IMSML Website Article 42/2024: Resolution MSC.539(107) - Amendments to the International Maritime Solid Bulk Cargoes (IMSBC) Code (PART 2 of 7), Section 2 - General Loading, Carriage and Unloading Precautions, AND Section 3 - Safety of Personnel and Ship

Section 2 - General Loading, Carriage and Unloading Precautions

Section 2.1 - Cargo Distribution

To prevent accidents, solid bulk cargoes have to be properly distributed throughout the ship. This ensures stability and that the ship’s structure is never overstressed. The master shall be provided with adequate information from the shipper about the cargo so that the ship can be properly loaded, see Section 2.1.1.

What should be given attention when loading high-density solid bulk cargo? Distribution of weights to avoid excessive stresses. This shall take into account loading conditions that may differ from normal. Improper distribution of cargo may be capable of stressing either the structure under the load, or the entire hull. Exact rules for distribution of loading is not practicable as structural arrangement of each vessel vary greatly. Loading calculators used in conjunction with the ship’s stability information booklet could be used to derive information for proper distribution of cargo, see Section 2.1.2.

What is the master’s duty when calculating stability? He/she must anticipate the worst conditions during the voyage at departure and demonstrate that stability is adequate, see Section 2.1.3.1.

When should shifting division and bins (of adequate strength) be erected? This is required whenever solid bulk cargoes carried in ‘tween deck cargo spaces or in only partially filled cargo spaces, as suspected of readily shifting, see Section 2.1.3.2.

Is there a preference for loading spaces? High density cargoes shall be loaded in lower hold cargo spaces in preference to ‘tween deck cargo spaces (as far as practicable), see Section 2.1.3.3.

When can high density cargoes be carried in ‘tween decks or higher cargo spaces? Only if the deck area is not overstressed, and the ship’s stability is not reduced below the minimum acceptable level specified in the ship’s stability data, see Section 2.1.3.4.

Section 2.2 - Loading and Unloading

Is there a duty to inspect cargo spaces? Yes, in preparation for the particular cargo which is to be loaded as required by Resolution A.866(2), see Section 2.2.1.

Is special preparation necessary for bilge wells and strainer plates? Yes, due consideration is required to facilitate drainage and to prevent entry of the cargoes into the bilge system, see Section 2.2.2. Note, that bilge lines, sounding pipes and other service lines with the cargo space shall be in good order, see Section 2.2.3.

Is special care necessary to protect cargo space fittings from damage? Yes, due to the velocity at which some high density solid bulk cargoes are loaded. Sounding of the bilges after the completion of loading may be effective to detect any damage on cargo space fittings, see Section 2.2.4.

Should ventilation systems be shut down or screened, and air conditioning systems place on recirculation during loading or discharge? As far as practicable, this is done to minimise dust ingress into the living quarters or other interior spaces, see Section 2.2.5. Note, that due consideration shall be given to minimise the extent to which dust may come into contact with moving parts of deck machinery and external navigational aids, see Section 2.2.6.

Section 3 - Safety of Personnel and Ship

Section 3.1 - General Requirements

All the necessary precautions shall be observed, ie prior to and during loading, carriage and discharge of a solid bulk cargo, see Section 3.1.1.

What sort of onboard operational fire safety risk assessments shall be carried out? Such routine assessments shall be carried out by the ship’s crew for cargo handling areas on self-unloading bulk carriers featuring internally installed conveyor systems within the ship’s structure, see Section 3.1.2.

What sort of due consideration shall be given to fire prevention? Effective operation of fire detection systems, containments and suppression under all anticipated operating conditions and cargoes. This shall be detailed in the ship’s Safety Management System (SMS) together with recommended timing to provide regular assessments, see Section 3.1.2. Note, a copy of the instruction on emergency response and medical first aid relevant to incidents involving dangerous goods in solid form in bulk shall be on board, see Section 3.1.3.

Section 3.2 - Poisoning, Corrosive and Asphyxiation Hazards

Different types of hazardous cargoes identified in Section 3.2.1:

[1] Cargoes susceptible to oxidation - May result in oxygen depletion, emission of toxic gasses or fumes and self-heating;

[2] Cargoes NOT susceptible to oxidation, but when wet, may emit toxic fumes;

[3] Cargoes that are corrosive when wet, in particular to skin, eyes and mucous membranes, or to the ship’s structure.

Note, for types of cargoes identified in Section 3.2.1, special attention shall be given to the protection of personnel. Therefore Special precautions are to be taken prior to loading and after unloading.

What areas on the ship should be given appropriate attention? Areas identified by Section 3.2.2 include:

[1] Cargo spaces and adjacent spaced that may be depleted in oxygen, or may contain toxic or asphyxiating gases, AND …

[2] Empty cargo space or tank which has remained closed for some time which may have insufficient oxygen to support life.

What solid bulk cargoes are liable to cause oxygen depletion in a cargo space or tank? See Section 3.2.3 which includes the following:

[1] Most vegetable products;

[2] Forest products;

[3] Ferrous metals;

[4] Metal sulphide concentrates;

[5] Coal cargoes.

Is a cargo space or tank that has been tested always 100 percent safe for entry? Not necessarily. Caution is advised as small areas may exist where oxygen is deficient or toxic fumes still present, see Section 3.2.4.

What shall be done when carrying a solid bulk cargo that is liable to emit a toxic or flammable gas, and/or cause oxygen depletion in the cargo space? The Appropriate instrument(s) for measuring the concentration of gas and oxygen shall be provided, see Section 3.2.5.

Who shall undertake emergency entry into a cargo space? Only trained personnel wearing self-contained breathing apparatus and protective clothing. These persons shall always be under the supervision of a responsible officer, see Section 3.2.6, and Resolution A.1050(27) ‘Revised Recommendations for Entering Enclosed Spaces Abroad Ships’.

Section 3.3 - Hazards Due to Dust

What can be done to miniseries the chronic and acute risks associated with such exposure? Need for a high standard of personal hygiene. Precautions under Section 3.3 include necessary usage of the following:

[1] Breathing protection;

[2] Protective clothing;

[3] Protective skin creams;

[4] Adequate personal washing;

[5] Laundering of outer clothing.

Section 3.4 - Flammable Atmosphere

How can risk be minimised for solid bulk cargoes that constitute an explosion hazard especially while loading, unloading and cleaning? By ventilating to prevent the formation of a dust-laden atmosphere, AND by hosing down rather than sweeping, see Section 3.4.1.

What should be done when cargo information provided by the shipper indicates that the cargo may emit flammable gases in sufficient quantities to constitute a fire or explosion hazard? The following is mandated by Section 3.4.2:

[1] The cargo spaces shall be effectively ventilated, as necessary;

[2] The atmosphere in the cargo spaces shall be monitored by means of an appropriate gas detector;

[3] Due consideration shall be given to the ventilation and monitoring of the atmosphere in the enclosed spaces adjacent to the cargo spaces.

Section 3.5 - Ventilation

When shall mechanical or natural ventilation be provided? When cargoes which may emit toxic gases are carried (unless expressly provided otherwise), see Section 3.5.1.

When is only mechanical ventilation needed? When cargoes which may emit flammable gases are carried, see Section 3.5.1.

What if maintaining ventilation would endanger the ship or cargo? It may be interrupted unless this would produce a risk of explosion, see Section 3.5.2.

What should be done when from the information provided by the shipper, or when continuous ventilation is required by the schedule for the cargo in this Code? Ventilation should be maintained whilst the cargo is on board, unless a situation develops where ventilation would endanger the ship, see Section 3.5.3.

When should ventilation openings be provided in the cargo holds? For the carriage of cargoes that require continuous ventilation. The openings shall comply the requirements of the Load Line Convention (as amended). Note, that these opening are not fitted with a means of closure, see Section 3.5.4.

Under Section 3.5.5, due consideration and adequate precautions should be given to the following:

[1] Ensuring that escaping hazardous gases, vapours or dust cannot enter the accommodation or other interior spaces in hazardous concentrations;

[2] Prevent escaping hazardous gases, vapours or dust from reaching enclosed work areas;

[3] Adequate precautions to protect personnel in work areas.

What should be done when cargo may heat spontaneously? Ventilation other than surface, shall not be applied. On no account shall air be directed into the body of the cargo, see Section 3.5.6.

Section 3.6 - Cargo Under In-Transit Fumigation

IMO guidelines shall be followed when performing fumigation, see Section 3.6.1 and MSC.1/Circ.1264 (as amended by MSC.1/Circ.1396), Recommendations on the Safe Use of Pesticides in Ships Applicable to the Fumigation of Cargo Holds.

What shall be taken into consideration when a fumigant is used? Section 3.6.2 mandates the following as fumigants may enter into occupied spaces despite many precautions taken:

[1] Fumigants leaking from a cargo hold may enter the engine room via pipe tunnels, ducts, and piping of any kind, including wiring ducts on or below deck, or dehumidifier systems that may be connected to parts of the cargo hold or compartments of the engine room;

[2] Bilge, cargo lines and valves are potential problems areas.

[3] Ventilation procedures should be scrutinised as fumigant gas could be drawn in by incorrect ventilation procedures and settings, vacuum creation due to incorrect closing devices or flap settings, air conditioning and closed loop of the accommodation;

What should be done prior to commencement of fumigation procedures? Section 3.6.2 mandates the following:

[1] Verify that ventilation flaps and closing devices are set correctly;

[2] Closing and sealing all of the bulkhead openings (such as doors and manholes) leading from the engine room to piping tunnels / duct keels and other spaces that in case of leaks could become unsafe to enter during fumigation;

[3] Having warning signs posted.

When should gas concentration safety checks be carried out? Continuously throughout the voyage at least at 8 hour intervals. More frequently if so advised by the fumigator-in-charge at all appropriate locations, see Section 3.6.3.

What areas should be targeted for gas concentration safety checks? Areas identified by Section 3.6.3 include:

[1] Accommodation;

[2] Engine rooms;

[3] Areas designated for use in the navigation of the ship;

[4] Frequently visited working areas and stores (eg forecastle head spaces, adjacent to cargo holds being fumigated);

[5] Special attention is required for potential problem areas such as the bilge and cargo line systems.

Note, the readings obtained under Section 3.6.3 shall be recorded in the ship’s logbook.

Thank you for reading IMSML Website Article 42/2024

Stay tuned for the next IMSML Website Article 43/2024: Resolution MSC.539(107) - Amendments to the International Maritime Solid Bulk Cargoes (IMSBC) Code, Section 4 - Assessment of Acceptability of Consignments for Safe Shipment, AND Section 5 - Trimming Procedures

Signing-off for today,

Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT

Professor of Maritime and Transport Law

Head of the Centre for Advocacy and Dispute Resolution

Faculty of Law

Universiti Teknologi MARA Shah Alam

Selangor, Malaysia

Tuesday, 20 August 2024

Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my