Article: Carriage of Solid Bulk Cargoes - Liquefaction and Dynamic Separation

Background

This article should be read in conjunction with the club circulars linked below.

Nothing in this article supersedes the previous advice and requirements contained in the above circulars, which remain valid.

Liquefaction continues to be a major concern, particularly in respect of the carriage of bulk cargoes from certain markets. A recent report from Intercargo highlights that between 2011 and 2020, liquefaction accounts for the highest loss of life with five casualties resulting in 61 lives lost or 47.7% of the total loss of life in the past ten years. These consisted of three bulk carriers carrying nickel ore from Indonesia, one vessel with iron ore fines from Malaysia and one vessel with bauxite from Malaysia.

At that time, bauxite was classified under the International Maritime Solid Bulk Cargoes (IMSBC) Code as a Group C cargo - a cargo which is neither liable to liquefy (Group A) nor to possess chemical hazards (Group B). Following the tragic loss of BULK JUPITER in 2015, the International Maritime Organization (IMO) acknowledged that the incident was attributed to “dynamic separation”. Consequently, a new cargo schedule for ‘Bauxite Fines’ (Group A) was developed and the existing schedule for ‘Bauxite’ (Group C) was revised accordingly.

Similarly, there have been cases where other Group C cargoes (for example, bulk clay cargoes) have exhibited the liquefaction characteristics of Group A cargoes. Even though the IMSBC Code lists ‘Clay’ as a Group C cargo, which suggests that it is not liable to liquefy when carried in bulk, the loss of a general cargo ship (XIN HONG), whilst on a passage from Malaysia to Hong Kong on 17 December 2020, serves as a reminder that liquefaction risks may apply to all cargoes that have a high proportion of fine particles.
 

Obligations of the shipper and master under the IMSBC Code

As stated in section 1.2 of the IMSBC Code, the cargo properties given in the IMSBC schedules are for guidance purposes only. It is therefore essential to obtain current valid information from the shipper on the physical and chemical properties of cargoes presented for shipment.

Section 4 of the IMSBC Code sets out the obligations and responsibilities imposed on the shipper for providing information about the cargo. These include the requirements and procedures for testing and analyzing the moisture content and transportable moisture limit of cargoes which may liquefy. It is recommended that members take note of sections 4.3.2 and 4.3.3, which require the local (and frequently shipper’s) procedures for sampling, testing and controlling the moisture content of cargo to be checked and approved by the competent authority.

At the same time, it is an owner's (in practice, the master’s) obligation to allow only safe and compliant cargoes to be loaded. Loading should not be commenced until the master or the ship’s representative is in possession of all requisite cargo information in writing as described above. The master or his representative should monitor the loading operation from start to finish. The master has an overriding authority under SOLAS not to load a cargo, and/or to stop the loading of a cargo, if he/she has any concerns that the condition of the cargo might affect the safety of the ship.
 

Specific concerns noticed at various load ports

The main concerns noticed at several load ports in Malaysia, Indonesia, Philippines, New Caledonia, Guatemala, Guyana, Turkey, Albania, Mozambique, and West Africa (Mauritania, Côte d’Ivoire, Sierra Leone and Equatorial Guinea) which members should be aware of are:

1. Lack of enforcement by local competent authorities

The monitoring and / or approval by the competent authority at the load port of the shippers’ obligations under sections 4.3.2 and 4.3.3 of the IMSBC Code, regarding sampling, testing and controlling the moisture content of cargo, are not consistently carried out.

2. Shippers’ certificates

Mines may have their own ‘in-house’ laboratories. Frequently it is not possible to determine whether the correct testing equipment is available, in a satisfactory condition and / or whether the procedures laid down under the IMSBC Code have been followed. Accordingly, the test results may be unreliable. In order to obtain results from an accredited laboratory, cargo samples may need to be sent overseas. If this is done, members should seek advice on packing and sealing the sample to prevent loss of moisture during transportation.

3. Loading areas and cargo stockpiles

Mines can be situated in remote locations where cargo stockpiles are seldom covered, and hence are exposed to the prevailing weather. The cargo may be wet when mined or become wet when left in open storage areas. Some shippers may insist on carrying out sun-drying prior to loading, but the effectiveness of this method is questionable. Inspection of the stockpiles is often rejected by the local mines/shippers.

4. Loading from barges

Often due to the lack of proper facilities, vessels are loaded whilst at anchor from barges which have themselves been loaded from inadequately covered stockpiles. The cargo on the barges may also have been exposed to the weather. When there is more than one vessel loading in the area it is not uncommon for a barge rejected by one vessel to be presented to another. A cautious approach needs to be taken when assessing the acceptability of the cargo from barges.

5. Deteriorating weather trends

In recent years, there has been a fluctuation in weather patterns with extended rainy seasons, unseasonal heavy rainfalls and more frequent tropical storms. Heavy rainfall on uncovered stockpiles increases the risk of liquefaction.

6. Cargo sampling and testing

The IMSBC Code requires that the testing for the moisture content should be done within seven days of the loading date or after a period of rain, but in many instances, this is not observed.

7. Can tests

Frequently, the cargo will be loaded on the basis of can test results, despite the fact that such tests are only a rudimentary indicator. The IMSBC Code clearly states the limitations of the can test, and even a satisfactory can test does not mean that a cargo is safe to carry.

8. Commercial pressure

Clubs continue to see cases of commercial pressure where the ship’s crew are forced to accept the cargo even if there are reasonable doubts about its condition.

Preventative measures

• Members should not assume there is no risk of liquefaction simply because a cargo is not identified as ‘Group A’ in the IMSBC Code.
• If a cargo presented for loading does not meet the properties listed in the IMSBC Code, or if the master is in any doubt whatsoever as regards the suitability and safety of the cargo then loading should be stopped. The member should contact the club immediately.
• Members should maintain enhanced vigilance regarding potential misdeclaration of any cargoes which may liquefy (defined as those with a certain proportion of fine particles and a certain amount of moisture), particularly in areas where these issues are prevalent.
• The master should be aware of his obligations under the IMSBC Code to only allow safe and compliant cargoes to be loaded and members should follow the ‘recommended precautions’ listed in the 2011 IG circular for all cargoes that contain fine particles, irrespective of the cargo group declared by the shipper.
• Loading should not be commenced until the master is in possession of all requisite cargo information and documentation/certificates that a shipper is obliged to provide under the IMSBC Code or local regulations (where not in conflict with the IMSBC Code) and is satisfied that the cargo is safe to load and carry.
• Members are required to comply with the ‘notification requirements’ of the 2012 IG circular on the dangers of carrying nickel ore, namely that owners/members who plan to fix or charter a ship to load nickel ore from ports in Indonesia and the Philippines, or where under an existing fixture a ship is ordered to load such cargo, must contact the club at the earliest opportunity and, where possible, provide the information listed below. 
  • • Ship name
    • Port/anchorage of loading and estimated time of arrival
    • Date of intended loading
    • Charterer’s/shipper’s details
    • Agent’s details
    • Copy of the shipper’s cargo declaration and supporting certificates

The fact that a member has notified the club does not imply an endorsement from the club for the intended voyage, and nor does it discharge the member from its responsibility to ensure full compliance with the IMSBC Code and to take any measures necessary to ensure safe carriage.

Club cover

Owners/members should be aware that they may be prejudicing club cover if they fail to follow the recommended precautions and / or to notify the managers that they plan to fix or charter a ship, or that a ship has been ordered, to load nickel ore from a port in Indonesia or the Philippines. The club reserves its right to appoint a surveyor on behalf of the ship in advance of loading to assist the master.

Category: Cargo