This Report of the eleventh session of the International Maritime Organization's Sub-Committee on Dangerous Goods, Solid Cargoes and Containers (DSC), held in London from 11-15 September 2006, is published courtesy of BIMCO.
BC Code Amendments and its mandatory application
Clarification on the classification of seed cake
At DSC 9, BIMCO made a submission which inter alia requested the sub-committee to clarify the definition of the seed cake entry, UN 1386 (b) in the BC Code, as well as the certificate requirements pertaining to the non-hazardous seed cake entry. For easy reference, the definition of seed cake entry UN 1386 (b) is appended below:
SEED CAKE, containing vegetable oil UN 1386
(b) solvent extraction and expelled seeds, containing not more than 10% of oil and when the amount of moisture is higher than 10%, not more than 20% of oil and moisture combined.
The above two issues which remain outstanding were referred at this session to the working group tasked to look into the BC Code Amendments and its mandatory application.
As mentioned in the last BIMCO News article (Loading of seeds and seedcakes dated 15 August 2006), BIMCO members have had problems interpreting the above definition. Hence, at this working group, BIMCO requested that a clear interpretation of the definition, given in the form of an explanatory note, be inserted into this schedule. BIMCO believes that this will greatly aid users of the Code in determining whether the cargo in question to be carried falls under this schedule. This was agreed by the working group and was included in the correspondence group's terms of reference for the next DSC session (DSC 12). BIMCO will accordingly forward an appropriate explanatory note to the correspondence group for consideration and approval at DSC 12.
This explanatory note should to a certain extent clarify that not only does seed cake UN 1386 (b) entry cover seed cakes (solvent extractions and expelled seeds) containing not more than 10% oil and when the amount of moisture is more than 10%, the combined oil and moisture contents should not be more than 20%, it also includes seed cakes that contain not more that 10% moisture.
As for the seed cake non-hazardous entry, the working group was of the view that the certificate requirement which is connected to the exemptions in seed cakes UN 1386(b) and UN 2217 was unclear and would need to be further examined by the correspondence group in their terms of reference for DSC 12.
It should also be noted that as a result of the above BIMCO submission, Australia's proposal to include fuzzy cotton seed as a BC Code entry in its own right was considered by the working group. Pending some minor amendments including a change of name to Linted Cotton Seed, the entry would probably be incorporated in the BC Code amendments for approval at DSC 12.
Carrriage of DRI fines
At the last DSC session (DSC 10), a circular was issued notifying administrations and others of the dangers of shipping and transporting direct reduced iron (DRI) fines ( DSC.1 /circ 36 - Accidents involving transport of DRI fines). IMO members were also urged to submit more relevant information concerning such carriage in order for a proposed schedule on DRI fines to be drawn up for consideration at DSC 11.
At this session, the sub-committee considered the relevant submissions made, which included two proposals in respect of a schedule for DRI fines and related casualty reports of the bulk carriers Adamandas and Ythan.
As a starting point, some information about the carriage of DRI products would be useful here. These products have two major hazards; they can self heat and/or evolve hydrogen when they come into contact with water. Also, the correct ventilation requirements pertaining to these cargoes seem to be unclear i.e., whether inerting or continuous ventilation should be the correct ventilation procedure used.
At the plenary, further problems were raised by various delegations; in particular, the type and form of DRI fines that is being transported, e.g. DRI fines and DRI fines in pellet form are two different products and hence would react differently, thus suggesting that precautions required for safe carriage may not necessarily be the same.
In view of the above concerns and the issue as a whole being of a contentious nature, the sub-committee decided to refer the submissions on the carriage of DRI fines to the working group for detailed consideration and deliberation.
At the working group, in which BIMCO was actively involved, an extensive debate ensued. One delegate, who made various submissions including an elaborate power point presentation, showed and explained the analyses of DRI (A) Briquettes, hot-moulded (also known as HBI) fines conducted by independent organisations, the hazards and risks associated with this carriage as well as the safe practices recommended for safe transport. Furthermore this cargo, as explained by the delegate, is a family of by-products, which are generated during the HBI production and handling process.
Though the submissions made by the said delegate showed that the carriage of DRI (A) Briquettes, hot-moulded fines if transported according to the safe practices advocated, is neither dangerous nor hazardous, it was felt at the working group that the conclusion arrived at was based on limited data, in particular, limited shipments, and hence was not conclusive.
The working group also considered the recommendations made in the casualty report on the bulk carrier Adamandas which carried DRI pellets: that different types of DRI should be defined clearly as apparently, their behavioural characteristics differ significantly hence posing danger if proper precautions are not adhered to. Also, residues lying at the bottom of DRI piles tend to contain mostly fines and therefore should not be loaded on board.
This view was also reiterated in the casualty report for the bulk carrier Ythan, where the particular type of DRI carried should be clearly indicated, advocating that proper terminology be used and not a series of trade names, which tend to confuse matters regarding the safety precautions required to be taken for safe carriage. Also, according to the report, the sizes of the DRI fines dictate the type of ventilation required or inerting of the cargo holds, and for the latter, this may require the use of specialised ships such as OBOs.
In BIMCO's opinion, notwithstanding the large amount of information obtained by the working group, precise and accurate information was still lacking; in particular, information pertaining to the type and form of DRI carried and the correctness of the terminology of the names used. This lack of information, in BIMCO's view, could not enable the working group to determine a clear set of safety procedures required for the safe carriage of DRI fines.
At the end of the debate, it was agreed that more information was needed to allow the DRI products to be defined correctly, and information in the form of the following will be required for DRI (other than DRI (A) Briquettes hot moulded) from the industry:
1. Product types - (a) physical properties including grain sizes (bulk density and grain size distribution, and (b) chemical properties
2. Ship type
3. Mechanical ventilation: (a) arrangements of the ventilation system; (b) performance (number of air changes per hour); (c) duration of ventilation; and (d) type of fan drive (level of explosion proof)
4. Inerting methods and hazards with this cargo
5. Monitoring arrangements and results of measurements during voyage (hydrogen, oxygen, temperature)
6. Moisture content and temperature at the time of shipment
7. Emergency procedures during voyage
8. Any other information (such as loading/unloading precautions etc.)
This above-mentioned list was brought forward to the sub-committee and approved
Pending the receipt of this information or the development of a schedule in the BC Code for DRI fines, BIMCO would caution that members wishing to transport shipments of DRI fines during this interim period should consider very carefully it should be undertaken, taking into account the aforementioned. BIMCO would strongly recommend that members seek the advice of their P&I Club so that an informed decision can be made and the highest level of precautions be taken if carriage of such a product is so decided.
Mandatory application of the BC Code
The working group took on the onerous task of identifying which sections of the BC Code should be mandatory and which recommendatory, as well as identifying the necessary amendments required. Work is still in progress and it is envisaged that a draft mandatory BC Code will be tabled at the next DSC session. It is hoped that the mandatory BC Code, if agreed upon at DSC 12 and adopted by MSC 84 (2008), will be placed on a voluntary basis as from 1 July 2008 in the interest of safety to ships and crew.
In connection with this, the amendments to SOLAS chapters II-2, VI and VII would also be finalised to be in line with the proposed mandatory status of the Code.
Application of the BLU Code to ships carrying grain
The report of the Correspondence group on the extension of the Code of Practice for the Safe Loading and Unloading of Bulk Carriers (BLU Code) to include grain, established at DSC 10 of which BIMCO was a member, was presented to the sub-committee for consideration.
The sub-committee agreed to the following:
1. Preparation of an MSC Circular for approval at MSC 82 adopting the amendments to the BLU Code so that the application of the Code will be extended to ships carrying grain;
2. Preparation of an MSC circular for approval at MSC 82 adopting the amendments to the Manual on Loading and Unloading of Solid Bulk Cargoes for Terminal Representatives in view of the extension of the BLU Code to include grain; and
3. To request the working group on the amendments to the BC Code and its mandatory application to consider the necessary amendments to SOLAS in view of the extension of the BLU Code to include grain.
Apart from the above, the correspondence group commented that the BLU Code and the Manual for Terminal Representatives should be included in the BC Code as one publication. The reason is that this would make referencing an easier task since only one source of information instead of three will be identified. This was warmly received at the plenary. A suggestion to include them as the BC Code Supplements, just like the IMDG Code Supplements, was made at the plenary and it is envisaged that this course of action is likely.
IMDG Code Amendments
The Sub-committee considered the following issues:
Carriage of radioactive materials
At this session, the sub-committee agreed with the proposal that the IMO Secretariat would act as a facilitator to monitor the industry's experiences, in particular difficulties encountered with the shipment of IMDG Code Class 7 Radio Active Materials (RAM). The secretariat would then, in accordance with reports received in relation thereto, consider the appropriate action to be taken, e.g., this may involve contacting the relevant national authorities if there are delays or denials of carriage. An ad hoc mechanism to put in place this facilitation process is underway and hopefully it will pave the way towards resolving the difficulties encountered in the carriage of RAM materials.
It should also be noted that at the last session of the Facilitation Committee (FAL 33), it was agreed that it would not be appropriate to assign specific UN numbers and thus an associated proper shipping name to the carriage of such materials. In addition, technical concerns were raised at this sub-committee regarding an entry in the Transport Document and/or Dangerous Goods Manifest (FAL Form 7) to confirm that RAM shipments are to be used in medical or public health applications only. Concerns such as e.g. the definition of medical, consumer, public health or agricultural applications are at present not clear in the broader context of radioactive materials and also the issue concerned here is multimodal in nature, and hence should be brought to the attention of the UN committee of experts on the transport of dangerous goods and on the globally harmonized system of classification and labelling of chemicals. In view of these concerns, the sub-committee advised that these concerns be relayed to the FAL 34 and MSC 83 accordingly.
Unpacked ice in cargo transport units
A submission on unpacked dry ice which is normally used for cooling purposes, e.g. used for the transport of seafood, in standard freight containers was raised at this session. The primary danger associated with this unpacked dry ice was that during transport, large amounts of the dry ice could turn into gaseous carbon dioxide, which will significantly reduce the oxygen content in a cargo hold. Hence, such transport without any warning seems unacceptable. Furthermore, although dry ice is listed as a dangerous good under the IMDG Code, the requirements of the IMDG Code pertaining to the carriage of unpacked dry ice seem unclear.
The sub-committee considered the paper and approved in principle the following proposals indicated in the submission, with the instruction that the same be forwarded to the group tasked with the draft amendments (34-08) to the IMDG Code for consideration and incorporation:
1. That transport of unpacked dry ice in freight containers should not be permitted;
2. With regard to IMO special provision 297 concerning carriage of dry ice under certain conditions, to align IMO SP 297 with that of the UN Recommendations SP 297; and
3. That 5.4.2.1.8 of the IMDG Code should be amended to read "When packages containing carbon dioxide solid (dry ice) are loaded into the container/vehicle, the exterior of the container/vehicle should be conspicuously marked on two sides "WARNING CO2 SOLID (DRY ICE)"
Some delegations expressed the view that stowage of cargo transport units containing dry ice should not be allowed under deck and remarked on the need to have them appropriately marked. The sub-committee advised that this issue should be further examined in a wider context as in the form of multimodal transport and hence invited the delegation that submitted the above to raise this issue at a future meeting of the UN Sub-committee of experts on the transport of dangerous goods.
Next DSC meeting
DSC 12 has been tentatively scheduled for 10-14 September 2007.
| 
