West P&I Club has highlighted the issue surrounding wet weather loading Group A IMSBC cargoes.
The Club said it has recently seen several instances regarding loading bulk cargoes that are categorised as Group A cargoes under the IMSBC Code during precipitation.
Group A cargoes should never be loaded where it has been determined that the moisture content of the cargo exceeds the Transportable Moisture Limit (TML). It is therefore understandable that some vessels opt to restrict the amount of moisture that the cargo is exposed to by avoiding loading during periods of precipitation.
However, the IMSBC Code does allow loading of Group A cargoes in certain situations.
Several Group A cargo schedules within the IMSBC Code have specific provisions in place for wet weather loading, such as:
- The moisture content of the cargo shall be kept less than its TML during loading operations and the voyage;
- Unless expressly provided otherwise in the individual schedule, the cargo shall not be handled during precipitation;
- Unless expressly provided otherwise in the individual schedule, during handing of the cargo, all non-working hatches of the cargo spaces into which the cargo is loaded, or to be loaded, shall be closed;
- The cargo may be handled during precipitation under the conditions stated in the procedures required in 4.3.3 of the Code; and
- The cargo in a cargo space may be discharged during precipitation provided that the total amount of cargo in the cargo space is to be discharged in the port.
The first point emphasises that the priority when loading any Group A cargo is ensuring that the moisture content of the cargo is kept below the TML at all times throughout the loading period.
Point 4 is perhaps the most pertinent point in regard to loading in the rain and makes reference to Section 4.3.3 of the IMSBC Code. This requires that procedures for sampling, testing and controlling the moisture content are in place to ensure that the moisture content is less than the TML when it is on board the ship. These shall be established by the shippers, and such procedures shall be approved, and their implementation checked by the competent authority of the port of loading.
It is the shippers’ responsibility, in close co-ordination with the competent authority of the port of loading, to create a moisture management plan for the loading operation to ensure that the moisture content is kept below the TML of the cargo throughout operations. If such plans and procedures are not put in place by the shippers or the competent authority has not approved them, or they are not carefully checking the implementation of the plan, then no precipitation loading is permissible under Section 4.3.3 of the Code.
The Club added members who are requested to load Group A cargoes in ports under precipitation must request a copy of the competent authority approved moisture management plan from the shippers which should outline the various methods and means that the shippers will ensure that the moisture content of the cargo never exceeds the TML of the cargo during the loading period.
Download the PDF: West - Group A IMSBC Cargoes - The Rain Loading Dilemma