Britannia P&I Club has issued information about what actions to take when loading different bulk cargoes to meet the requirements of the International Maritime Solid Bulk Cargoes (IMSBC) Code. The shipper is responsible for providing the master (or their representative) with sufficient information in advance to allow safe preparation for loading, stowage, and carriage of the nominated cargo under the requirements of the IMSBC code.
Britannia highlights that one of the most critical pieces of information is the Bulk Cargo Shipping Name (BCSN). Once the BCSN is known, the corresponding schedule in Appendix 1 of the IMSBC Code can typically be identified, allowing the ship to confirm compliance with safety requirements.
Ships regularly carrying bulk cargoes often hold a Statement of Compliance or equivalent from their Classification Society, listing BCSNs they are approved to carry, along with any conditions. Challenges arise when the cargo name provided does not match any BCSN listed in the IMSBC Code. In such cases, the standard schedules cannot be used directly, and alternative steps must be taken to verify the cargo’s safety for carriage.
Britannia P&I highlights quick confirmatory checks that can be made should this occur:
– Check for synonyms – when provided with a BCSN that does not appear within Appendix 1, check if the same name is being referenced in Appendix 4. It is possible that a synonym has been used, for example a cargo declared as “Chrome Ore” directs the user to review the schedule under a BCSN of “CHROMITE ORE”. This only provides the master and crew with the correct references they require to understand the characteristics of the cargo sufficiently in advance of loading to enable the precautions which may be necessary for proper stowage and safe carriage of the cargo to be put into effect. However, it still does not fulfil the requirement of Section 4.1.3 and Section 4.2 of the Code, if such a circumstance does occur, we recommend that clarification is sought from the shipper, and ultimately the correct BCSN should be inserted in the cargo declaration and not the synonym. It is also recommended to compare the cargo with the description and characteristics described within the individual schedule, and should notable differences be found, contact the Club for further advice.
- Check for groupings – some BCSNs have been grouped under a single schedule. A good example is the schedule for “Mineral concentrates”, which contains the information required for 25 different BCSNs.
- Check language – It may be that the BCSN has been provided in a language different from that which is expected. Appendix 5 provides BCSNs translated into three different languages: English, French, and Spanish.
If, however, the name of the cargo cannot be conclusively matched to a BCSN listed in the IMSBC Code, then the standalone procedure in Section 1.3 – “Cargoes not listed in this Code” shall be followed.
In the first instance, the shipper must supply the required information on the cargo’s characteristics and properties to the Competent Authority at the Port of Loading (CA-PL). The CA-PL will assess the suitability of the cargo for safe carriage by sea.
The next step depends upon whether the cargo is assessed as possessing any of the hazards that would classify it as Group A or Group B.
- GROUP A: cargoes which possess a hazard due to moisture that may result in liquefaction or dynamic separation if shipped at a moisture content in excess of their transportable moisture limit.
- GROUP B: cargoes which possess a chemical hazard which could give rise to a dangerous situation on a ship.
- GROUP C: cargoes which are classified as neither Group A nor Group B.
If this is the case, a ‘Tripartite Agreement’ must be obtained. This means that details of the cargo and its assessment are shared with the Competent Authority at the Port of Discharge (CA-PD) and the ships Flag State. Together the three bodies will agree upon the conditions that must be followed to allow safe carriage.
Furthermore, if the cargo is assessed by the CA-PL to meet the standards of a Group C cargo, then they can simply authorise the cargo for carriage. This authorisation should be communicated to the CA-PD and ships Flag State also.
Regardless of the outcome of the cargo assessment, if the cargo is authorised for carriage, the CA-PL must provide the ships master with a certificate containing the information contained in Section 1.3.2 of the Code.
Britannia Club recommends that any cargo presented by the shipper with insufficient information is not accepted for loading until further guidance has been obtained. Where it is found that a cargo is not listed in the IMSBC Code, great caution must be exhibited, and strict observance of the procedure contained in section 1.3 of the IMSBC Code must be followed.