Beware cargoes not listed in the IMSBC Code that might still liquefy, says Gard’s Russell

Gard’s Mark Russell, Vice President, Head of Cargo Claims, has said that the Norway based Group P&I club and marine insurer had become aware of a number of cases involving cargoes which might liquefy even though they were not listed in the International Maritime Solid Bulk Cargoes (IMSBC) Code as Group A cargoes, and therefore not declared as such by shippers.

Group A consists of cargoes which might liquefy if shipped with a moisture content in excess of their Transportable Moisture Limit (TML). In two of the instances the cargoes liquefied and as a result endangering the lives of the crew. Although there were no fatalities, in one case the vessel sank, posing risks to the environment.

Gard is therefore encouraging owners of the need to make their crews aware of Appendix 3, Article 2 of the IMSBC Code, which states that “many fine particle cargoes, if possessing a sufficiently high moisture content are liable to flow. Thus any damp or wet cargo containing a proportion of fine particles should be tested for flow characteristics prior to loading.”

As Russell observed, the above was relevant also to cargoes not listed in the Code as Group A cargoes. The IMSBC “is not a comprehensive database of all commodities that may be carried on ships. When fixing bulk cargo, owners should also be aware of the IMSBC provisions for dealing with cargoes not listed in the Code”.

Furthermore, some cargoes in the Code might not be categorized as Group A because they were typically dry, with descriptions such as “dry” or “dusty”, despite having properties of a Group A cargo when the moisture content was higher. In such cases the same provisions applied.

Gard said that it was also continuing to see cases giving rise to liquefaction concerns for Group A cargoes listed in the Code. Owner members of Gard had discharged back to shore cargoes that were found to be unsafe at the time of loading, including Group A iron ore fines and fluorspar (fluorite), the mineral form of calcium fluoride.

In another case, involving cargo of soil from a landfill, a vessel was transporting more than 1,900 tonnes of soil that was not listed in the IMSBC Code. During the voyage, the vessel was exposed to wind and waves, which caused the cargo to behave more like liquid cargo. The vessel listed; the five crew members were rescued, and the vessel then sank. The authorities ordered the removal of oil from the wreck, which was otherwise not considered to pose a danger to navigation. The case was the subject of an investigation by the Norwegian Safety Investigation Authority (NSIA). The NSIA considered it likely that there was moisture in part of the stockpile and thereby in the soil that was taken on board.

In another case, a vessel developed a list shortly after leaving load port. Fortunately, the crew were able to get the ship to a sheltered anchorage. Upon inspection the cargo had mostly levelled and there was water on top of it. Salvors removed the free water and the vessel was towed to a nearby port, where the cargo, calcium carbonate, was discharged. Calcium Carbonate is not specifically listed in the IMSBC Code. Limestone, which is also calcium carbonate, is listed as being a Group C. Calcium Fluoride, Calcium Sulphate and Calcium Carbonate mixture is identified on page 493 of the 2022 version of the Code as being Group A.

The cargo had been stored on the quay as an open stockpile, subject to snow showers before and during loading. The Chief Officer inspected the stockpile and noted that the consistency was between clay and sand. The CO also observed that it was partly frozen. After checking the Code and seeing that the cargo was not listed, the Master requested further information from the charterers. The CO was advised that the cargo was not dangerous. No can tests were conducted by the crew prior to loading. Can-tests that were performed on the cargo after the incident, and therefore after free water had been removed from the top of the stow, indicated the “possibility of flow”.

The shippers confirmed that the cargo had not been tested for flow characteristics. Laboratory testing of cargo samples later confirmed the cargo to be Group A and unsafe for carriage. It had a moisture content over 30%, exceeding both the TML of 24% and Flow Moisture Point (FMP) of 26.7%.

Gard noted that Section 1.3 of the IMSBC Code provided instructions for dealing with cargoes not listed in the Code. However, Gard said that in its experience these provisions were not easy to put into practice. “We understand that proposals are being formulated to improve the so-called Tripartite Agreement”, the insurer said.

Shippers must use the Bulk Cargo Shipping Name (BCSN) when the cargo is listed in the Code. Gard noted that shippers sometimes used trade names instead of the BCSN, which might misleadingly suggest that the cargo was not listed. Trade names should only be used as secondary names in addition to the BCSN, said Gard.

If shippers provide cargo documents for solid bulk cargoes without a BCSN, Members are advised to ask them to provide the correct BCSN or the acceptance from the competent authority in accordance with section 1.3.

Gard concluded by noting that in one of the above cases an experienced master could not recall carrying a Group A cargo previously during his career. In both of the above cases, the crew were extremely fortunate to survive unharmed.