means that the to move against it. up on the inner chimney surfaces also force returning the vessel from angles gives rise to another type of dust – scale of heel beyond the angle of list, back Liquefaction of solid bulk cargoes dust. The contents of these substances to the same angle, will be less than depends on particle size and vary enormously and chemical hazards the force returning the vessel to the distribution as well as moisture content. are often associated with them. This is upright had she not been listed. The The former determines whether one of the reasons why many societies angle of deck edge immersion will moisture can drain freely through the in our greener world no longer allow also be closer than that for an upright cargo, and will obviously change during them to be left stored and forgotten vessel and if this is reached stability will a vessel’s voyage due to vibration, on open slag heaps or in land-fill sites. also be reduced. A list will also tend to rolling, pitching and twisting. The The option to be considered in many subject the vessel to greater angles of effect of this movement is to break of today’s societies is re-cycling and it heel and this may give rise to a domino down lumps of cargo and reduce the is this which has, to some extent, led to effect causing other cargo and objects space between particles – effectively the water transport of dust. to break securings and/or to shift. Solid compacting the cargo. Moisture can bulk cargoes that shift from one side of then become trapped between cargo The problems and dangers of watery the vessel to the other with the rolling particles and if there is sufficient filter dust were last mentioned in Gard of the vessel, that is to say, cargoes saturation a flow state can develop. News Edition 1046, and a recent case behaving like a liquid in a part-filled The point at which this occurs is called involving scale dust suggests to us tank, will also give rise to a Free Surface the Flow Moisture Point (FMP) and is that these problems and dangers are Effect, and this again will reduce the usually expressed as a percentage of not fully understood and that essential vessel’s stability in a similar way to the moisture content. The IMO Bulk precautions are not being adhered to.

© Gard AS, January 2014 10 The vessel in question loaded at Lessons learned and precautions (6) The cargo space should be filled Algeciras, Spain, and the scale dust to be taken as much as is practicable, but always in bulk was to take up most of her It is perhaps fair to say that the within stability, stress and deck loading centre hold. The majority of the scale above vessel was fortunate to have constraints. A part-filled compartment is dust was noted by the master to be completed her voyage without more more prone to shifting and has greater in open storage on land, unprotected serious incident. Having read the case space in which to allow shifting. from the elements, and on closer summary, the reader will probably be (7) Longitudinal separation (e.g. examination, was found to have a high able to find a number of areas where temporary bulkheads), and overstowing moisture content in parts. Whilst the essential additional precautions could (e.g. bulk bundles) can be effective in master was concerned as to the state have been taken. Outlined below are limiting the distance cargo can shift, the of the cargo, loading commenced, and a number of points which should be shift amount and forces involved. Expert since this took place during periods considered when contemplating the advice is recommended to ensure of rainfall, moisture levels increased. loading of solid bulk cargoes suspected that these measures are appropriate. No documents were produced by the of having a propensity to shift. In addition, overstowing may not be shippers to record the properties of the (1) Carry out a visual examination of appropriate, and shifting forces are scale dust, and when the master did the cargo and enquire as to the extent often underestimated thus risking the raise concerns with the various cargo and duration of exposure to moisture failure of longitudinal separation. interests, including their surveyors, (unprotected stowage on wet ground or (8) Cargo stows should be trimmed he was told that the loading of the in wet weather). level right out to all sides of the cargo cargo during rain, and the wetting (2) Obtain and keep safe ship’s own compartment. It is appreciated that of the cargo, was normal and of no samples (the quantity should be trimming has its disadvantages, e.g. importance with regard to the quality of sufficient for any necessary tests and increased time and cost at load and the cargo. be properly labelled and recorded etc). discharge ports. However, it has more Do not just accept shippers’ samples, important advantages. Apart from The loading of the cargo seemed to unless these are taken in your/your reducing the possibility of cargo shift, be completed without further event representatives’ presence. weight distribution and stability are or protest and clean bills of lading (3) Request in advance of the vessel’s improved. were issued. On the loaded passage arrival, the shippers’ declarations with (9) Do not stow other cargoes the vessel encountered moderately regard to FMP, stowage factor, TML, containing moisture in same heavy weather, causing heavy rolling moisture content, angle of repose, any compartment. and pitching at times. Four days into chemical hazards and details which (10) Do not load during rain. If this the passage a series of splashing and may require safety precautions to be cannot be avoided have the moisture banging noises were heard which taken7. If such documentation is not content re-tested to ensure that it seemed to come from the hold forthcoming it should be demanded complies with point 5 above (it should containing the scale dust. Inspection and a letter of protest to shippers be noted that some cargoes can be of this hold revealed that the scale and charterers should be issued. The damaged by exposure to moisture). dust had become fluid and was master can and should refuse to load (11) If possible, adjacent tanks to the splashing violently against the hold the cargo if the documentation is still compartment concerned should be sides. The inspection itself was not not forthcoming8. Remember that each empty. If they cannot be made empty, without danger as a 5 – 6 metre geyser individual cargo is unique. Details of extra care should be taken to ensure erupted from the booby hatch opened cargoes previously carried, even if from that watertight integrity is intact. This for inspection. The resultant mess on the same origin, should not be relied recommendation also applies for the the ship’s superstructure was the least on. whole compartment; hatch covers in of the worries facing the master as (4) Check the details of the shippers’ particular should be closely examined shortly afterwards the vessel took on declaration carefully. The details should and tested (hose/chalk/day light tests). a list. Fortunately the vessel was able be accurate at the time the certificate (12) The vessel should not be too stiff in to compensate for this by careful and is issued and the combination of a terms of her stability as this will cause strategic ballasting and was able to pre-dated declaration and suspected the vessel to roll quickly and perhaps reach the discharge port without further exposure to further moisture since violently. In saying this, the vessel needs serious incident. the date of the certificate should an adequate metacentric height taking raise concern. Some ports have rain into account all the various factors Further inspection at the discharge gauges to assist in the quantitative which can lead to a reduction in this port revealed that the forces involved assessment of the effects of rainfall on during the voyage. with the shifting of the liquefied scale moisture content after certificates have (13) Bilges should be clean and empty, dust had resulted in the penetration of been issued. If suspicions are raised, strums or rose boxes should be clear the cargo into an adjacent hold under the shipper should be requested to and lumber boards, where fitted, should and above a moveable transverse grain perform the necessary tests. In any be intact. Bilge well grilles should be bulkhead. Problems ensued with the event, loading should not commence covered with burlap. The pumps and consignees who held the vessel liable again until the vessel itself is satisfied bilges should be tested in all respects for loss and damage to the cargo and that the cargo can be transported. (particularly alarms and non-return the extra costs of discharging and It may be necessary for the ship to valves) prior to loading. Soundings are storing the fluid cargo. The surveyors perform its own tests9. Do not be led to be taken at regular appointed by the owners learnt that astray by shippers proclaiming that all intervals during the voyage and bilges the surveyors appointed on behalf of is fine and normal and that the cargo pumped as necessary. Concerns as shippers, had issued a “certificate” of quality will be unaffected. This is not a to the effect of cargo weight loss due the moisture content at the loading quality issue, it is a safety issue. to moisture removal are understood, port and given this to the consignees, (5) In any event, cargoes with a moisture but again there are more important but not to the master. The certified content above the TML should not be concerns. To protect owners’ position it moisture content was said to be in the shipped. Remember that it may only be is recommended that a record is made region of 11 per cent but tests at the necessary to reject parts of the cargo, of the amounts of moisture removed discharge port determined a moisture but this should raise concern as to the via the bilges, and this can be done by content of nearly double this figure. safety of the remaining cargo. soundings.

© Gard AS, January 2014 11 (14) Weather routing is recommended Footnotes safe cargoes and without the necessary in order to avoid heavy weather and/or 1 For a guide to the basic principles of documentation this can not be determined. sustained periods of it. transverse stability (including definitions used Laytime disputes may arise and it is recommended that charterparties expressly (15) Always consult the relevant IMO/ in this article) please refer to the article in Gard News Edition 145, March 1997 (pages 14–18). stipulate that time lost due to non-production flag state/port state/company codes/ 2 The term grain includes wheat, maize, oats, of the necessary documentation and/or due guidelines/recommendations. Port rye, barley, rice, pulses and seeds. to reasonable measures taken by the ship states in particular may impose 3 The angle which the cargo naturally, and of its where the accuracy of document details is stricter rules than those adopted own accord, makes with the horizontal. reasonably suspected, is to be counted as laytime. Diversion to a port of refuge may internationally, e.g. with regard to the 4 The IMO Code of Safe Practice for Solid Bulk Cargoes 1991 (as amended) lists some also be necessary and it is recommended that TML. commodities which may liquefy. charterparties make provision for charterers to (16) If in doubt and assistance is 5 An IBC may be described as a disposable or bear the costs and consequences of this where needed, the Association is always on re-usable receptacle designed for the carriage caused without the owners’ negligence. hand. of bulk commodities in parcels of 0.5 to 3.0 9 The IMO Code of Safe Practice for Solid Bulk tonnes. They can be of rigid (e.g. fibre board) or Cargoes 1991 sets out the tests and procedures. flexible (e.g. bags) construction. In conclusion, shifting solid bulk 6 December 1986 (page 13). cargoes can be costly, not least in 7 As of 1st January 1994 it became a SOLAS terms of money, but people’s lives. requirement for the shipper to provide this type The dangers are real and are not to of information. See International Convention for be ignored – precautions need to be Safety of Life at Sea 1974 (as amended) Chapter VI, Part A and specifically Regulation 2. adhered to. 8 Charterers are obliged to load only

Gard News 197, The carriage of nickel February/April 2010 ore from the Philippines and Indonesia - The insurance position

Advice should be sought regarding the the nature and characteristics of the considered to be an “unlawful, unsafe position under the P&I and hull and cargo his ship will be carrying. Rule 7 or unduly hazardous trade or voyage”. machinery policies before agreeing to of Gard’s P&I Rules for Ships deals with carry nickel ore from certain ports. a situation where the risk is altered. Furthermore, and although not stated A similar rule concerning hull and explicitly in Gard’s P&I Rules, it is a The previous article in this issue of machinery insurances can be found condition of cover that any dangerous Gard News, by Brookes Bell, identifies in §§ 3-8 to 3-13 of the Norwegian cargo is carried in full compliance with the potential problems and dangers Marine Insurance Plan. It seems clear the IMO Code of Safe Practice for Solid facing a shipowner who is asked to from Brookes Bell’s article that a ship Bulk Cargoes (the BC Code). Similarly, load a cargo of nickel ore in the ports may be invited to load cargo with the BC Code may be considered as a and places mentioned in that article. characteristics which have either been safety regulation in relation to hull and Any owner who is asked to load such a misdeclared by the shippers, or which machinery policies, whereby a breach cargo is recommended to contact Gard can not be ascertained accurately by of the Code may affect cover. See in relation to either their P&I cover or the tests which have, according to for instance § 3-22 and § 3-25 of the their hull and machinery cover, or both the shippers, been performed. In Norwegian Marine Insurance Plan. The if both are placed with Gard, for advice such circumstances, it is likely that circumstances described by Brookes as to the position under the relevant Gard will take the view that the risk Bell indicate clearly that the insufficient insurance policy(s) if it is decided to being assumed by an owner who, and/or inaccurate testing performed by load the cargo on offer. nevertheless, agrees to load such a the shippers and the resulting inability cargo is altered. on their part to accurately state the Each case will be considered on characteristics of the cargo as required its own merits, but some general Rule 74 of Gard’s P&I Rules (Unlawful by the BC Code mean that such comments can be made. Firstly, it is trades, etc.) may also be relevant requirements will almost certainly not essential that a shipowner identifies insofar as the loading and carriage have been met. accurately and informs the insurers of of misdeclared nickel ore can be

Gard News 205, Cargo liquefaction - February/April 2012 An update

Solid bulk cargo liquefaction continues it is the shippers who are obliged result of cargo liquefaction and shift to be a hot topic for P&I Clubs and their under the IMSBC Code to declare that in bad weather. However, the cargo Members. There have been several a consignment is fully and accurately documentation provided to the masters recent developments on which to described, that their given test indicated that the moisture content of update readers. results are correct to the best of their the cargo samples was lower than the knowledge and are representative of Transportable Moisture Limit (TML)”. Background the cargo to be loaded. The answer, The topic of cargo liquefaction gained and what lies at the heart of the Market forces appear to be driving prominence in Gard News in the early problem, is inaccurate declarations and ships to carry cargoes that may liquefy. part of 20101 and since then Gard has certificates from shippers. This may dealt with a large number of enquiries range from cargo being mis-declared The reasons behind inaccurate and requests from Members to arrange as Group C (i.e., cargo not liable declarations and certificates are precautionary surveys. Despite the well- to liquefy), to inaccurate FMP (flow numerous and in Gard’s experience publicised potential dangers, it appears moisture point)/TML (transportable these can range from a complete lack that market forces are driving ships to moisture limit) figures and/or moisture of knowledge that the IMSBC Code carry cargoes that may liquefy and weak content. Judging by what has been exists, a lack of understanding of the freight markets may make it difficult reported at IMO level, this appears to IMSBC Code, improper sampling for owners and charterers to pass up have had disastrous consequences in and analysis procedures/equipment employment opportunities. some cases where it is likely that ships and even deliberate manipulation and crews had relied on declarations/ of samples/test results. The latter is Since early 2010, Clubs in the certificates being accurate. In 2010 particularly concerning and may arise International Group of P&I Clubs (IG the IMO issued a circular5 referring to because shippers are unwilling or Clubs) have issued circulars alerting two serious casualties in the monsoon unable to provide cargo with a moisture Members to the dangers and problems season of 2009 and many near-misses content below the TML because to do of iron ore fines shipped from India on ships engaged in the carriage of so would require an investment in time/ as well as nickel ore shipped from iron ore fines. In that circular the IMO costs to remove moisture. This may Indonesia and the Philippines.2 stated: “some shippers have in the particularly be the case where cargoes Concerns have also arisen with regard past declared iron ore fines as iron ore, are simply shipped straight from the to other cargoes and countries of which is a Group C cargo”. This was ground without any processing. shipment, such as sinter feed from followed by the loss of 45 seafarers Brazil,3 chromite ore and mill scale. and three vessels carrying nickel ore Other problems and complications The problems are often exacerbated from Indonesia and a submission by Whilst unreliable shippers’ declarations by commercial pressures, and in China to the IMO in March 2011 which and certificates may be at the heart difficult market conditions, owners stated that “According to the evidence of the problem, this is complicated by will feel under greater pressure from available, the direct cause of these several other problems, some of which charterers and shippers seeking to accidents was the loss of stability as a are discussed below. persuade owners to avoid extra costs and delays, such as may be caused by owners’ own surveys and tests on cargo waiting to be shipped. Various charterparty clauses have been seen in circulation that attempt to weaken, avoid, and/or restrain owners’ ability to take appropriate and necessary precautions, such as those set out in the aforementioned Circulars. This resulted in the IG Clubs recently producing a standard charterparty clause to assist owners in trying to resist commercial pressures that could lead to the International Maritime Solid Bulk Cargoes Code (the IMSBC Code) provisions and precautions related thereto being compromised.4

The heart of the problem Members may well ask why they should go through the time, cost and trouble of arranging their own survey, sampling and analysis of cargo, when Market forces appear to be driving ships to carry cargoes that may liquefy.

© Gard AS, January 2014 13 Successful shipment history for analysis also presents a logistical especially with regard to the FMP/ A number of shippers and charterers challenge (especially if the laboratory TML, is also a problem, not just in the are quick to point out that many is located overseas). For example, for country of shipment, but world-wide. cargoes have successfully reached a stockpile of 50,000 MT, sampling With many competent laboratories their destination without incident according to the IMSBC Code requires located outside the country of shipment and without owners having arranged 200 samples to be taken and then there can be significant delays and their own precautionary sampling combined to at least 50 sub-composite costs. Often owners take the decision and analysis. There may be numerous samples. Owners trying to avoid delays to start loading pending laboratory reasons for this, such as the fact that by making early survey arrangements analysis results, but this can also lead cargoes are rarely homogenous in all can also face the problem that, to complications if such analysis shows holds, as well as the weather and sea according to the IMSBC Code, the the cargo to be unsafe. However, a lot conditions. Some voyage orders have time interval between moisture content of good work has been done, notably been known to advise masters to avoid testing and sampling shall not be more in India, where industry experts have heavier seas/weather, which is rather than seven days. If unprotected cargo witnessed proper testing in a number impractical and ignores the fact that is affected by precipitation between of independent laboratories, often conditions can not always be accurately testing and loading, further sampling through training by the very same forecast, particularly at a local level. and analysis would be required. It is experts. Perhaps a significant factor is that the also worth mentioning here the danger TML is set at 90 per cent of the FMP, of Members and their crews over-relying in other words there is a 10 per cent on ‘can tests’. Whilst these may indicate The on-board rectification of safety margin. A cargo may therefore if cargo is unfit for shipment they can cargo moisture levels is far from have a moisture content above the not determine if a cargo is fit to be straightforward. TML, but not so high as to reach the loaded - this can only be determined by FMP. All this said, it is fair to say that proper laboratory testing. To make this Cargo already loaded the precise reasons why some cargoes clear, one of the revisions to the IMSBC If cargo is loaded and subsequent liquefy and some do not are not fully Code agreed at the 16th Session of concerns arise as to its fitness for safe understood. It is reasonable to assume IMO Sub-Committee on Dangerous carriage, there is the obvious problem that the IMSBC Code has been drafted Goods, Solid Cargoes and Containers of identifying within the bulk what parts with this in mind. Sadly, it would seem (DSC 16) was to make clearer the of the cargo are unfit. Often, therefore, that numerous shippers and indeed limitations of the ‘can test’ by adding the whole bulk has to be discharged. some owners do not feel obliged to to the IMSBC Code a statement that “If However, it can be extremely difficult to comply with the IMSBC Code. It is not samples remain dry following a can test, get cargo re-discharged at the place of uncommon to hear that, following the the moisture content of the material loading. This may be because of a lack rejection of cargo by one owner, the may still exceed the Transportable of facilities to take cargo back: in some very same cargo is loaded onto another Moisture Limit (TML)”. remote locations cargo is bulldozed ship. into barges from ashore and whilst Testing cargo can be off-loaded to barges with Sampling Some shippers have questioned the ship’s cranes, shippers may have a The IMSBC Code includes provisions whether the tests recognised by the problem getting it back ashore. There for sampling and there is often IMSBC Code are suitable for certain may also be complications caused by a problem obtaining sufficiently cargoes, particularly if they have a local customs regulations, which may representative samples. Owners larger particle size and/or the cargo consider a cargo to be exported once are often refused access to shore consists of only a small portion of loaded. Quite often, when owners find stockpiles, if indeed there are any, as fine material that may liquefy. Experts their ships with unsafe cargo on board, some cargoes are taken directly from advising Gard and the IG have been lawyers are instructed and legal battles the ground and loaded to the ship. able to successfully test numerous with charterers and others ensue. The Even if access to stockpiles is given, cargoes, using the different test on-board rectification of cargo moisture shippers may not make clear which methods, with reasonable consistency. levels is far from straightforward. Many stockpiles will be used to load the The lack of independent laboratories attempts, using various techniques, vessel. The number of samples required that are competent to perform testing, have been carried out but with limited success, particularly in holds that are full.

P&I cover Whilst Gard does not see the P&I cover as a complication or problem as regards liquefaction issues, Members may benefit from the clarification given below.

Gard has taken the decision not to afford cover for the cost of precautionary surveys. Some say that such surveys are a measure to avert or minimise loss. Subject to certain provisos, Gard’s Rule 46 provides cover for “extraordinary costs and expenses reasonably incurred on or after the occurrence of a casualty or event for the purpose of avoiding or minimising any liability on the Association”. Whilst it is The on-board rectification of cargo moisture levels is far from straightforward.

© Gard AS, January 2014 14 debatable whether any event has taken Member loads unsafe cargo from a Local pressures place at the time a precautionary survey country where there is a history of Mention has already been made of is requested, the key point in Gard’s unreliable shippers’ certificates, doing commercial pressures. There are also view is that the primary purpose of such so solely on the basis of ‘can tests’ and local pressures, despite the fact that surveys is to confirm that the cargo is without independent sampling and some states, such as India, have taken safe for carriage and not to minimise analysis.8 Of course, much depends the problem seriously and introduced any liability on the Club. on the facts of each case and there are national regulations in support of the likely to be a number of facts (notably IMSBC Code. For example, a circular In addition, Gard’s Rule 8 provides that whether or not the cargo is unsafe and/ recently issued by one Indian port “it shall be a condition of the insurance or the shipper’s certificates are accurate) authority, concerned with the effect of the Ship that...) the Member shall unknown to the Club at the time cargo of loading stoppages on berthing comply or procure compliance with is presented for shipment and Members schedules, required the production all statutory requirements of the state seek the Club’s position on cover. by the owners’ P&I surveyor of test of the Ship’s flag relating to the...safe certificates together with a statement operation...of the Ship”. The IMSBC Gard’s view is that it essentially boils by the surveyor that the cargo was fit Code is part of SOLAS (a statutory down to a question of risk which one for loading. The circular went on to requirement) and under SOLAS the Member may be prepared to take, but suggest that if, despite such certificates, master has an overriding duty and which at a certain level, the mutual vessels subsequently stopped loading, authority not to load the cargo or to membership of the Club can not surveyors’ licences would be reviewed. stop the loading of the cargo if he has reasonably be expected to share. Is it This is a good example of the pressures any concerns that the condition of the right that an owner who does not follow that local surveyors often face, not least cargo might affect the safety of the the recommended precautions, thus since such pressure may cause them ship. avoiding time, trouble and cost, should to believe they are being asked to get the same level of cover as one who choose between their own livelihood It should also be borne in mind that does? and the lives of those on board ships. bulk carriers are not the only ships It is worth emphasising here that a that carry dangerous cargo. Container Cargoes not listed in the IMSBC surveyor appointed by the Club on ships carry many dangerous goods Code behalf of the owners is not speaking and the Club can not be expected The fact that a number of cargoes that for the Club itself. Neither the Club to pay for surveys to check that the may liquefy, such as nickel ore and iron nor the owner can confirm whether or numerous dangerous cargoes are safe ore fines, are not listed in the IMSBC not a particular cargo is safe to carry for carriage. For similar reasons as those Code causes uncertainty. However, the and it is not their obligation to do outlined above, P&I cover is unlikely to IMSBC Code recognises (in section 1.3) so under the IMSBC Code. Owners respond to the cost of discharging an that some cargoes that may liquefy may should be aware that doing so could unsafe cargo. be not be listed in it. The IMSBC Code prejudice any potential recourse against also states that “many fine-particled a shipper/charterer were something So what costs does Gard cover? Clearly, cargoes, if possessing a sufficiently to go wrong. Local tensions have also the carriage of these cargoes may give high moisture content, are liable to seen surveyors and experts, especially rise to various claims for which Defence flow. Thus any damp or wet cargo those from overseas, refused access to cover may be available, including containing a proportion of fine particles ports. Local authorities have also been survey costs in connection with such should be tested for flow characteristics known to have threatened legal action claims and incurred with prior approval prior to loading”.9 In addition, Group against the removal of samples from from Gard. Cover may also be available C cargoes are defined in the IMSBC the country for testing overseas without if a survey is subsequently used in the Code as cargoes not liable to liquefy their prior approval (which is unlikely to defence of a claim that is covered by and Group A cargoes are defined as be given anyway). P&I. That brings us to the more difficult cargoes which may liquefy. The words issue of Club cover where a Member emphasised tend towards a more What is being done to address the does not follow the recommendations cautious approach, which given the problems? made by the Club, notably those potentially disastrous consequences, is Alerting Members to the problems and set out in the International Group wholly appropriate. dangers has been a priority in the past of P&I Clubs circulars. As stated in year. Members have then been able to those circulars “...if a Member fails to At the 16th Session of the IMO Sub- raise the level of awareness within their comply with the [IMSBC] Code or local Committee on Dangerous Goods, Solid own organisations and with long term regulations when not in conflict with Cargoes and Containers it was agreed, business partners. Whilst Gard tries to the Code, they should also be aware as a matter of principle, that if a cargo lend as much support to its Members that they might be prejudicing Club may liquefy it should be categorised as it can, this is an industry problem that cover. All of the Group Clubs have as Group A. As mentioned above, needs to be addressed at a national similar Rules which in essence exclude section 1.3 of the IMSBC Code deals and international level. cover for liabilities, costs and expenses with cargoes not listed in the IMSBC arising from unsafe or unduly hazardous Code and if such a cargo may liquefy National level trades or voyages”.6 Until such time the IMSBC Code requires preliminary As already mentioned, some states as Gard or the IG Clubs may decide suitable conditions for carriage to be have recognised the problems and to take a stricter line, Gard’s approach set by three competent authorities, i.e., dangers of liquefaction and have has been to forewarn Members that those in the port state of loading, the taken action. For example, The Indian there is a grave risk of losing cover7 if flag state of the ship and the port state government, through the Directorate the Member knowingly carries unsafe receiving the cargo. Gard has yet to see General of Shipping (DGS), has issued a cargo, for example where independent any such ‘tripartite agreement’ issued number of Merchant Shipping Notices test results on samples show a moisture in respect of nickel ore or indeed iron which generally support the IMSBC content in excess of TML. Members ore fines (despite IMO circular DSC.1/ Code. China is also understood to be are also at significantly greater risk of Circ.66 recognising that iron ore fines in the process of drafting regulations. prejudicing cover if unsafe cargo is are not listed but may liquefy). It is of course important for national loaded without any checks, or if the provisions to be in uniformity with the

© Gard AS, January 2014 15 internationally agreed IMSBC Code. Pre-fixture/order time as the risks of liquefaction in a Where they broadly are, these can - If the vessel is on time charter, check given cargo can be identified with be powerful points of reference for whether the cargo is permitted under more certainty, the role of authorities shippers attempting to compromise the charterparty. Consider excluding in the ports of loading is vital to ensure safety. A number of states have also it given the time/trouble/costs/risks that shippers comply with the IMSBC made submissions to the IMO, with involved. Code. If they do not, owners and their various suggestions being made to - If owners are prepared to carry these P&I Clubs will have no option but to address the problems (see below). cargoes (in accordance with the IMSBC continue to take their own precautions. Code) discuss the owners’ expectations Owners who choose to run risks, International level with the charterer well in advance. calculated or otherwise, may have to Industry bodies, including the - Try to incorporate into the contract the face the consequences on their own. International Group of P&I Clubs, have charterparty clause recommended by attended numerous meetings in the the International Group of P&I Clubs. past year which recently culminated in - Do not accept any charterparty clauses Footnotes joint industry papers being submitted that may compromise the IMSBC Code 1 See for instance the article to the 16th Session of the IMO Sub- or prevent owners’ appointment of “Liquefaction of unprocessed mineral Committee on Dangerous Goods, certain surveyors/experts. ores - Iron ore fines and nickel ore” in Solid Cargoes and Containers. That Gard News issue No. 197. session included a meeting of a At fixture/order 2 See Gard P&I Member circulars No. Working Group on Amendments to the - Demand proper declaration of the 16/10 (iron ore fines) and No. 23/10 IMSBC Code, including the evaluation cargo and its Bulk Cargo Shipping (nickel ore). of properties of solid bulk cargoes. Name. 3 See Gard Loss Prevention Circular No. The meeting was attended by state - Consult the IMSBC Code. 6/11. and industry representatives and on - Make swift contact with Gard for 4 See Gard Alert of September 2011. 22nd September 2011 it reported on guidance on specific cargoes/countries 5 DSC.1/Circ.66 (revised in 2011). measures to improve safe transport so that sampling and independent 6 Gard’s Rule 74 states: “The of cargoes that may liquefy. These testing can be arranged to try and Association shall not cover liabilities, measures are considered in more detail minimise delay. losses, costs or expenses arising out of in the article “Future IMSBC Code - Seek to clarify any improper or consequent upon the Ship carrying amendments regarding cargoes that declarations/certificates with charterers contraband, blockade running or being may liquefy”, which appears elsewhere before the vessel arrives at the load employed in or on an unlawful, unsafe in this issue of Gard News. port. or unduly hazardous trade or voyage”. - Remember that the master will need 7 In respect of for liabilities, costs and What can owners do in practice? support/help locally and that this can expenses arising out of carrying unsafe One might say that the IMSBC Code take time (sometimes days) to arrange. cargo or out of non-compliance with already provides a sufficiently sound the IMSBC Code. basis on which to safely transport Before loading 8 Unless an independent expert solid bulk cargoes that may liquefy. - Demand the proper IMSBC Code customarily advising the Club/IG can The agreed amendments to the documentation, including the shipper’s confirm that the shipper’s documents IMSBC Code, which seem unlikely declaration and certificates of moisture are in accordance with the IMSBC to come into effect until 2013 at the content and TML/FMP. Code and acceptable based on earliest, should serve to strengthen - Check shipper’s documents against representative samples and proper the precautions to be taken, notably the provisions of IMSBC Code. analysis from a competent laboratory. by shippers. Ultimately, however, much - Do not accept for loading any cargo or 9 Section 2.1 of Appendix 3. depends on shipper compliance and parts of cargo until it has been properly if there is insufficient confidence in the tested and documented as safe to carry reliability of shippers’ declarations and in accordance with the IMSBC Code. certificates, owners and their Clubs - Support the master’s overriding will be hesitant to relax their own authority under SOLAS not to load precautions. So this is what owners can the cargo or to stop the loading of the do, practically speaking: cargo if he has any concerns that the condition of the cargo might affect the Know what to expect safety of the ship. - Understand the problems and complications, such as those mentioned Conclusion above. Inaccurate declarations and certificates - Chartering and operations from shippers appear to be at departments and most importantly the heart of the problem with the ships’ crews should be aware of the transport of cargoes liable to liquefy, dangers and precautions. though it is recognised there are - If they are not satisfied the cargo numerous complications. Whilst factors is safe to carry, owners should causing liquefaction may not be fully be ultimately prepared to sail understood, the IMSBC Code adopts without cargo and to deal with a cautious approach, which is wholly the consequences (safer than the appropriate, given the potentially alternative). disastrous consequences. Until such

Loss Prevention Circular Cargo liquefaction No. 06-11 problems – sinter feed from Brazil

Several Members have reported for loading. Cargo should never be and, if the cargo is not excluded, to try problems with sinter feed cargoes accepted on the basis of the ‘can’ test and incorporate provisions that pass on loaded in Brazil. The ports of Ponta da alone. The test may indicate if the responsibility to charterers. If a Member Madeira and Santana have featured cargo is unfit for shipment but cannot does fix to carry sinter feed they are most prominently thus far. determine if a cargo is fit to be loaded advised to refer to the precautions set – this can only be determined by out in International Group Circular No. Sinter feed and liquefaction laboratory testing. Given an apparent 16/2010. Sinter feed is an iron concentrate lack of reliable testing facilities in containing fine particles and moisture Brazil, expert advice has recently Footnotes and, being similar to iron ore fines, is seen samples sent as far as the UK for 1 Gard News 197 Feb/Apr 2010 at risk of liquefaction, resulting in cargo testing, which can obviously result in “Liquefaction of unprocessed mineral shift and loss of stability. Liquefaction serious delays. It is worth emphasising ores - Iron ore fines and nickel ores”. is believed to have resulted in here the importance of avoiding the 2 See Gard Member Circulars Nos. numerous casualties, causing the loss loading of cargo and parts of the cargo 16/2010 and 23/2010. of many seafarers’ lives. This year two which have not been properly tested 3 Described in section 8 of the IMSBC International Group Member Circulars and documented as safe to carry in Code as a spot check a Master can have been issued, alerting Members accordance with the Code as it can be conduct if he is suspicious of the to the dangers of liquefaction and the difficult to discharge cargo once it is condition of the cargo precautions to be taken, specifically loaded, not to mention the practical with reference to iron ore fines and difficulty of identifying “unsafe” parts nickel ore. of the cargo that may have to be discharged. Problems The Association is aware of at least one Survey costs and P&I cover case where shippers have declared The primary purpose of surveys in sinter feed as a Group C cargo (not respect of cargoes such as sinter feed, liable to liquefy) under the IMSBC iron ore fines and nickel ore, is to Code. This is in clear contravention of confirm safe carriage. For that reason, the Code since sinter feed is classed as the Club does not cover the survey a Group A cargo (under the group entry costs and neither are they considered “Mineral concentrates”) which may a measure to avert or minimise loss, liquefy if shipped at a moisture content since if Members act in accordance with in excess of its Transportable Moisture the Code and satisfy themselves as to Limit (“TML”), and defined in the Code safe carriage there should no undue as 90% of the Flow Moisture Point, exposure under the P&I cover. The (“FMP”). There are also reports of lack survey costs may, however, be covered of local survey capacity, with surveyors in full or part if the survey is actively reportedly acting for shippers as well as used in defence of a P&I claim. shipowners – a clear conflict of interest, a lack of reliable testing facilities able to The Club will assist Members faced test for the FMP in accordance with the with these problem cargoes as best we methods set out in the Code. Shippers can. However, it is important to point are also presenting cargo to load from out that, if a Member fails to comply stockpiles that have not been sampled/ with the Code they may be prejudice analysed. Club cover. Rule 74 of Gard’s Rules excludes cover for liabilities, costs and Problems are exacerbated by heavy expenses arising from an unsafe or rainfall increasing the moisture content unduly hazardous trade or voyage. The of the cargo. As described in the above carriage of these cargoes may give rise circulars, the ‘can’ test is not meant to various claims for which Defence to replace or supersede laboratory cover may be available, including survey testing which is the responsibility costs in connection with such claims of the Shippers. Section 8 of the which have been incurred with the prior Code states that if the sample shows approval of the Club. signs of liquefaction, i.e. flat surface with evidence of free moisture, Advice and precautions arrangements should be made to have Members should carefully consider the additional laboratory tests conducted potential costs/risks of carrying this on the material before it is accepted cargo before entering into new fixtures

Loss Prevention Circular Liquefaction of cargoes No. 08-10 of iron ore

Background risk of liquefaction is greater during heavy good time to assist them in engaging the Members may be aware of the problems weather, in high seas, and while under full services of a competent and experienced that have arisen in recent times with power, there are no safe sailing conditions surveyor to act on the Member’s behalf to respect to the liquefaction of cargoes for a cargo with unsafe moisture content. assist the master both before and during of iron ore fines originating in India and Liquefaction can occur unpredictably loading operations in order to ensure loaded at Indian ports . However, similar even in relatively calm conditions on a that the cargo is loaded in compliance problems have been experienced in the vessel at anchorage or proceeding at low with SOLAS and that the IMSBC Code is past with similar cargoes elsewhere in speed. adhered to. the world and, as such, these cargoes must always be treated as liable to liquefy Given this unpredictability, it is of utmost Freight disputes regardless of their origin. importance that the length of voyage Although not directly connected with the and prevalent and forecasted weather safe transport of iron ore fines from India, Liquefaction of mineral ores, resulting conditions do not serve to encourage this seems like an opportune time to in cargo shift and loss of stability, has the carriage on ships of cargoes prone highlight this issue. been a cause of some major marine to liquefaction with a Transportable casualties for many decades. However, Moisture Limit in excess of that which We understand that some Chinese ports a spate of incidents leading to several is accepted as safe for carriage. It is for do not allow the discharge of low grade losses in recent times involving iron ore these reasons that SOLAS and the IMSBC iron ore without an import permit. This fines loaded in Indian ports has lead Code incorporate provisions intended to can cause considerable delay of vessels to considerable focus on the lack of ensure that only cargoes with sufficiently and disputes concerning, e.g. freight, compliance with the requirements for safe low inherent moisture content to avoid demurrage or deadfreight may arise in carriage of this cargo . There have also liquefaction are loaded. Strict adherence relation to iron ore from India. been incidents involving cargoes of nickel to these provisions is the only safe way of ore from Indonesia, the Philippines and carrying these types of cargoes. We understand that “China Chamber New Caledonia. of Commerce of Metals Minerals and Preventive measures Chemicals Importers and Exporters” The Southwest Monsoon generally Based on previous experiences with and “China Iron & Steel Association” prevails from June to September and respect to cargoes of iron ore fines notified their members in April of this mainly affects India’s west coast. The loaded from India, Members are advised year to stop importing iron ore with an Northeast Monsoon generally prevails to exercise extreme caution when loading Iron (Fe) content below 60%. This has from December to March and mainly such cargo on their vessels. It is important made it difficult to obtain import permits affects India’s east coast. The advent of that cargoes of iron ore fines unsuitable from the government through these two the Southwest Monsoon gives us good for shipment are identified and rejected Associations. reason to revisit this subject through this before coming onboard the vessel and circular. proper measures are taken to ensure that It is therefore recommended that before the cargo loaded on board complies with transporting Indian iron ore or iron ore Main causes of casualties SOLAS and meets the requirements of with less than 60% Fe content from other The main cause of the casualties and the IMSBC Code. Additional sampling countries into China, shipowners should near misses appears to be the poor will be required if the cargo is subject to check with the Charters/ compliance of some shippers with the sources of moisture during loading. Shippers/Cargo Receivers if the Chinese testing and certification requirements buyers have obtained the import permit that are required under SOLAS and the Although the IMSBC Code places the so as to avoid unnecessary disputes over IMSBC Code 2009 and designed to burden of certification on the shipper, in freight, demurrage and detention of ensure that cargoes are loaded only if many cases the information contained vessels. Similar caution should also be the moisture content is sufficiently low to in the certificates may be incorrect. exercised with respect to spot cargoes of avoid liquefaction occurring during the This may be due to failure to correctly low grade iron ore into China. voyage. Indian iron ore fines tend to be analyse the samples, or use of facilities left in the open prior to shipment, and not geared to properly test the samples, See Gard Loss Prevention Circular No. as a consequence, are entirely subject to or the test samples not being properly 10-07: Loading of iron ore fines in India. weather conditions during this period. representative of the cargo to be loaded. Liquefaction of cargoes of Iron ore The problems related to wet cargo and It is thus extremely important that the ship has also been addressed in Gard News its moisture content particularly worsen owner and master ascertain that the cargo 197 (Feb/April 2010) “Liquefaction of during the wet monsoon seasons. is suitable for sea transport. unprocessed mineral ores – Iron ore fines and nickel ore”, by Dr. Martin In cargoes loaded with a moisture Although exposure to moisture is Jonas, Brookes Bell, Liverpool. The content in excess of the Flow Moisture heightened during the monsoon article describes the SOLAS/IMSBC Point (FMP), liquefaction may occur seasons, ship owners should ensure that Code Regulations, Certification of TML unpredictably at any time during the the same level of caution is exercised / moisture content and principles of voyage. Some cargoes have liquefied and with respect to the loading of iron liquefaction. caused catastrophic cargo shift almost ore fines irrespective of the time of We are grateful to “Hai Tong and immediately on departure from the load the year. The Association strongly Partners” of Beijing, China for providing port, some only after several weeks of recommends Members to contact the the information with respect to the apparently uneventful sailing. While the local correspondent or the Association in Freight disputes.

International Group Member India - Safe Shipment Circular No. 16/2010 of Iron Ore Fines from Indian Ports

Introduction requirements including those under the not be commenced until the master As Members may be aware in 2009 two Code, relating to the loading, stowing, or the ship’s representative is in ships, the ‘Asian Forest’ and the ‘Black carriage and discharge of iron ore lumps possession of all requisite cargo Rose’, capsized and sank following and fines cargoes loaded at Indian ports information in writing as described liquefaction of iron ore fines cargoes are fully complied with. above. The master has an overriding which they had loaded in the Indian ports authority under SOLAS not to load of Mangalore and Paradip. There have International Maritime Solid Bulk the cargo or to stop the loading of been other incidents of liquefaction, Cargoes Code (IMSBC Code) the cargo if he has any concerns that particularly when loaded during or after The Code is issued under SOLAS 1974 the condition of the cargo might the Indian monsoon season, resulting and its Protocols, which have been affect the safety of the ship. in ships becoming unstable and being incorporated into the Indian Merchant forced to seek refuge. In other cases Shipping Act 1958 (as amended). The (B) Shipper’s Obligations cargoes loaded have been found to Code sets out the internationally agreed (1) Cargo Information have moisture content in excess of the provisions for the safe stowage and The shipper must provide the Transportable Moisture Limit (TML) prior shipment of solid bulk cargoes, including master or his representative in to the vessel’s departure and the ships cargoes that may liquefy, such as iron writing with all information and in question have been prevented from ore fines. Those cargoes not specifically documentation required under sailing by the local port authorities until listed are covered by Section 1.3 of the Code in sufficient time before the situation has been rectified leading the Code. It is currently advisory but loading to ensure that the cargo to substantial delays. becomes mandatory internationally on can be safely loaded onto, carried 1 January 2011. However in India it is and discharged from the ship The Indian Government through the already mandatory by virtue of M Notice (section 4.2.1). Ministry of Shipping, Directorate General No 9. of Shipping (DGS) conducted enquiries (2) Documentation into the sinking of the ships and Regulation VI/2, SOLAS 1974 requires The documentation must include: established a Committee to look into the shipper to provide the master or (a) a certificate/declaration the safe loading and carriage of iron ore his representative with all relevant certifying the moisture content lumps and fines from Indian ports. The information relating to the cargo of the cargo loaded in each of DGS has issued a number of Merchant sufficiently in advance of loading to the ship’s holds together with Shipping Notices, the latest of which is M enable precautions which may be a statement that to the best Notice No. 9 of 2010, dated 27th August necessary for the proper stowage and of the shipper’s knowledge 2010. The Group is in dialogue with the safe carriage of the cargo to be put into the moisture content is the DGS on a number of issues arising from effect. average moisture content of the M Notices and how they relate to the cargo. the International Maritime Solid Bulk Section 4 of the IMSBC Code sets out Cargoes Code (the Code). M Notice No. the obligations and responsibilities (b) a certificate certifying the TML 9 is being made law in India as part of imposed on the shipper for providing of the cargo together with the the new Carriage of Goods Regulations. information about the cargo. FMP test result prepared by a competent laboratory. The Indian Government also submitted Most importantly for cargoes that may a report to the 87th session of the IMO liquefy (Group A cargoes), certificates The Code requires that the interval Maritime Safety Committee (MSC) in should be provided evidencing the between testing for the Flow Moisture May 2010 reporting on the findings of its moisture content of the cargo at the Point (FMP) and loading be no more than investigation into the two casualties and time of shipment and the transportable six months for regular materials unless the actions that the Indian authorities moisture limit (TML). The TML is defined the production process is changed in had taken following the casualties in the Code as 90% of the Flow Moisture any way and the interval between testing together with various recommendations Point (FMP). The FMP can only be for the moisture content and loading relating to the carriage of iron ore determined by laboratory analysis of shall never be more than seven days. fines. The report was considered by the cargo samples. Any cargo with moisture However with irregular materials such 15th session of the Sub-Committee on content in excess of the TML should as iron ore fines every shipment should Dangerous Goods, Solid Cargoes and not be accepted for loading (unless on be checked. Masters should be wary of Containers (DSC) in September 2010. specially constructed or fitted ships). Iron moisture content certificates provided The DSC issued a Circular DSC.1/Circ 63 Ore fines does not have its own schedule by the shipper’s laboratory and moisture which sets out a number of conclusions in the Code but should be regarded as content percentages that are very close and recommendations relating to the being a Group A cargo. to the TML. If there is significant rain carriage of iron ore fines. between the time of testing and the time (A) Master’s Obligations of loading the shipper must conduct test In view of the incidents referred to The master or his representative checks (section 4.5.2) to ensure that the it is most important that Members should monitor the loading operation moisture content of the cargo is still less ensure that all local and international from start to finish. Loading should than its TML.

© Gard AS, January 2014 19 (3) Laboratories surveyor by the ship is not intended to cargo should never be accepted on the The shipper must identify the laboratory and does not relieve the shipper of his basis of the ‘can’ test alone. The test may used to conduct the tests on the obligations under the Code or local indicate if cargo is unfit for shipment but cargo samples. It is recommended regulations. cannot determine if a cargo is fit to be that masters check with the local loaded – this can only be determined by correspondents/appointed surveyors to The terms of the surveyor’s appointment laboratory testing. ensure that the laboratory is reputable should include the following: and competent. The number of such 3. If the master or his appointed surveyor laboratories in India is currently very (a) To assist the master with compliance is presented with any document seeking limited. with his obligations under the Code and their confirmation that the cargo is safe local regulations. to carry they should refuse to sign it. (4) Stockpiles (b) To contact and liaise with shippers The obligation under the Code is on the The shipper must identify the stock piles to identify the stockpiles from which the shipper to declare that the cargo is safe from which the cargo is to be loaded cargoes are to be shipped on the subject to carry and signing such a document and confirm in writing that the samples vessel and to ensure that representative could prejudice a Member’s rights of tested and in respect of which certificates samples are correctly taken in recourse against a shipper in the event of have been issued/declarations made accordance with sections 4.4 and 4.6 of a subsequent casualty. originated from those stock piles. the Code. (c) To take owners’ own representative 4. Report any commercial pressure to the (5) Barges samples for testing in an independent Association so that this may be taken up Where barges are used to transport competent laboratory. by the Group with the DGS. cargo to the ship they must be capable (d) To liaise with an independent expert of being individually identified by the to ensure that the laboratory conducts its 5. Members should consider how they master/ship/ appointed surveyor. tests in accordance with Appendix 2 of might protect themselves contractually the Code. before agreeing to carry iron ore fines Problems encountered with the shipment (e) To compare the shipper’s certificates cargoes, e.g. including an appropriate of iron ore fines from India with owners’ own test results for TML clause in any charterparty. Equally and moisture content. Masters should Members should not be pressurised into It is understood that Members have be wary of moisture content certificates entering into charterparties which restrict encountered a number of problems with provided by the shipper’s laboratory their right to fully apply the provisions shipments of iron ore fines from India, and moisture content percentages of the Code, appoint independent including:- that are very close to the TML. If there surveyors of their choice or take and test is significant rain between the time of cargo samples. • Cargoes being mis-described to avoid testing and the time of loading the application of the Code shipper must conduct test checks. 6. Members should refer to the Club any • Iron ore fines not being declared as (f) To monitor the loading operation from contractual and/or safe carriage concerns Group A cargo start to finish, paying particular attention it may have relating to the iron ore lumps • Certificates and declarations not to the weather conditions and the and fines loaded in India being provided presence of any moist cargo, particularly • Inaccurate moisture content and TML in barges. Consequences of a Member’s failure to certificates, resulting in unsafe cargo (g) To stop loading if further moisture comply with the Code being presented for shipment and/or can tests are conducted, as • Commercial pressure on masters necessary, on any parts of the cargo The risks of loss of life, damage to the not to delay shipment and to carry presented for shipment (sections 4.5.2 environment and loss of property are cargoes without the provision of and 8.4 of the Code). only too apparent, but if a Member fails accurate certificates (h) To monitor the stockpiles and/ to comply with the Code and/or local • Restrictive clauses in charterparties or barges to ensure that the cargo regulations they should also be aware • Cargo not being stock piled but presented for shipment is from the that they might be prejudicing Club delivered straight from the mine designated and tested stockpiles and/or cover. All of the Group Clubs have similar • Only one certificate being provided barges. This will involve keeping a careful Rules which in essence exclude cover when there is more than one distinct tally and identification of barges offered for liabilities, costs and expenses arising source of cargo for loading. from unsafe or unduly hazardous trades • Moisture content certification being (i) To ensure loading is suspended during or voyages. over seven days old periods of rain. (j) To carefully examine cargo offered All Clubs in the International Group of Recommended precautions for loading from uncovered barges and P& I Clubs have issued a similar Circular. 1. Loading should not be commenced if in any doubt of the moisture content until the master is in possession of conduct ‘can’ tests particularly when Any questions with regard to the above all requisite cargo information and rain has been experienced. The ‘can’ may be addressed to Nick Platt or Mark documentation/certificates that a shipper test is described in section 8 of the Russell in Gard (UK) Limited (Tel: +44 (0) is obliged to provide under the Code or IMSBC Code as a spot check a Master 20 7444 7200). local regulations and is satisfied that the can conduct if he is suspicious of the cargo is safe to load and carry. condition of the cargo, and is not meant Yours faithfully, to replace or supersede laboratory GARD AS 2. Following consultation with the testing which is the responsibility of Association, appoint a surveyor on behalf the Shippers. Section 8 states that if of the ship in advance of loading to the sample shows signs of liquefaction assist the master. It may in any event be - i.e. flat surface with evidence of free a local requirement to do so. However, moisture, arrangements should be it should be made clear to the port and made to have additional laboratory competent authorities, shippers and tests conducted on the material before Claes Isacson charterers that the appointment of a it is accepted for loading. Nevertheless Chief Executive Officer

International Group Member Indonesia and the Circular No. 23/2010 Philippines – Safe Carriage of Nickel Ore Cargoes

Introduction reports without having been permitted cargo samples. Such audits as it has As members may be aware in October the opportunity of independently been possible to carry out of mines and November 2010 three vessels the verifying such declarations and reports. equipment and testing and sampling ‘Jian Fu Star’, ‘Nasco Diamond’ and The Marshall Islands supported procedures suggest not. Accordingly ‘Hong Wei’ sank during the carriage Intercargo’s intervention and the Indian the reliability of the information and of nickel ore from Indonesia to China delegation outlined the actions that documentation which the shipper with the loss of forty four seafarers. the Indian authorities were taking to is required to provide under the The cause of the sinkings has not improve the safe carriage of iron ore Code which became mandatory yet been definitively determined fines cargoes loaded in India. internationally on 1/1/11, most notably but nickel ore, like iron ore fines and the Transportable Moisture Limit (TML) many concentrates, is a cargo which Specific Concerns Associated with the certificate and the Flow Moisture Point may liquefy, if the moisture content of Loading and Carriage of Nickel Ore (FMP), is questionable. the cargo exceeds the Transportable Moisture Limit (TML) when loaded. The loading and carriage of nickel ore (e) The composition and physical Liquefaction of such a cargo can result cargoes from both Indonesia and the properties of nickel ore vary in loss of stability which in turn can lead Philippines has given rise to the specific considerably from location to location. to a vessel capsizing. It is therefore very concerns set out below. Since the cargo is not homogenous possible that all three vessels were lost it is difficult to accurately determine as a result of cargo liquefaction. (a) Most mines are situated in remote the TML and moisture content of the locations and loading/port facilities cargo as a whole. Frequently shippers There have been a number of other are therefore non-existent or very will only provide one TML certificate recent reports of cargoes of nickel limited and loading equipment and for a cargo that has been drawn from a ore loaded in both Indonesia and the methods rudimentary. Cargo is stock- number of different sources and is not Philippines liquefying and causing loss piled, uncovered, on the beach and homogenous, which is contrary to the of stability to the carrying vessel but accordingly totally exposed to the Code. fortunately not resulting in the loss of prevailing weather conditions. the vessel. In one such case the carrying (f) Nickel laterite has high clay content. vessel grounded causing extensive (b) The traditional practice has been Because of this, testing the FMP of hull damage. Currently nickel ore is to ship nickel ore cargoes in the dry a sample using the usual flow table only loaded in four locations in the season, between February and May/ method can be subjective and the Philippines, Santa Cruz (Luzon), Surigao June when rainfall in past years was results questionable. If the flow table and Tubay (Mindanao) and Rio Tuba negligible. However in recent years method of testing is not suitable, (Palawan Island). anecdotal evidence suggests that the section 1.1.1 of the Code provides that distinct demarcation between the wet the procedures to be adopted should Liquefaction of some ore cargoes can and dry seasons has been substantially be those approved by the relevant be caused by the normal incidents of eroded and heavy rainfall is now authority of the Port State. a sea voyage, for example the motion experienced during the dry season. The of the ship in the seaway or vibrations stock-piles do not therefore benefit to (g) Vessels are invariably loaded whilst caused by the running of the main the same extent from solar-drying as in at anchor from barges or landing engine or other on-board machinery. the past. craft which have themselves been loaded from stockpiles situated on The International Group informally (c) The mines are not easily accessible the beach. The stock-piled cargo may raised its concerns about the loading due to their remoteness and it is well have been subject to rainfall after and carriage of nickel ore from therefore difficult for independent samples have been taken and tested, Indonesia and the Philippines, with the surveyors/experts acting for the vessel during transportation from the mine Indonesian and Philippine delegations to attend the mines and take samples to the beach and while stockpiled on that attended the 88th session of of the cargo to be loaded. the beach. The Code requires that the IMO Maritime Safety Committee the interval between testing for the (MSC) which was held between 24 (d) There are few, if any, independent moisture content and loading shall November and 3 December 2010. laboratories in Indonesia and the never be more than seven days but Intercargo made an intervention at Philippines. The mines generally have in many instances this period is not that session expressing its concerns their own laboratories but it is often observed. with respect to the hazards and risks not possible to determine whether associated with the carriage of cargoes the correct testing equipment is (h) There have been a number of that can liquefy such as nickel ore. In available and in a satisfactory condition reports of surveyors appointed on addition Intercargo pointed out that or whether they are following the behalf of vessel interests to take cargo some charterers and masters had been procedures laid down under the samples and conduct independent put under extreme pressure to accept International Maritime Solid Bulk testing, being subject to extreme shippers’ declarations and testing Cargoes Code (the Code) when testing pressure by shippers to accept the

© Gard AS, January 2014 21 results of the tests carried out by time before loading, to ensure that master/ship/appointed surveyor. the mines. In certain instances the the cargo can be safely loaded onto, ‘pressure’ has been nothing short of carried and discharged from the ship Recommended precautions physical intimidation. (section 4.2.1). 1. Loading should not be commenced until the master is in possession of International Maritime Solid Bulk (2) Documentation all requisite cargo information and Cargoes Code (IMSBC Code) The documentation must include: documentation/certificates that a The Code is issued under SOLAS 1974 shipper is obliged to provide under the and its Protocols. The Code sets out (a) A certificate/declaration certifying Code or local regulations (where not in the internationally agreed provisions the moisture content of the cargo to be conflict with the Code) and is satisfied for the safe stowage and shipment of loaded together with a statement that that the cargo is safe to load and carry. solid bulk cargoes, including cargoes to the best of the shipper’s knowledge that may liquefy, such as nickel ore. the moisture content is the average 2. Considering the recent casualties Those cargoes not specifically listed are moisture content of the cargo. Where mentioned above, members are covered by Section 1.3 of the Code. It a cargo is to be loaded into more than encouraged to consider reviewing became mandatory internationally on 1 one cargo space, the certificate or with the Managers steps that might be January 2011. declaration of moisture content shall considered to reduce the risk presented certify each type of material loaded into by this cargo before loading and in Regulation VI/2, SOLAS 1974 requires each space, unless, following proper any case, if the master is in any doubt the shipper to provide the master or sampling and testing it is apparent as regards the suitability of the cargo his representative with all relevant that the different types are uniform for loading, very serious consideration information relating to the cargo throughout the whole consignment. should be given to the appointment sufficiently in advance of loading to of a surveyor on behalf of the ship in enable precautions which may be (b) A certificate certifying the TML advance of loading to assist the master. necessary for the proper stowage and of the cargo together with the FMP However, it should be made clear to safe carriage of the cargo to be put into test result prepared by a competent the competent authority (which, in the effect. laboratory. The Code requires that the Philippines, is likely to be the Bureau of interval between testing for the Flow Mines), shippers and charterers that the Section 4 of the IMSBC Code sets out Moisture Point (FMP) and loading be appointment of a surveyor by the ship the obligations and responsibilities no more than 6 months for regular is not intended to and does not relieve imposed on the shipper for providing materials unless the production the shipper of his obligations under the information about the cargo. process is changed in any way and Code or local regulations (when not in the interval between testing for the conflict with the Code). Most importantly for cargoes that may moisture content and loading shall liquefy (Group A cargoes), certificates never be more than 7 days. However The terms of the surveyor’s should be provided evidencing the with irregular materials such as nickel appointment should include the moisture content of the cargo at the ore every shipment should be checked. following: time of shipment and the transportable Masters should be wary of moisture moisture limit (TML). The TML is content certificates provided by the (a) To assist the master with compliance defined in the Code as 90% of the Flow shipper’s laboratory and moisture with his obligations under the Code Moisture Point (FMP). The FMP can only content percentages that are very and local regulations (when not in be determined by laboratory analysis close to the TML. If there is significant conflict with the Code). of cargo samples. Any cargo with a rain between the time of testing and moisture content in excess of the TML the time of loading the shipper must (b) To contact and liaise with shippers should not be accepted for loading conduct test checks (section 4.5.2) to to identify the stockpiles from which (unless on specially constructed or fitted ensure that the moisture content of the the cargoes are to be shipped on ships). Nickel Ore does not have its own cargo is still less than its TML. the subject vessel and to ensure that schedule in the Code but should be representative samples are correctly regarded as being a Group A cargo. (3) Laboratories taken in accordance with sections 4.4 The shipper must identify the laboratory and 4.6 of the Code. (A) Master’s Obligations used to conduct the tests on the cargo The master or his representative should samples. However as stated above little (c) To take owners’ own representative monitor the loading operation from reliance can be placed on the results of samples for testing in an independent start to finish. Loading should not be testing conducted by mine laboratories competent laboratory which are likely commenced until the master or the and samples should be the subject of to be located outside the country. ship’s representative is in possession of independent testing by surveyors and all requisite cargo information in writing experts appointed on behalf of the (d) To liaise with an independent expert as described above. vessel. to ensure that the laboratory conducts its tests in accordance with Appendix 2 The master has an overriding authority (4) Stockpiles of the Code. under SOLAS not to load the cargo or The shipper must identify the stock to stop the loading of the cargo if he piles from which the cargo is to be (e) To compare the shipper’s certificates has any concerns that the condition of loaded and confirm in writing that with owners’ own test results for TML the cargo might affect the safety of the the samples tested and in respect of and moisture content. Masters should ship. which certificates have been issued/ be wary of moisture content certificates declarations made originated from provided by the mines laboratories (B) Shipper’s Obligations those stock piles. and moisture content percentages (1) Cargo Information that are very close to the TML. If there The shipper must provide the master (5) Barges is significant rain between the time of or his representative in writing with Where barges are used to transport testing and the time of loading the all information and documentation cargo to the ship they must be capable shipper must conduct test checks. required under the Code in sufficient of being individually identified by the

© Gard AS, January 2014 22 (f) To monitor the loading operation cargo should never be accepted on 6. Members should refer to the Club from start to finish, paying particular the basis of the ‘can’ test alone as it any contractual and/or safe carriage attention to the weather conditions and is difficult to accurately interpret the concerns it may have relating to nickel the presence of any moist cargo in the behaviour of the sample in the can ore cargoes loaded in Indonesia or the barges/ landing craft. and accordingly its moisture content. Philippines The test may indicate if cargo is unfit (g) To stop loading if further moisture for shipment but cannot determine if a Consequences of a Member’s failure to and/or can tests are conducted, as cargo is fit to be loaded – this can only comply with the Code necessary, on any parts of the cargo be determined by laboratory testing. presented for shipment (sections 4.5.2 The risks of loss of life, damage to the and 8.4 of the Code). 3. If the master or his appointed environment and loss of property are surveyor is presented with any only too apparent, but if a Member (h) To monitor the stockpiles and/ document seeking their confirmation fails to comply with the Code or local or barges to ensure that the cargo that the cargo is safe to carry they regulations when not in conflict with the presented for shipment is from the should refuse to sign it. The obligation Code, they should also be aware that designated and tested stockpiles and/ under the Code is on the shipper to they might be prejudicing Club cover. or barges. This will involve keeping declare that the cargo is safe to carry All of the Group Clubs have similar a careful tally and identification of and signing such a document could Rules which in essence exclude cover barges/landing craft offered for loading. prejudice a Member’s rights of recourse for liabilities, costs and expenses arising against a shipper in the event of a from unsafe or unduly hazardous trades (i) To ensure loading is suspended subsequent casualty. or voyages. during periods of rain. 4. Report any instance of commercial All Clubs in the International Group (j) To carefully examine cargo offered pressure exerted on or intimidation of have issued a similar Circular. for loading from barges/landing craft the master, surveyor or experts to the and if in any doubt of the moisture Association so that this may be taken Any questions with regard to the above content, conduct ‘can’ tests particularly up by the Group with the Indonesian/ may be addressed to Nick Platt or Mark when rain has been experienced. The Philippine authorities. Russell in Gard (UK) Limited (Tel: +44 (0) ‘can’ test is described in section 8 of the 20 7444 7200 or Geir Kjebekk in Gard IMSBC Code as a spot check a Master 5. Members should consider how they AS, Arendal can conduct if he is suspicious of the might protect themselves contractually (Tel: +47 37 01 91 00). condition of the cargo, and is not meant before agreeing to carry nickel ore to replace or supersede laboratory cargoes e.g. including an appropriate Yours faithfully, testing which is the responsibility of clause in any charterparty. Equally GARD AS the Shippers. Section 8 states that if Members should not be pressurised the sample shows signs of liquefaction into entering into charterparties - i.e. flat surface with evidence of free which restrict their right to fully apply moisture, arrangements should be the provisions of the Code, appoint made to have additional laboratory independent surveyors of their choice tests conducted on the material before or take and test cargo samples. Claes Isacson it is accepted for loading. Nevertheless Chief Executive Officer

International Group Member Dangers of carrying Nickel Circular No. 5/2012 Ore from Indonesia and the Philippines – Mandatory Notification Requirements

Background carriage of nickel ore cargoes from fail to notify the Managers that they This circular should be read in ports in Indonesia and the Philippines, plan to fix or charter a ship, or that a conjunction with the previous circular Members who plan to fix or charter ship has been ordered, to load nickel 23/2010: Indonesia and the Philippines a ship to load nickel ore from ports ore from a port in Indonesia or the – Safe Carriage of Nickel Ore Cargoes in Indonesia and the Philippines, or Philippines. dated January 2011 relating to the where under an existing fixture a ship safe carriage of nickel ore cargoes is ordered to load such cargo, must Conclusion and nothing in this circular supersedes contact the Managers at the earliest The objective of this notification the previous advice. The liquefaction opportunity and, where possible, procedure is to try and ensure Members of such cargoes has resulted in the provide the following information:- engaged in or contemplating the sinking of a number of ships with a loss carriage of nickel ore are made aware of many lives in the last 18 months. • Ship name of the dangers, the IMSBC Code Nickel ore is a cargo which may liquefy • Port/anchorage of loading and requirements, Club cover implications if the moisture content of the material estimated time of arrival and also provided with information on exceeds its Transportable Moisture • Date of intended loading measures available to mitigate these Limit (TML). Cargo liquefaction may • Charterer/shipper’s details risks, even if they cannot be entirely lead to a loss of stability, to the extent • Agent’s details excluded. that the ship may capsize. • Copy of the shipper’s cargo declaration and supporting All Clubs in the International Group Due to the numerous dangers and certificates. have issued similar circulars. difficulties associated with this particular cargo, the International Group is This will enable the Managers to Any questions with regard to the above actively involved with other industry provide Members with relevant may be addressed to Nick Platt or Mark bodies in discussions currently taking information on measures that might Russell in Gard (UK) Limited (Tel: +44 place within the International Maritime be taken to reduce the risk, as set out (0)20 7444 7200). Organisation (IMO) to determine if in the previous circular, such as the and how the International Maritime appointment of a local surveyor to Solid Bulk Cargoes (IMSBC) Code assist the Master, and the appointment Yours faithfully, can be amended to improve the of an expert, not necessarily to attend GARD AS safe carriage of nickel ore cargoes. in person, but to liaise and supervise Representatives from the International the local surveyor throughout. These Group also recently met with the measures may reduce the risks inherent Indonesian Administration in Jakarta, in the carriage of nickel ore cargoes but as part of an industry delegation, to are not a guarantee of safety. discuss industry concerns with regard Claes Isacson to the safe carriage of such cargoes If the Master is in any doubt whatsoever Chief Executive Officer from Indonesia. The issues discussed as regards the suitability and safety included the duty of a competent of the cargo then loading should be authority to oversee compliance by stopped. The Member should contact shippers of their obligations under the Managers immediately. Problems the Code in respect of reliable testing are likely to arise if the loading of and accurate certification of the cargo unsafe cargo is permitted. It may, for to be shipped. In the absence of an example, be difficult to discharge the early resolution to these discussions cargo due to the lack of facilities in the and the on-going risks to safety, loading port or complications arising Members considering the carriage from local customs regulations. of nickel ore from ports in Indonesia and the Philippines should note the As experience is gained as a result recommendations contained in this of these mandatory declarations, circular. the Managers aim to be in a better position to identify those areas, ports and shippers which present particular Mandatory Notification difficulties, including inaccurate cargo Requirement declarations. Whilst it remains the Members’ responsibility to ensure full compliance Possible Prejudice to Club Cover with the IMSBC Code and to take any Members should be aware that they measures necessary to ensure the safe may be prejudicing Club cover if they

Gard Alert, New BIMCO Charterparty July 2012 clause for solid bulk cargoes that may liquefy

We refer to the Gard Alert “IMSBC bulk cargoes that may liquefy. A key Gard recommends that ship owners Code - Charterparty clause for solid feature of the clause is that it requires incorporate this clause into time bulk cargoes that may liquefy” charterers to provide owners with charterparties that allow for the carriage published in September 2011. written evidence from the shippers that of solid bulk cargoes that may liquefy the moisture content of the cargo does and in voyage charterparties fixed In the period following publication not exceed the Transportable Moisture for such cargoes. The new clause is of the above Gard Alert, BIMCO and Limit (TML). The clause also allows the quoted below and replaces the clause the International Group of P&I Clubs owners to take their own test samples previously recommended by Gard. worked together and developed a new of the cargo prior to loading and for the industry charterparty clause for solid master to be able to refuse to accept the cargo (or to sail if already loaded).

Solid Bulk Cargoes that Can Liquefy Clause for Charter Parties

(a) The Charterers shall ensure that all solid bulk cargoes to be carried under this Charter Party are presented for carriage and loaded always in compliance with applicable international regulations, including the International Maritime Solid Bulk Cargoes (IMSBC) Code 2009 (as may be amended from time to time and including any recommendations approved and agreed by the IMO).

(b) If the cargo is a solid bulk cargo that may liquefy, the Charterers shall prior to the commencement of loading provide the ship’s Master, or his representative, with all information and documentation in accordance with the IMSBC Code, including but not limited to a certificate of the Transportable Moisture Limit (TML), and a certificate or declaration of the moisture content, both signed by the shipper.

(c) The Owners shall have the right to take samples of cargo prior to loading and, at Charterers’ request, samples to be taken jointly, testing of such cargo samples shall be conducted jointly between Charterers and Owners by an independent laboratory that is to be nominated by Owners. Sampling and testing shall be at the Charterers’ risk, cost, expense and time. The Master or Owners’ representative shall at all times be permitted unrestricted and unimpeded access to cargo for sampling and testing purposes.

If the Master, in his sole discretion using reasonable judgement, considers there is a risk arising out of or in connection with the cargo (including but not limited to the risk of liquefaction) which could jeopardise the safety of the crew, the Vessel or the cargo on the voyage, he shall have the right to refuse to accept the cargo or, if already loaded, refuse to sail from the loading port or place. The Master shall have the right to require the Charterers to make safe the cargo prior to loading or, if already loaded, to offload the cargo and replace it with a cargo acceptable to the Master, all at the Charterers’ risk, cost, expense and time. The exercise by the Master of the aforesaid rights shall not be a breach of this Charter Party.

(d) Notwithstanding anything else contained in this Charter Party, all loss, damage, delay, expenses, costs and liabilities whatsoever arising out of or related to complying with, or resulting from failure to comply with, such regulations or with Charterers’ obligations hereunder shall be for the Charterers’ account. The Charterers shall indemnify the Owners against any and all claims whatsoever against the Owners arising out of the Owners complying with the Charterers’ instructions to load the agreed cargo.

(e) This Clause shall be without prejudice to the Charterers’ obligations under this Charter Party to provide a safe cargo. In relation to loading, anything done or not done by the Master or the Owners in compliance with this Clause shall not amount to a waiver of any rights of the Owners.

For more information about the new clause please go to www.bimco.org. For a collection of Gard’s previously published information on the topic of cargo liquefaction, please go to the “Cargo Liquefaction Spotlight” found under Preventing Losses on our website.

Gard News 205, IMSBC Code amendments February/April 2012 regarding cargoes that may liquefy

Amendments to the IMSBC Code Editorial and Technical Group meeting greater than 6.35 mm being present. If aiming to improve the safe transport in March 2012. In the meantime, it was there is any doubt regarding whether of cargoes that may liquefy have been also agreed, albeit with resistance from a material is Group A or Group C, it agreed by the IMO. industry (specifically those representing should be submitted for testing for flow ship interests), that the existing DSC properties. Ultimately, the revisions to The article “Cargo liquefaction - An circular concerning iron ore fines would the circular may simply lead to more update”, which appears elsewhere be revised. This circular (DSC.1.Circ/63, shippers trying to avoid declaring iron in this issue of Gard News, makes dated 7th October 2011) introduces ore fines as Group A cargo and to more reference to works at the IMO during what can best be described as a owners seeking expert advice on each the past year which have culminated in temporary definition of iron ore fines: cargo. joint industry papers being submitted a cargo “mainly constituted by iron to the 16th Session of IMO Sub- bearing minerals with a size up to 6.35 Nickel Ore Committee on Dangerous Goods, mm”. The revised circular also goes on With regard to nickel ore, a draft Solid Cargoes and Containers (DSC to provide that “if there is a question new schedule proposed by France 16). The session included a meeting about the applicability of this circular categorising this cargo as Group A was of a Working Group on Amendments for a specific particle size distribution of accepted in principle by the Working to the IMSBC Code whose report sets iron ore, advice should be sought from Group and will be forwarded to the out a number of agreed amendments the competent authority of the port of Editorial and Technical Group for to improve the safe transport of loading” and that “the Master should further consideration. cargoes that may liquefy, including the observe current best practice when following: handling and carrying this cargo, such Ship design as the use of specifically designed filters It is also worth mentioning that the - Clarification that the “competent to protecting the cargo holds bilge Working Group considered the issue authority” shall operate independently covers to stop the ingress of this fine of developing alternative requirements from the shipper. Amendments to the cargo into the bilge”. on the prevention of accidents through IMSBC Code aiming to improve the ship design. Further consideration safe transport of cargoes that may As mentioned, these revisions met with of this and any stability mitigation liquefy have been agreed by the IMO. some resistance from industry, as it was measures following the occurrence of felt somewhat premature to be making liquefaction were left for consideration - A requirement that the moisture revisions to a 2010 circular pending by other IMO Committees. In July 2011 content and TML (transport moisture the findings of the Correspondence the Italian classification society RINA limit) certificates be issued by an entity Group. Several obvious questions also announced that it had “established recognised by the competent authority arise. How is the master supposed to rigorous design standards for the of the port of loading. make an appropriate assessment of modification or newbuilding of dry particle size distribution and can the bulk cargo carriers to enable them to - A requirement that the shipper has in competent authority be relied on to carry fine ores safely at any moisture place procedures for sampling, testing make the correct assessment? What is content.1 It remains to be seen whether and controlling moisture content and a specifically designed bilge filter and the cost of modification of existing for these procedures to be approved by who should approve it? ships (estimated at USD 3 million for a the competent authority of the port of Supramax bulker) will be commercially loading. It is difficult to answer these questions feasible, as the number of modified here, but experts advising Gard and new builds is unlikely to provide - A requirement that the shipper other IG Clubs take the view that the capacity needed to meet world facilitates access to stockpiles for bilge covers can not and do not avoid demand for a long time to come. the purpose of inspection, sampling liquefaction and that particle size is not and subsequent testing by the ship’s the issue - the issue is whether or not The agreed amendments to the IMSBC nominated representative. the cargo, or a part of it, may develop a Code will probably only come into flow state at a certain moisture content. effect in 2013 at the earliest. Iron ore fines Studies have shown that the potential More specifically, the DSC 16 Working to liquefy is principally governed by the Footnotes Group also agreed that an IMO behaviour of the very fine material in a 1 See www.rina.org/en/news/press/_file/ Correspondence Group should develop cargo (1 mm in size and smaller), and attacksnickel_eng.pdf. a new schedule(s) for iron ore fines not the sizing of the larger material. and to consider test methods. This The presence of particles greater Group, which is now functioning with than 6.35 mm in the cargo does not input from industry, including the automatically categorise the cargo as International Group of P&I Clubs (IG) Group C. If it contains a proportion of and experts customarily advising the IG fine particles under 1 mm it may be a Clubs, will report to the next IMO DSC Group A cargo, irrespective of particles

Gard Alert, Brazil - liquefaction of March 2012 bauxite cargoes

Gard has learned that several vessels the IMSBC Code as a Group C cargo: a immediately upon departure from the have recently experienced cargo cargo not liable to liquefy. Appendix 1 load port whilst others have liquefied liquefaction problems after loading of the IMSBC Code describes bauxite after several weeks of apparently bauxite in the Amazon region in as a cargo with moisture content uneventful sailing. Members and clients northern Brazil, apparently from between 0% and 10% consisting of loading bauxite from terminals in the terminals in Trombetas. To our 70%-90% lumps varying in size between Amazon region in northern Brazil should knowledge, the exact causes of the 2.5 and 500 mm and 10%-30% powder. be aware of the potential costs/risks of incidents have not been reported so If any of the properties listed in carrying this cargo and ensure that it far, but it has been suggested that Appendix 1 of the IMSBC Code are not has been verified to be safe for carriage heavy rain in the region has led to an met, the requirements of section 1.3 of in accordance with requirements of unusually high moisture content of the the Code, “Cargoes not listed in this the IMSBC Code. It is worth bearing in loaded bauxite. As far as Gard is aware, Code“, should be followed. mind that seemingly safe cargoes can no serious consequences or casualties create dangerous situations. have resulted from the reported Liquefaction of mineral ores resulting in incidents, merely problems related to cargo shifting and loss of stability has For general advice Members and clients delays and extra costs in connection been a major cause of marine casualties should also refer to Gard’s compilation with the discharge operations. for many decades. In cargoes loaded “Cargo liquefaction”, which contains a with too high a moisture content, collection of articles published by Gard Bauxite is a cargo which normally liquefaction may occur without warning over the years relating to the carriage of consists of lumps, with a relatively low at any time during the voyage. Some cargoes liable to liquefaction moisture content. Due to these typical cargoes have liquefied and caused characteristics of the cargo, it is listed in catastrophic shifting of cargo almost

Gard Alert, Bar, Montenegro - zinc June 2012 concentrate liquefaction risk

Gard’s correspondent in Genoa, Hugo the accuracy of the transportable Trumpy s.r.l., for their assistance in the Trumpy, has reported that, over the moisture limit (TML) and that the preparation of this alert. last months, some cargoes of zinc actual moisture content is below the concentrate1 presented for loading in TML. To our knowledge, there are Footnote Bar, Montenegro have been rejected currently no independent laboratories 1 Zinc concentrate is listed in the due to high moisture content. The in Montenegro able to perform the IMSBC Code under the schedule terminal has, reportedly, implemented tests required by the IMSBC Code for “Mineral Concentrates”, which is measures such as using nylon tarpaulin and samples must therefore be sent defined as a Group A product: cargoes covers to prevent wetting of the cargo to suitable laboratories elsewhere in which may liquefy if shipped at moisture by rain. Europe. Given the time that this may content in excess of their transportable take, early survey arrangements should moisture limit (TML). Members and clients loading zinc be made to avoid delays. concentrate in Bar, Montenegro should be aware of the potential risks of For general advice Members and clients carrying this cargo and should seek should also refer to Gard’s compilation to ensure that it is safe for carriage in “Cargo liquefaction”, which contains accordance with the requirements of a collection of articles and circulars the International Maritime Solid Bulk published by Gard over the years Cargoes (IMSBC) Code. Consideration relating to the carriage of cargoes liable should be given to the appointment to liquefaction. of surveyors to take representative samples of the cargo and to arrange We would like to thank Gard’s for tests to be conducted to determine correspondent in Genoa, Italy, Hugo

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