Dangerous Solid Cargoes in Bulk February 2012

8/11/2019 Dangerous Solid Cargoes in Bulk February 2012

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Dangerous solidcargoes in bulk

DRI, nickel and iron ores

A selection of articles previouslypublished by Gard AS


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Gard AS, February 2012

3

Carriage of dangerous cargo - Questions to ask before you say yes ................................ 4

Understanding the different direct reduced iron products .................................................. 7

The new IMSBC Code and the carriage of direct reduced iron .......................................... 8

Carriage of Direct Reduced Iron (DRI) by Sea - Changes to the IMO Code of Safe

Practice for Solid Bulk Cargoes ......................................................................................... 9

The dangers of carrying Direct Reduced Iron (DRI) ............................................................ 12

Liquefaction of unprocessed mineral ores - Iron ore fines and nickel ore ........................ 13

Intercargo publishes guide for the safe loading of nickel ore ........................................... 17

Shifting solid bulk cargoes .................................................................................................... 18

Cargo liquefaction - An update ............................................................................................ 21

Cargo liquefaction problems sinter feed from Brazil....................................................... 25

Liquefaction of cargoes of iron ore ...................................................................................... 26

India - Safe Shipment of Iron Ore Fines from Indian Ports ................................................ 27

Indonesia and the Philippines Safe Carriage of Nickel Ore Cargoes ............................ 29

The carriage of nickel ore from the Philippines and Indonesia - The insurance position 32

IMSBC Code - Charterparty clause for solid bulk cargoes that may liquefy ...................... 33

IMSBC Code amendmentsregarding cargoes that may liquefy ........................................ 34

Contents

Disclaimer

The information contained in this publication is compiled from material previously published by Gard AS and isprovided for general information purposes only. Whilst we have taken every care to ensure the accuracy and quality

of the information provided at the time of original publication, Gard AS can accept no responsibility in respect of anyloss or damage of any kind whatsoever which may arise from reliance on information contained in this publicationregardless of whether such information originates from Gard AS, its shareholders, correspondents or othercontributors.


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Carriage of dangerouscargo - Questions to ask

before you say yesThe shipment of dangerous cargo isnow commonplace in many trades. Thisarticle is aimed at those operating intrades where the carriage of dangerouscargo is not an ordinary occurrence.

Whilst cargoes can be legallydangerous as well as physicallydangerous, this article is written in thecontext of the latter. Unfortunately,there has been a number of cases inwhich crews and their ships have beenlost because of dangerous cargoes(e.g., due to liquefaction) or havesuffered harm from fires/explosionscaused by dangerous cargoes.1Thesad truth is that there are some shipoperators who probably do notknow they are carrying a dangerouscargo because shippers misdeclarethem, in some cases deliberately. Thecommentary below summarises someof the main questions to be askedbefore agreeing to carry dangerous

cargoes, perhaps starting with the mostimportant question: who is shipping?It is in the industrys interest, andparticularly the ships crews, to avoiddoing business with so-called rogueshippers.

Who is shipping?If the request to ship dangerous cargo(or cargo which, given its description,may be dangerous but not declared assuch) is made by a party with whom thecarrier has had no previous dealingsor experience, investigations oughtto be undertaken as to that partys

experience in shipping such cargo,and whether they have previouslybeen connected with any accidentsor rogue shipments. Of course, rogueshippers can be expected to changenames, so be aware of newly-formedcompanies. If the request or order isfrom time charterers, it is still importantto indentify and research the underlyingshipper. In summary: is the party askingto ship/shipping dangerous cargoreliable and trustworthy?What can you refuse to carry?

Under a time charterparty, the charterer

has relative freedom to employ theship on lawful trades and to loadlawful cargoes, but shipowners canexclude their right to load certaincargoes. Therefore, before entering

any time charter, particularly a longone, shipowners should think carefullyabout which dangerous cargoes theywish to exclude. Standard form timecharterparties usually contain a cargoexclusion clause, but not all require theshipowners prior written consent. It isup to the owner to name cargoes hewishes to exclude from carriage andit is worth doing some research (andmaybe obtaining expert advice) beforedoing so. It may be easier to expresslystate which cargoes are allowed underthe charterparty, to the exclusion of allothers without prior written consent.Regulations may require certain fire-fighting arrangements or ships ofspecial construction/strengtheningfor the carriage of dangerous cargoesand for a document of compliance tobe issued before dangerous cargoescan be carried. Also, there may belimitations on the quantity of dangerouscargo that the ship can carry, e.g.,

for structural/stability reasons and/orbecause of restrictions under the IMDGCode. On smaller ships, the simpleability to safely segregate certain goodsmay be an issue.

What are you asked to carry?It is all too common for dangerousgoods to be misdeclared. It alsohappens that they get incorrectlyor incompletely named. Differentcompanies, countries and trades mayalso use different names for specificdangerous cargoes.2It is importantto establish the exact cargo you are

dealing with by obtaining details onits physical and chemical properties,its hazards and origin. It is then a caseof referring to the relevant codes/regulations, such as SOLAS, BCCode and IMDG Code, to establishthe relevant carriage guidance. It isimportant to note, however, that thecargo lists in the IMDG and IMSBCCodes are not exhaustive, which iswhy details from shippers on cargoproperties and hazards are important.Care should be taken to refer to anyamendments to the relevant codes/regulations and/or their very latest

version (only recently has a new BCCode been introduced - now namedthe IMSBC Code). Guidance can besought from the P&I Club or otherindustry bodies and if necessary advice

Gard News 197,February/April 2010

can be obtained from experts. Withreference to the IMSBC Code, it shouldbe noted that a number of specificcargoes may be grouped togetherunder a general entry, e.g., mineralconcentrates and metal sulphideconcentrates.

What are the dangers/hazardsposed by the cargo?Once the cargo has been correctlyidentified, the carrier should seek tofully understand the dangers posed bythat cargo to the ship and crew. Beyondwhat is provided in relevant codes/regulations, research can be undertakenwith relevant industry bodies, the P&IClub,3flag state4and port state. It isimportant to be aware that codes suchas the IMDG Code and IMSBC Codemay not be completely comprehensive.For example, some ores, fines andconcentrates that may liquefy may notbe identified as cargoes possessing that

hazard in the IMSBC Code. If necessary,expert advice can be sought. The cargomay be dangerous by its very nature(for instance, it poses chemical hazards),but others may only become dangerousin certain circumstances. The carriershould have a basic understanding ofhow and why the cargo can becomedangerous - it may depend on the rateat which it is loaded, its mass/densitywithin a given cargo space, its moisturecontent, temperature or contactwith certain solids/liquids/gases. It isworth remembering that seeminglysafe cargoes can create dangerous

situations; for example wood can causeoxygen depletion with the obvious riskthat poses to those that may seek toenter the cargo space.

What does the ship/crew need tosafely carry dangerous cargo?The ship may need to be of a certainconstruction or strengthening for thecarriage of dangerous cargo. It mayalso need special equipment, suchas fire-fighting apparatus, a nitrogengenerator for inerting, temperaturemonitoring, gas detection devices,protective clothing for the crew. The

crew will need to be provided with therelevant codes/regulations containingguidance material on safe carriage andon responding to accidents involvingdangerous cargo (e.g., the Medical


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First Aid Guide for Use in AccidentsInvolving Dangerous Goods). Of course,and most importantly, the crew willneed to know exactly what dangerouscargo they are carrying (and, indeed,the answers to many of the questionsposed in this article - and more).

What should the shippers provide?The shippers should provide the exactcargo that the carrier has agreed tocarry. The cargo actually presentedfor shipment may well differ from thatfirst declared/notified and the carriershould check this before any cargo isloaded. Obviously, this will be difficultwith packaged/containerised cargo,but at least external labels shouldbe checked. Documentation shouldalso match the cargo presented forshipment and that which the carrierhas agreed to carry. Full and properdocumentation is a key aspect in the

carriage of dangerous cargo and, again,no cargo should be loaded in absenceof this. Unfortunately, there have beenmany instances in which shippers havesimply failed to provide the requireddocumentation.5

Documentary requirements are setout in the relevant regulations/codesand, essentially, form the basis of theinformation on the dangerous cargowhich the carrier needs as evidence thatthe goods/cargo is safe for carriage,to alert the carrier and his crew to therelevant hazards, and to guide the

carrier/his crew on safe carriage andhow to react in the case of emergency.The information should be providedsufficiently in advance to enableprecautions to be put into effect by thecarrier. The shippers documentationshould include analysis certificatesfor key safety parameters, such as themoisture content, flow moisture pointand transportable moisture limit fora bulk cargo that may liquefy. Theshipper should provide the relevantdeclarations that the informationprovided is accurate. The informationprovided should be truly representative

of the cargo actually loaded. Key safetyparameters stated in generic materialsafety data sheets may not be specificto the cargo to be loaded and shouldbe treated with caution in the absenceof analysis certificates that are specificto the cargo to be loaded. Sadly, therehave been instances in which shipperscertificates have been found not tobe truly representative of the cargoskey safety parameters, which is why itis extremely important for the carriernot to place full reliance on them. Ifthe carrier is in any doubt, he shouldconsider arranging his own tests (see

below). In addition to documentation,dangerous cargo in a packaged formshould be properly packaged andlabelled by the shipper.

What does your contract say?Cargo exclusions in time charterpartieshave already been mentioned, but whatelse does the charterparty say aboutthe carriage of dangerous cargo? Is themaster entitled to refuse to load, or, ifalready loaded, to unload and disposeof dangerous cargo that is unsafe for

carriage at charterers time, risk andexpense? If the contract incorporatesor will be compulsorily subject to theHague/Hague-Visby/Hamburg Rules,it should be noted that all these Rulescontain provisions with regard todangerous cargoes. For example, theHague-Visby Rules provide (in Article IVRule 6):Goods of an inflammable, explosiveor dangerous nature to the shipmentwhereof the carrier, master or agentof the carrier has not consentedwith knowledge of their nature andcharacter, may at any time before

discharge be landed at any place, ordestroyed or rendered innocuous bythe carrier without compensation andthe shipper of such goods shall beliable for all damages and expensesdirectly or indirectly arising out ofor resulting from such shipment. Ifany such goods shipped with suchknowledge and consent shall becomea danger to the ship or cargo, they mayin like manner be landed at any place,or destroyed or rendered innocuous bythe carrier without liability on the part ofthe carrier except to general average,if any.

The applicable law and jurisdictionunder the contract are also worthconsidering. Will these result in readyaccess to justice in the event of adispute or casualty involving dangerouscargo? It should be kept in mindthat the law covering liability for loss/damage arising out of the shipment ofdangerous goods varies from countryto country. Under English commonlaw charterers/shippers would riskbeing in breach of an implied andabsolute undertaking if they were toload cargo without notice of its peculiar

characteristics which endanger the ship,unless the owners or their crew knewor ought reasonably to have known ofthem. In the context of cargo whichis known to be dangerous, Englishcase law suggests that owners shouldbe regarded as having contracted tobear risks which can be avoided byappropriate methods of carriage forthe goods of the relevant type (theowners being expected to keep up todate with the correct carriage methodsbut not to have the knowledge ofan expert chemist), but not the risksproduced by a particular cargo, whichare of a totally different kind (whether innature or degree) from those attachedto the carriage of the described cargo,and which should fall on the shippers/

charterers. In a recent case6the Englishcourts decided that a carriers rightof indemnity against a shipper wasnot limited to a situation where thedangerous nature was the sole ordominant cause of the loss, but wherein any event the damage would nothave occurred except for the peculiar

characteristics of the actual cargoshipped.7The position under Englishlaw can be contrasted with that underUS law, which appears to be moreonerous for the shipowner.8

If the Hague/Hague-Visby Rules apply,a claim by the carrier against theshipper under Article IV Rule 6 would,under English law, be defeated if thecarrier breached his duty to exercisedue diligence to make ship seaworthyand that was a contributing cause ofdamage resulting from shipment ofdangerous cargo. This is very relevant,

as shown in the case of the EURASIANDREAM.9In that case the English courtsdecided that a pure car carrier wasrendered unseaworthy as a result of theoperators failure to provide the vesselwith specific documentation dealingwith the peculiar danger of fire on carcarriers and the precautions to be takento avoid such fires.

The stowage of dangerous goods isoften an important factor in their safecarriage and it is worth consideringwho would be responsible for stowageunder the contract. In a recent English

court case (involving the negligentstowage of dangerous cargo next toa ships bunker tanks),10it was foundthat where a charterparty allocatedresponsibility for the stowage to thecharterers, the shipowners had noresponsibility to the charterers fordamages consequent on improperstowage, even if it rendered thevessel unseaworthy. The outcome ofthe case would almost certainly havebeen different had the words andresponsibility been added to clause8 of New York Produce Exchange formcharter.

It should not be forgotten that,when negotiating contract terms,the shipowner has an opportunity tostipulate what the shippers/charterersare obliged to provide in advance ofloading dangerous cargo and what thecarrier is entitled to do if the shipper/charterer does not comply. This canbe particularly relevant if the place ofloading has a history of problem orrogue shipments. Consideration canalso be given to making contractualprovision for full co-operation fromcargo interests, full access to the

cargo ashore for possible inspection/sampling and for analysis at specificlaboratories which can be relied uponto give accurate results (preferably


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being at owners option to invokesuch provisions, whilst not relievingcharterers and cargo interests of theprimary obligation to provide fulland accurate documentation). Suchprovisions would need to be carefullyconsidered on a case by case basis asthe ultimate effect could be to make it

more difficult for an owner to refuse tocarry a cargo in respect of which doubtsstill remain.

What is your insurance cover?It is important to be aware that thecarriage of dangerous cargo can, incertain circumstances, prejudice thecarriers insurance cover. There may bea warranty in the insurance contractthat no dangerous cargoes will becarried, or that they will only be carriedin accordance with relevant regulations.In the absence of any warranty, ageneral duty of disclosure applies at

the inception of an insurance contract(see for example Rule 6 of Gards Rulesfor P&I cover). If a vessels trade indangerous cargo is not made knownto the insurer and the insurer could notbe reasonably expected to know ofsuch trade, insurance cover could beprejudiced. Similarly, a radical changein the trade of the ship from one whichhas, for example, involved the carriageof steel to one involving the carriageof dangerous cargo in bulk couldwell be deemed to be an alterationof the risk requiring disclosure to theinsurer. Rule 7 of Gards Rules for P&I

cover (Alteration of Risk) sets out theconsequences of an alteration of risknot disclosed to the Club: one beingthat the member has no cover forliability, loss, cost or expense caused orincreased by the alteration of the risk.

Gards P&I Rule 74 (Unlawful Trades etc.)provides that:The Association shall not coverliabilities, losses, costs or expensesarising out of or consequent upon theShip carrying contraband, blockaderunning or being employed in or on anunlawful, unsafe or unduly hazardous

trade or voyage.

The words unsafe or unduly hazardoustrade or voyage may be of particularrelevance in the context of carriageof dangerous cargo, and someguidance may be derived from thelegal principles which govern contractsof carriage. Other Club Rules, such asRule 8 (Classification and Certificationof the Ship), requiring compliance withstatutory requirements of the ships flagstate, and Rule 73 (Nuclear Perils), whichsets out certain exclusions with regardto the carriage of nuclear material, may

also be relevant.

Where/when is the carriage to/from?Another important considerationwhen asked to carry dangerous cargois the place/country of shipment.Sadly, a number of countries have apoor reputation for the shipment ofdangerous cargoes, probably due

to a lack of internal controls and/or sanctions on shippers. P&I Clubcirculars and articles can be referredto for guidance in this regard. Thenature of the voyage and the shipsremoteness from assistance shouldalso be considered. A long voyagethrough predictably heavy weather may,for example, raise additional concern.Having considered these factors,decisions can be taken on how best tosafeguard the crew and the ship.

How to manage the peculiar risks?If the decision is that the ship can carry

dangerous cargo, it is worth spendingtime considering how the risks peculiarto the dangerous cargo in question canbe best managed and minimised. Themost important phase is pre-carriageand, as already mentioned, the carriershould put in place his own checks toensure that the cargo presented forshipment is safe for carriage.11Findingout how and where a dangerous bulkcargo susceptible to liquefaction hasbeen stored and for how long is usefulto know when moisture content ofthe cargo is the key safety parameter.Performing the carriers own tests on

the cargo can be as simple as the crewperforming a can test12but if in anydoubt proper representative samplingand reliable analysis will need to beconsidered. It goes without sayingthat the crew will need to be properlybriefed before loading, and all crewmembers should be aware of thelocation and dangers of the cargo.It may be necessary to display signsprohibiting entry into spaces containingdangerous cargo and/or properly notifythird parties involved in the carriage,such as stevedores and terminalpersonnel, about the dangerous cargo.

Perhaps most importantly, the crew willneed to know the warning signs thatsomething is going wrong with thecargo and how they should respond.If an accident does occur, it will havebeen prudent to have drilled thecrew in the emergency procedures asthe speed and thoroughness of theresponse can often make the difference.The lessons learnt from previousincidents are extremely valuable: theydemonstrate the importance of properrisk assessment13and quick access toaccurate information and expert advice/assistance.14

Why should you take the risk?After reading this article you may askyourself: why should I take the risk ofcarrying dangerous cargo? No doubtthe vast majority of dangerous cargois carried successfully and withoutproblem. On the occasions whenproblems do occur, the consequences

can be severe. A cautious approach isalways to be recommended. As always,prevention is better than cure.

Footnotes1 See article Liquefaction ofunprocessed mineral ores - Iron orefines and nickel ore elsewhere in thisissue of Gard News.2 See for example the articleUnderstanding the different directreduced iron products in Gard Newsissue No. 178.3 See Gards for example LossPrevention Circular No. 07-03, The

dangers of carrying Direct Reduced Iron(DRI).4 See for example the UK MCA MarineGuidance Note MGN 107 (M) inreference to The Merchant Shipping(Carriage of Cargoes) Regulations 1999.5 See the article Shipowners standfirm against lack of proper BC Codedocumentation in Gard News issueNo.193.6 CSAV v. Sinochem Tianjin Importand Export Corp. (The ACONCAGUA)[2009] EWHC 1880 (Comm).7 See article Has justice finally beendone in the calcium hypochlorite

cases? in Gard News issue No. 196.8 See article The DG HARMONY onappeal in Gard News issue No. 191.9 See article An insight into theinterpretation and implementation ofthe ISM Code in Gard News issue No.169.10 CSAV v. MS ER HamburgSchiffahrtsgesellschaft mbH & Co KG(The ER HAMBURG) [2006] EWHC 483(Comm).11 See for example Loss PreventionCircular No. 15-08 Loading of hot coalat Maputo, Mozambique.12 See the article Shipowners stand

firm against lack of proper BC Codedocumentation in Gard News issueNo.193.13 See for example the article P&Iincident - dangerous goods containeroverboard in Gard News issue No.179.14 See for example the article Facingthe challenge of fire at sea in GardNews issue No. 175.


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Understanding thedifferent direct reduced

iron productsThe term direct reduced iron, or DRI,has a generic meaning which covers anumber of products with a variety ofproperties and hazards.

There has been a disturbing increase inthe number of potential life threateningincidents involving the carriage ofdirect reduced iron (DRI). Gard LossPrevention Circular No. 07/2003provided general advice on the carriageof this product.1Since this circularwas issued Gard has received severalenquiries from members and clientsasking about the carriage of this cargoand the actions to be taken to preventany problems occurring during thevoyage.

Disturbingly, some enquiries relateto types of DRI which charterers andshippers do not consider as dangerousor restricted in any way. The termsused include HBI, hot briquette,

fines, remet and metallic fines.These terms may well be an accuratedescription of the specific product butthey are often used to avoid limitationsagreed in charterparties for the carriageof dangerous cargoes.

It is important to note that the term DRI,generally used in charterparties, has ageneric meaning, covering a numberof products with a variety of propertiesand hazards. It also covers a technicaldescription of a specific type of refinediron ore.

These products must be grouped underthe genus of direct reduced iron (DRIBC 015 or HBI BC 016) for the purposesof the IMO Code of Safe Practice forSolid Bulk Cargoes (BC Code). Thisarticle is intended to help mastersand owners understand what may ormay not be offered to them and whatprecautions should be taken.

DRI Direct reduced ironNormally in the form of sponge pelletsor lumps varying between 6 and 25mmnominal diameter, but often 8 to 12mmdiameter. The IMO BC Code classes

this product as a material that ishazardous only when in bulk (MHB).It can be found under the BC Codeas BC015. If this product becomeswet it can significantly overheat and

Gard News 178,May/July 2005

emit hydrogen gas. Thus it must becarried under inert conditions. Nitrogengas is normally used and is appliedto the holds by way of a temporarymanifold fitted to the tank top priorto loading. Thermocouples must alsobe positioned in the cargo on the tanktop and elsewhere throughout thestow at different heights to monitorthe temperature. Gas monitoring ofthe holds, normally for hydrogen andoxygen, must also be undertakenthroughout the voyage. The productmust be kept dry at all times priorto and during carriage. The productshould be treated as DRI, BC 015.

HBI Hot briquetted ironThis material is manufactured fromDRI product, which is compressed attemperatures exceeding 650 C toform briquettes between about 90 and130mm long, 80 to 100mm wide and 20to 50mm thick. This product is a much

safer form of DRI than DRI pellets. Itis far more resistant to overheating ifit becomes wet. During a voyage itcan still generate small amounts ofhydrogen. Inerting is not required bythe BC Code but adequate surfaceventilation is required. It should betreated as HBI BC 016, provided thereis no additional qualification to the HBI(see below).

CBI Cold briquetted ironCBI is manufactured from the variousresidual products produced duringthe manufacture of associated ferrous

products and semi-refined raw materialsincluding DRI (DRI fines but also otherresiduals). Some manufacturers coldbriquette their own DRI pellets so thatthey can be fed into their particularfurnace. CBI briquettes are producedat temperatures below 650C anda binder is often used. Because thebriquetting operation is carried out ata temperature lower than is used forHBI, some of the critical characteristicsof DRI, such as porosity, relatively largesurface area and a reactive surface,remain in the CBI to some degree. Thusessentially CBI can have the same or

very similar properties to DRI pelletsand should be treated in exactly thesame manner, as the propensity tooverheat and generate hydrogen,if it becomes wet, still remains. The

original source of the material usedto manufacture CBI is obviously ofsignificance if this can not be verifiedthen the CBI should be treated in asimilar manner to DRI, BC 015.

DRI finesThese are the by-product of the DRImanufacturing process, pellets orbriquettes, and are often 4mm indiameter or less. Although smallerthan normal DRI pellets, this product isessentially DRI pellets and will behavein a similar manner, so it should betreated with the same caution: it shouldbe kept dry at all times, the holdsshould be inerted and temperature andgas monitoring should be carried out.One added potential hazard with thisproduct is that it may not have beenstored under ideal dry conditions atthe plant, as should be the case withnormal DRI, and therefore there maybe wet pockets of DRI fines within the

cargo, which can subsequently causeproblems during the voyage. Therefore,it should be treated as DRI, BC 015 andthe storage history should be obtained.HBI finesThis is a term used by shippers todescribe ordinary DRI fines possibly inan attempt to achieve a reduction in thecarriage requirements as afforded toreal HBI. The fines can be either simpleDRI fines which have been completelymisdescribed by the shipper, or finesproduced during production of HBI.If the fines have been produced after

the HBI briquetting process then it ispossible that they may be in a relativelysafe form and could be treated ina similar manner to HBI briquettes.However, if the fines have beenproduced prior to the HBI briquettingprocess, they may potentially be similarto a DRI pellet product. If the history ofthe fines is not known then they shouldbe considered as DRI fines and treatedin the same manner as DRI, BC 015.

Remet finesThis is another term used by shippersto describe DRI fines. They are not re-

melted fines, as the name could andmay be intended to suggest, for theobvious reason that if the product hadbeen produced by a (re)melting process(which DRI is not) then it would not be


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in the form of fines. If a ship is offered acargo of this description there is a veryhigh chance of the product being DRIfines and it should therefore be treatedas DRI, BC 015.

Remet fines (HBI)As with remet fines, remet fines (HBI)

should be treated as DRI, BC 015.

Metallic HBI FinesAs with HBI fines, metallic HBI finesshould be treated as DRI, BC 015.

Other namesShippers have used other qualificationsfor DRI fines which exclude theabbreviation DRI, such as Orinocoiron remet fines and Orinoco remetfines in bulk. These should all betreated as DRI, BC 015.

Conclusion

It is a requirement of SOLAS Chapters

VI and VII and of the IBC Code thatthe master must be provided with allrelevant documentation related to thecarriage of the intended cargo. Ownersshould be wary of any bulk cargooffered for shipment under trade namesor abbreviated names and always insiston a full product description, including

technical and alternative names. Futureversions of the BC Code are likely tomaintain the current two categories ofDRI but differentiate between the twotypes by referring to them as DRI Aor B.

In summary, if any iron bulk cargo isoffered as fines and is described withterminology such as HBI, remet,or any other wording not found in therelevant section of the BC Code, itshould be treated as a DRI product asdetailed in the BC Code No. 015. Theonus is on the shipper to show that

the fines have not originated from DRI

The new IMSBC Codeand the carriage of directreduced iron

New code introduces new carriagerequirements for direct reduced iron.

The International Maritime Solid BulkCargoes Code (IMSBC Code) andamendments to SOLAS chapter VI tomake the IMSBC Code mandatory wereadopted at the 85th Session of the IMOMaritime Safety Committee at the endof 2008. The amendments are expectedto enter into force on 1st January 2011.

The IMSBC Code will replace the Codeof Safe Practice for Solid Bulk Cargoes(BC Code).

The IMSBC Code introduces newcarriage requirements for directreduced iron (DRI), which has beendivided into the following three sub-categories, based on the increasinghazardous nature of each group:1

DRI (A), made of hot mouldedbriquettes, is the least dangerous, asthe process reduces the reactivity of DRIand the carriage requirements remain

essentially the same as the previous BCCode wording. DRI (B), made up of lumps, pellets orcold moulded briquettes, is considered

to be highly reactive to moisture andthe amendments allow carriage onlyunder inert conditions with enhancedmonitoring of atmosphere and changesin emergency procedures to reflectcurrent best practices.

For DRI (B), the BC Code alreadymakes carriage compulsory for theentire voyage in an inert atmospherecontaining less than five per cent

oxygen. The IMSBC Code repeats thisrequirement, but specifies how thisis to be performed. It states that anadequate means of maintaining theinert atmosphere in the hold(s) for theentire duration of the voyage should beprovided. An example of this is a vesselfitted with a nitrogen generating plant. DRI (C) comprises by-products, suchas fines and small particles, which arenot dealt with in the BC Code. DRI (C)has very similar properties to DRI (B),but finely divided DRI (C) is consideredto be more reactive than DRI (B). Thisnew schedule has been added to reflect

the increase in carriage of fines andsmall particles, which are by-productsof the manufacture of DRI (A) and (B).This new schedule closely reflects the

manufacture, and without that evidencethe ship is entitled to insist on applyingthe more stringent requirements of BCCode 015 to the loading and carriage.

If the vessel has any doubts aboutany particular DRI loading it isrecommended that independent advice

be obtained from an expert. Gard ishappy to assist in this regard, and in anyother way it can.

This article was produced with the kindassistance of Dave Hughes, ConsultantMetallurgist, Taylor Marine TR Little.

Footnote1 See also the article The dangers ofcarrying direct reduced iron (DRI) inGard News issue No. 173.

Gard News 194,May/July 2009

increased carriage requirements for DRI(B).

In addition to DRI, the IMSBC Codeintroduces modified rules to thecarriage of coal, brown coal briquettesand formed solid sulphur.

Footnotes1 See also article Understanding thedifferent direct reduced iron products

in Gard News issue No. 178.


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Carriage of Direct Reduced

Iron (DRI) by Sea - Changes to

the IMO Code of Safe Practicefor Solid Bulk CargoesMembers will be aware of the generalconcerns that exist with regard to thecarriage of Direct Reduced Iron (DRI)by sea. These concerns have increasedsignificantly since the loss of life arisingfrom the carriage of DRI on boardthe YTHAN (2004) and the deliberatesinking by the French Authorities of theADAMANDAS (2003) with her cargoand bunkers on board.

The explosion and accompanyingtragic loss of life on the Ythan resultedfrom the interaction between thevessels cargo of HBI Fines and thefresh water (moisture) contained in thecargo at the time of loading. At thetime of the incident the IMO Codeof Safe Practice for Solid Bulk Cargo(the Code) categorised two types ofDRI, namely hot moulded briquettesor hot briquetted iron (subsequentlyre-designated as DRI (A)), and pellets,lumps etc. (subsequently re-designated

as DRI (B)). The DRI/HBI fines cargocould not in reality be categorised aseither (A) or (B) under the Code and theexpert advice was to treat it as the moredangerous and reactive type of DRI (B).

Following the above mentionedincidents and their subsequentinvestigation, the IMO Sub-Committeeon Dangerous Goods, Solid Cargoesand Containers (DSC) consideredamendments to the relevant Schedulesof the Code as part of a review of theCode. The Marshall Islands, Intercargoand the IG proposed that DRI Fines

should be individually classified anddesignated DRI (C) and both DRI (B)and (C) should be carried under aninert (nitrogen) atmosphere with amaximum allowable moisture contentof 0.3 per cent in respect of DRI (C).It was recommended by the DSC atits 12th session held in September2008 that these (and other minor)amendments be adopted by the IMOthrough the IMO Maritime SafetyCommittee (MSC). The MSC adoptedthe recommendations in November2008 and the Code was renamed theInternational Maritime Solid Bulk Cargo

Code (IMSBC Code).

The main changes to the Code inrelation to the carriage of DRI (A), (B)

and (C) can be summarised as follows:

DRI (A), Briquettes, hot-moulded a maximum limit on the moisture

content of 1 per cent. cargo is to comprise essentially

whole briquettes. Fines of less than6.35mm and dust are limited to 5per cent.

concentration of hydrogen tobe measured throughout thevoyage. If it exceeds 25 per centLEL appropriate precautions to betaken.

surface ventilation only shall beconducted as necessary. Whenmechanical ventilation is used, thefans shall be certified as explosion-proof and shall prevent sparkgeneration.

wire mesh guards shall be fittedover inlet and outlet ventilationopenings.

DRI (B), Lumps, pellets, cold-moulded briquettes average particle size is limited to

6.35mm to 25mm. Fines of less than6.35mm and dust are limited to 5per cent.

loading conveyors are to be dry. prior to loading, an ultrasonic test

or another equivalent methodwith a suitable instrument shallbe conducted to ensure weathertightness of the hatch covers andclosing arrangements.

moisture content must be less than0.3 per cent and must be monitored

during loading. any cargo that has already beenloaded into a cargo space andwhich subsequently becomeswetted, or in which reactions havestarted, shall be discharged withoutdelay.

carriage is only permitted under aninert gas blanket.

the ship shall be provided withthe means of reliably measuringthe temperature at several pointswithin the stow, and determiningthe concentrations of hydrogenand oxygen in the cargo space

atmosphere on voyage whilstminimizing the loss of the inertatmosphere.

Member CircularNo. 3/2010, 16 March 2010

the ship shall be provided withthe means to ensure that therequirement to maintain the oxygenconcentration below 5 per centcan be achieved throughout thevoyage. The ships fixed CO

2fire-

fighting system shall not be usedfor this purpose. Considerationshould therefore be given toproviding vessels with the meansto top up the cargo spaces withadditional supplies of inert gashaving regard to the duration of thevoyage.

the ship shall not sail until themaster and a competent person aresatisfied that:- all loaded cargo spaces are

correctly sealed and inerted,- the cargo temperatures have

stabilised at all measuringpoints and are less than 65C,and

- concentration of hydrogen in

the free space has stabilisedand is less than 0.2 per cent byvolume.

Oxygen concentration shall bemaintained at less than 5 per centthroughout duration of voyage.

DRI (C), By-products, Fines average particle size is less than

6.35mm, and there are to be noparticles greater than 12mm in size.

the reactivity of this cargo isextremely difficult to assess dueto the nature of the material thatcan be included in the category.

A worst-case scenario shouldtherefore be assumed at all times. carriage requirements are largely

identical to those for DRI (B),including the 0.3 per cent limit onmoisture and carriage under aninert gas blanket.

Attached for assistance is a moredetailed summary of the carriagerequirements for DRI under the IMSBCCode but it should be noted that itis necessary to comply with all of therelevant provisions of the Code.

In light of the above, members, whencarrying DRI (B) or (C), should satisfythemselves that the nominated vessel


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is capable of maintaining oxygen levelsat a concentration of below 5 per centthroughout the voyage.

The Code will remain recommendatoryuntil January 2011 at which point it willbecome mandatory.

If Members have any questions or

All Types of DRI Fines are now defined as particles up to 6.35mm () in size. Cargo spaces shall be clean, dry and free from salt and residues of previous cargoes. Wooden fixtures and

combustible materials shall be removed.

The carriers representative is to have reasonable access to stockpiles and loading installations for inspection. Prior to loading, the shipper shall provide the Master with a certificate issued by a competent person stating thecargo is suitable for shipment and that it conforms with the requirements of the Code in terms of particle size,moisture content and temperature.

A similar certificate shall be provided after loading relating to the whole consignment. The shipper shall provide comprehensive information on the cargo and safety procedures to be followed in the

event of an emergency. No cargo shall be loaded or transferred during precipitation and non-working hatches shall be kept closed. The cargo shall not be accepted when its temperature is in excess of 65oC, or its moisture content exceeds the

permitted value, or if the quantity of fines exceeds the permitted value, where appropriate. The cargo temperatures shall be monitored during loading and recorded in a log. The cargo shall be trimmed in accordance with the relevant provisions of the Code. Adjacent tanks other than double bottom tanks shall be kept empty during the voyage. Weather tightness shall be maintained throughout the voyage. The bilge wells shall be clean and dry and protected from ingress of cargo.

Precautions shall be taken to protect personnel, equipment etc. from the dust of the cargo. During handling of the cargo, NO SMOKING signs shall be posted and no naked lights or other ignition sources

permitted. Suitable precautions shall be taken before entering cargo spaces, which be depleted of oxygen and/or contain a

flammable atmosphere. The ship shall be provided with a detector suitable for measuring hydrogen in an oxygen depleted atmosphere

and for use in a flammable atmosphere. Cargo temperatures and hydrogen concentrations in hold atmospheres shall be measured at regular intervals

during the voyage. If the hydrogen concentration exceeds 1 per cent or the cargo temperature exceeds 65oC, appropriate safety

precautions shall be taken. If in doubt, expert advice shall be sought. Bilge wells shall be checked regularly for the presence of water. All records of temperature, hydrogen and oxygen measurements, where appropriate, are to be retained on board

for 2 years. The hydrogen concentration shall be measured in the holds prior to opening the hatch covers.

DRI (A), Briquettes, hot-moulded The moisture content shall be less than 1 per cent. The cargo shall comprise essentially whole briquettes and the addition of fines shall be prohibited. Fines shall comprise no more than 5 per cent by weight. Weather deck closures and hatch covers shall be inspected and tested to ensure integrity and weather tightness. Surface ventilation only shall be conducted as necessary and air shall not be directed into the body of the cargo.

When mechanical ventilation is used, the fans shall be certified as explosion-proof and shall prevent sparkgeneration. Wire mesh guards shall be fitted over inlet and outlet ventilation openings, and the escaping gasesshall be unable to enter living quarters.

During discharge, the application of a fine spray of fresh water is permitted only when the cargo is to be stored inan open area.

concerns relating to the carriage of DRIthey should contact their Club.

All Clubs in the International Grouphave issued a similar circular.

Any questions with regard to the abovemay be addressed to Nick Platt or

Adrian Hodgson in Gard (UK) Limited

(+44 20 7444 7200) or Geir Kjebekk inGard Arendal (+47 37 01 92 52).

Yours faithfullyGard AS

Claes IsacsonChief Executive Officer


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DRI (B), Lumps, pellets, cold-moulded briquettes The average particle size shall be from 6.35mm to 25mm, with fines no more than 5 per cent by weight. The shippers certificate shall state the date of manufacture for each lot of cargo. The certificate issued after loading shall confirm that the moisture content has not exceeded the permitted

value. The cargo shall be certified as having been aged for at least 3 days, or treated so as to achieve the same

reduction in activity.

The cargo shall be kept dry at all times. Any cargo that has been wetted, or known to have been wetted, shallnot be loaded.

Loading conveyors shall be dry. Prior to loading, an ultrasonic test or another equivalent method with a suitable instrument shall be conducted to

ensure weather tightness of the hatch covers and closing arrangements. The moisture content shall less than 0.3 per cent by weight and shall be monitored during loading. Any cargo that has already been loaded into a cargo space and which subsequently becomes wetted, or in which

reactions have started, shall be discharged without delay. The breakage of briquettes and lumps shall be minimised and the addition of fines shall be prohibited. Carriage is only permitted under an inert gas blanket. Prior to loading, provision shall be made to introduce a dry inert gas at tank top level. Nitrogen is preferred. All

vents and openings shall be sealed to prevent the loss of the inert atmosphere. On completion of loading of a cargo space it shall be immediately closed and sufficient inert gas introduced to

achieve an oxygen concentration of less than 5 per cent throughout the cargo space. The ship shall be provided with the means of reliably measuring the temperatures at several points within the

stow, and determining the concentrations of hydrogen and oxygen in the cargo space atmosphere on voyagewhilst minimizing the loss of the inert atmosphere.

The oxygen concentration shall be maintained at less than 5 per cent throughout duration of voyage. The shipshall be provided with the means to ensure that this requirement can be achieved throughout the voyage.Consideration shall be given to topping up with additional supplies of inert gas: the ships fixed CO

2fire-fighting

system shall not be used for this purpose. The ship shall not sail until the master and a competent person recognised by the national administration of the

port of loading are satisfied that:- All loaded cargo spaces are correctly sealed and inerted;- The cargo temperatures have stabilised at all measuring points and are less than 65oC; and-The concentration of hydrogen in the free space has stabilised and is less than 0.2 per cent by volume (i.e. 5 per

cent LEL). The cargo spaces shall remain tightly sealed and the inert condition maintained throughout the voyage. The ship shall be provided with a detector suitable for measuring oxygen in a flammable atmosphere.

Oxygen concentrations shall be measured at regular intervals during the voyage. During precipitation, all cargo discharge operations shall be suspended and holds containing cargo shall beclosed.

DRI (C), By products, Fines The average particle size shall be less than 6.35mm, and there shall be no particles greater than 12mm in size. The reactivity of this cargo is extremely difficult to assess due to the nature of the material that can be included

in the category. A worst-case scenario should therefore be assumed at all times. The cargo shall be kept within the permissible moisture content at all times. The carriage requirements are identical to those for DRI (B), including the 0.3 per cent limit on moisture, with the

following exceptions:- The shippers certificate does not need to state the date of manufacture of each lot of cargo;- The cargo shall be certified as having been aged for 30 days.- Any cargo that has already been loaded and which subsequently is exposed to additional fresh water or

seawater over its natural moisture content and becomes wetted, or in which reactions have started and its

temperature has exceeded 120o

C, shall be discharged without delay.


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The dangers of carryingDirect Reduced Iron (DRI)

Since the International Group of P&IClubs Circular on Direct Reduced Ironpublished in 1982, the dangers of DRIhave somewhat disappeared fromthe limelight. Gard P&I has recentlybeen involved in several cases, whichhave served as a stark reminder ofthe dangers involved in carrying thishazardous bulk cargo.

Types of DRIDRI is the raw material used in theproduction of steel in electric arcfurnaces, which form the majority of thesteel production facilities worldwide.DRI can be split into two distinct sub-groups; cold moulded pellets or hotmoulded briquettes. The IMO BulkCargo (BC) Code deal with these twotypes separately. Hot moulded DRIbriquettes are a more refined product,formed by the further processing ofcold moulded pellets. Both forms ofDRI are considered hazardous whencarried in bulk and specific carriagerequirements are listed in the BC Code.

DRI properties and dangersDRI in either form is similar to othersteel structures in its susceptibilityto rust (re-oxidise) in the presenceof oxygen. The rate of oxidisationis dependant, to a greater or lesserdegree, on the moisture content of theDRI and the atmosphere in which theDRI is carried. The oxidisation processgenerates heat, which in bulk cargoesof DRI can be significant. The process ofoxidation is accelerated in the presenceof moisture and is substantially

increased if the water containsdissolved chlorides, as is the case withseawater. The sponge-like structureof DRI also inhibits the dissipation ofheat and DRI in bulk can therefore heatrapidly in isolated pockets.

Hot iron when in contact with watercan cause a chemical reaction resultingin the production of hydrogen, whichis highly explosive in the correctquantities. The generation of hydrogenis the most dangerous property of DRIand has led to several fatal explosions.

In some manufacturing processes, theDRI undergoes one of two processescalled either passivation, wherebythe briquettes are coated withsodium silicate or ageing in which

the briquettes are allowed to form aniron oxide coating. These processesare intended to reduce or inhibitthe oxidation process during transit.This additional process is dealt withspecifically in the BC Code.

Carriage RequirementsCarriage requirements are set out in theIMO BC Code. Reference should alsobe made to the latest published adviceand carriage requirements approvedby the local Competent Authority andissued by the shipper. The BC Coderecommends that the shippers shouldprovide specific instructions for thecarriage of DRI, and these should eitherbe:1. That the cargo spaces be

maintained in an inert condition,with the atmosphere containingless than 5 per cent oxygen. Thehydrogen content of the cargospaces should be maintained atless than 1 per cent by volume, OR

2. That the DRI is manufactured ortreated with an oxidation inhibitingprocess to the satisfaction of theCompetent Authority.

If the atmosphere is inerted, theinerting agent must be nitrogen.Carbon dioxide should not be used,primarily because it can produce carbonmonoxide, which is both toxic andflammable. Even on short sea voyages itis recommended that the cargo be fullyinerted. Passivation has been shown toeffectively reduce oxidation, from freshwater contamination, in the short term,

but, over time, the effective protectionis reduced. It should be noted thatthere is little protection from therapid reactions caused by the ingressof salt water into the cargo spaces.It is therefore recommended thatthe carriage of DRI should always beundertaken under a nitrogen blanket.The ships crew should carry outeffective monitoring of the atmospherein the cargo spaces. Records shouldbe kept of the levels of hydrogen andoxygen in each cargo space.

The condition of the cargo shouldbe monitored during loading. Cargothat is hot or damp should not beloaded. It is also recommendedthat the temperature of the cargo

during loading should be monitored.If the cargo temperature is abovethe ambient temperature, adviceshould be obtained from the localCompetent Authority. However, cargowith a temperature in excess of 65oCshould never be loaded. It is usualfor temperature thermocouples to beplaced within the cargo holds duringloading for the monitoring of cargotemperatures during carriage. It is

important that these thermocouples aretested prior to being positioned withinthe cargo and their location within thecargo recorded.

It is also recommended that the cargoshould be properly trimmed in orderto reduce the amount of surface areaexposed to the atmosphere. Trimmingalso helps reduce the funnel effectby reducing the amount of void spacesin the cargo where hot gases can moveupwards while drawing in fresh air.

If the vessel has any doubts aboutany particular DRI loading it isrecommended that independentadvice be obtained from an expert. TheAssociation is only too happy to assistin this regard, and in any other way itcan.

For more information regarding Gardloss prevention products, pleasecontact Terje Paulsen, at phone number+47 55 17 40 85 or email [email protected].

Loss Prevention CircularNo. 07-03


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Liquefaction ofunprocessed mineral ores -

Iron ore fines and nickel oreBy Dr Martin Jonas, Brookes Bell, Liverpool.

(see Figure 1). This suddenly reducesthe friction between particles, and thusthe shear strength of the cargo.

The effect of this process is a transition

from a solid state to a viscous fluidstate in which all or part of the cargocan flatten out to form a fluid surface.In this condition, cargo may flow toone side of the ship with a roll one waybut not completely return with a rollthe other way, progressively leadingto a dangerous list and potentially thesudden capsizing of the vessel.

Cargo liquefaction will not occurif the cargo contains a sufficientlylow inherent moisture content andsufficiently high interstitial air that, evenin its most compacted state, there

are still sufficient interstitial spaces toaccommodate all of the moisture sothat the increase in water pressure isinhibited.

The lowest moisture content at whichliquefaction can occur is called the FlowMoisture Point (commonly abbreviatedFMP). Its numerical value can varywidely even for cargoes with the same

description. It is not possible to predictthe FMP of a given cargo from itsdescription, particle size distributionor chemical composition and the FMPtherefore needs to be determined bylaboratory testing separately for eachcargo provided by each shipper.

In cargoes loaded with a moisturecontent in excess of the FMP,liquefaction may occur unpredictablyat any time during the voyage. Somecargoes have liquefied and causedcatastrophic cargo shift almostimmediately on departure from the

load port, some only after severalweeks of apparently uneventful sailing.While the risk of liquefaction is greaterduring heavy weather, in high seas, andwhile under full power, there are no

Gard News 197,February/April 2010

Dr Martin Jonas considers some of thetechnical issues behind the casualtiesinvolving the carriage of unprocessednatural ores from India and nickel orefrom Indonesia, the Philippines andNew Caledonia.

IntroductionLiquefaction of mineral ores, resultingin cargo shift and loss of stability,has been a major cause of marinecasualties for many decades. Recentproblems, already leading to severaltotal losses this year, have primarilyinvolved the carriage of unprocessednatural ores such as iron ore fines fromIndia and nickel ore from Indonesia,the Philippines and New Caledonia.The main cause of casualties andnear misses is the poor complianceof shippers with the testing andcertification requirements that aredesigned to ensure that cargoes areloaded only if the moisture content is

sufficiently low to avoid liquefactionoccurring during the voyage.1

Principles of liquefactionCargoes that are at risk of liquefactionare those containing at least somefine particles and some moisture,although they need not be visiblywet in appearance. The most widely-known cargoes with this hazard aremineral concentrates, although manyother cargoes can also liquefy, such asfluorspar, certain grades of coal, pyrites,millscale, sinter/pellet feed, etc.

Although they often look dry inappearance at the time of loading,these cargoes contain moisture inbetween the particles. At the time ofloading, the cargoes are usually in theirsolid state, where the particles are indirect contact with each other and,therefore, there is physical strengthof resistance to shear strains. Duringocean transport, cargoes are exposedto agitation in the form of enginevibrations, ships motions and waveimpact, resulting in compaction of thecargo. This leads to a reduction ofthe spaces between the particles. If

compaction is such that there is morewater inside the cargo than there arespaces between the particles, thewater pressure inside the cargo can risesharply and press the particles apart

Figure 1: Liquefaction as a result of cargo compaction. In the solid state (left), the shearstrength of the cargo is provided by the direct contact between the cargo particles.There are sufficient interstitial spaces to accommodate the inherent moisture and aproportion of interstitial air. As the cargo compacts under the influence of the shipsmotions, the volume between the particles reduces and interstitial air is expelled.Eventually, the water pressure resulting from compaction presses the particles apart,potentially leading to them losing direct contact and a resulting sudden loss of shearstrength, i.e., a fluid state (right).

Iron ore fines before and after liquefaction.


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safe sailing conditions for a cargo withunsafe moisture content. Liquefactioncan occur unpredictably even inrelatively calm conditions on a vessel atanchorage or proceeding at low speed.

It is for these reasons that SOLASand the IMSBC Code incorporate

provisions intended to ensure that onlycargoes with sufficiently low inherentmoisture content to avoid liquefactionare loaded. Strict adherence to theseprovisions is the only safe way ofcarrying these types of cargoes.

SOLAS/IMSBC Code RegulationsSOLAS requires that the shippersof bulk cargoes provide the Masterin writing sufficiently in advance ofloading with information on any specialproperties of the cargo, includingthe likelihood of shifting, and forconcentrates or other cargoes which

may liquefy additional informationin the form of a certificate on themoisture content of the cargo andits Transportable Moisture Limit(commonly abbreviated to TML).2Cargoes which may liquefy shall onlybe accepted when the actual moisturecontent is less than the TML.3

Unlike the FMP, which can bedetermined in the laboratory, the TMLis a parameter that is calculated, ratherthan measured, as 0.9 times the FMP.Thus, for example, a cargo with an FMPof, say, 10 per cent (as determined in

the laboratory) has a correspondingTML of 9 per cent, this being 0.9 times10 per cent.

Thus, the maximum allowed moisturecontent of a cargo at the time ofloading (the TML) is lower than themoisture content at which liquefactionactually occurs (the FMP). Thisdifference between the TML and theFMP is intended to provide a safetymargin to protect against variationsin moisture or FMP throughout thecargo and to allow for measurementuncertainties in the laboratory

determination of moisture and FMP.It is essential that this safety marginis always preserved and thus cargoesshould never be accepted if themoisture content exceeds the TML,regardless of by how much.4

Full details on the underlying testingand sampling procedures for shipperscertification obligations under SOLASare given in the IMSBC Code 2009 (andpreviously in effectively identical formin its predecessor, the BC Code 2004)5.In brief, the IMSBC Code specifies thefollowing:

1) Identification of hazardPrior to start of loading, the shippermust declare to the Master in writing

whether or not the cargo offered forloading is a cargo that may liquefy.6This is a very important part of theshippers obligation to provideappropriate cargo information, as it isnot necessarily obvious from the cargoname or from a visual inspection of thecargo whether the cargo may liquefy,and thus whether the Master shouldinsist on a declaration of moisture andTML prior to allowing the cargo to be

loaded. In principle, any bulk cargothat contains at least some moistureand at least some fine particles is atrisk of liquefaction. The IMSBC Codespecifies that all such cargoes shouldbe submitted for laboratory testing toestablish whether or not they possessflow properties.7 If such testingshows that the cargo possesses a flowmoisture point, then shippers mustprovide a certificate of moisture andof TML prior to loading, regardless ofwhether or not the cargo is specificallylisted by name in the IMSBC Code as acargo that may liquefy.

2) Certification of moisture contentThe declaration of moisture contentmust contain a statement from shippersthat this is the average moisture contentof the cargo at the time the declarationis handed to the Master prior tostart of loading.8 One importantconsequence of this is that the entirecargo must already be available at theload port to be sampled prior to startof loading, rather than be deliveredpiecemeal throughout a protractedloading process. The moisture contentdetermination must be carried out on

truly representative test samples ofthe entire cargo.9 This is an elaborateprocess requiring full access to thecargo and careful planning to ensure

the moisture content of the test sampleis truly the average moisture content ofthe entire consignment.10

Sampling for moisture content musttake place not more than seven daysprior to loading. Additional checktests should be conducted if there issignificant rainfall between samplingand loading.11

Shippers must declare the moisturecontent separately for each cargohold of the vessel, unless samplinghas shown that the moisture contentis uniform throughout the entireconsignment.12 In concentrates, themoisture content is often sufficientlyuniform, but in unprocessed ores suchas iron ore fines and nickel ore, themoisture content can vary significantlythroughout the consignment andthus separate hold-by-hold moisturedeclaration is required. In actualshipping practice, few if any shippersdo declare a hold-wise moisture

content even in highly non-uniformcargoes, and this is a cause for concern.

If more than one distinct type of cargois loaded commingled in the samecargo hold, e.g., if loading is fromdifferent stockpiles from a differentsource of supply or with differentexposure to rain, then shippers mustprovide separate certificates for eachtype of cargo in each cargo hold.Similarly, shippers must carry outseparate sampling and certification foreach substantial portion of materialwhich appears to be different in

characteristics or moisture contentfrom the bulk of the consignment. Themoisture content must be below therespective TML separately for each

Flow table test.


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distinct parcel of cargo. Any portionsthat are shown to have a moisturecontent above the TML should berejected as unfit for shipment.13 Thus,if cargo is loaded from more thanone source, it is not sufficient for theaverage moisture content of all of thecargo in each hold to be below the

TML. One important consequenceof this is that it is not possible tocompensate for the loading of a batchof excessively wet cargo by thenloading additional drier cargo into thesame cargo hold.

3) Certification of TMLAs discussed above, the TML is derivedmathematically from a laboratorydetermination of the FMP. In principle,there are several different alternativetest methods to determine the FMP:three of them are described in fulldetail in Appendix 2 of the IMSBC

Code and the competent authorityof the exporting county may approveadditional test procedures.14 Inactual shipping practice, the only testmethod that is in widespread use isthe flow table method, as described inparagraphs 1.1.1 to 1.1.4 of Appendix2. While the test method is not difficult,it contains a subjective elementand needs to be carried out by anexperienced analyst who is familiar withthe early signs of liquefaction in a testsample. The critical part is the ability toreliably identify a flow state in the testsample using the criteria given in the

Code.15 It is a matter of some concernthat laboratories testing iron ore finesin India and nickel ore in Indonesiaand the Philippines depart in manyimportant respects from the IMSBCCode test procedure without approvalfrom the respective competentauthorities and without conductingsystematic inter-laboratory comparisonsto establish consistency of their resultswith laboratories using the unmodifiedIMSBC Code method.

For most processed ores, such asconcentrates, the TML depends

mainly on the technical details of theconcentration process and does notvary significantly between shipments.For these cargoes, it is sufficient ifshippers carry out a TML test onceevery six months. However, if thecomposition or characteristics of thecargo are variable between successiveshipments for any reason, then anew TML test is required each time.16Unprocessed ores such as iron orefines and nickel ore vary greatly incomposition not only from shipment toshipment but also within each individualshipment. Thus, for these cargoes,

shippers must carry out a new TML testfor every single cargo being loaded.

Close adherence to the above

requirements of the IMSBC Codeis essential in order to ensure thatonly cargoes that are safe for oceantransport are loaded. The IMSBC Codeplaces the burden of certification onshippers, not on the Master. Withoutaccurate information and certificationbeing provided by shippers, the Master

can not independently assess whetheror not the cargo offered for loadingis safe to carry. This is because it isimpossible to determine from a visualinspection or from ad hoc samplingof cargo being delivered to the vesselwhether or not the moisture contentof a cargo is below the TML. Cargoeswith moisture above the TML typicallylook much the same as cargoes withmoisture below the TML. Clearlydiscernible alarm signals, such asseparation of free water on the cargosurface or muddy appearance of thecargo, are only visible during loading

when cargoes have a grossly excessivemoisture content.

Unprocessed ores - Iron ore finesand nickel oreThere is a wide range of mineralcargoes that may liquefy, and theyvary in their appearance and physicalproperties. One sub-group ofcargoes has a particularly dangerouscombination of risk factors, andaccounts for a large proportion ofrecent casualties, near misses andcontentious load port disputes duringcarriage of cargoes that may liquefy.

The cargoes in question areunprocessed ores, the most widely-encountered of which are iron ore fines,mainly exported from India, and nickelore, mainly exported from Indonesia,the Philippines and New Caledonia.Unlike concentrates, these are simplydug out of the ground in open-castmines in mineral-rich, and often remote,locations and are presented for oceantransport with little or no processing.Thus, where concentrates have a highlyuniform particle size and physicalconsistency, unprocessed ores are very

heterogeneous, consisting of a mixtureof fine-grained ore, clay-like material,pebble-sized stones and the occasionallarger lump.

For shipowners contemplating carriageof these cargoes, and for Mastersinstructed to load them, a majordifficulty is that neither iron ore finesnor nickel ore have a specific listingin the IMSBC Code and thus it is notimmediately obvious from consultingthe Code that these are indeedcargoes that may liquefy. Unlesshe is already aware of the potential

hazards from other sources, the Masteris dependent on shippers correctlydeclaring the cargo as a liquefactionhazard. Although most shippers do

indeed acknowledge that the cargois a liquefaction hazard by supplyinga moisture and TML certificate, albeitfrequently flawed, some shippers donot, and without expert knowledgeit is difficult for the Master to knowthat he should insist on a declarationof moisture and TML before allowing

loading to commence.

Implementing a sampling andtesting regime that complies with theprovisions of SOLAS and the IMSBCCode, as summarised above, is atechnically much more demandingtask for unprocessed ores than it isfor concentrate cargoes. The IMSBCprocedures were designed withconcentrates in mind and thereforehave an implicit assumption of uniformparticle size and reasonably uniformmoisture distribution throughout theentire cargo. Neither of these applies

to unprocessed ores.

It is an unfortunate combinationthat although sampling and testingcargoes of unprocessed ores is atechnically more demanding task thanfor concentrate cargoes, the shippersof these cargoes are typically relativelysmall operators often lacking in theknowledge, expertise and technicalinfrastructure, and sometimes thewill, to comply with their SOLAS andIMSBC Code obligations. Because ofthe unprocessed nature of the cargo,shippers have only very limited control

over moisture content and someshippers may not actually be able tosupply cargoes that meet the SOLASrequirements.

Following are some of the technicalissues that need to be consideredby shippers when designing theircertification procedures.

The physical composition ofunprocessed ores varies significantlyeven within a single open cast pit,and even more so as most cargoesare mixtures of material dug out

from several, and sometimes verymany, individual pits, which may bedistributed over a wide geographicalarea. As a result, the TML may varygreatly from one part of the cargo toanother, but in an unsystematic andunpredictable manner, which doesnot allow to simply test each source ofmaterial separately.

The moisture distribution throughouteach cargo is typically highly non-uniform. The material is alreadyvariable in moisture at the time it isdug out of the ground. Most mining

locations are in tropical countries withfrequent heavy rainfall and the cargoesare typically transported in open lorries/wagons and stored in open stockpiles


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leading to unpredictable increases inmoisture.

The IMSBC Code specifically statesthat the ubiquitous test method forTML determination, the flow tablemethod, is unsuitable for materialscontaining particles above 7mm in

size.17

This creates a dilemma forlaboratories testing unprocessedcargoes, which frequently containpebble-like stones above that size.Nickel ore, in particular, often has avery high proportion of lumps above7mm. Iron ore fines are generallysomewhat finer, but some cargoesalso have a significant proportion oflumps above 7mm. The most frequentworkaround to avoid this problem isto screen out all particles above 7mmprior to analysis and to conduct theTML test only on the proportion that isbelow 7mm in size. When doing so, it is

essential that the particles above 7mmare removed from both the samplesubmitted for TML testing and thesamples used to certify the moisturecontent of the cargo. Failure to do sowill systematically overstate the safetyof the cargo and may therefore leadto cargoes being accepted for loadingthat are actually unsafe.

Because of the non-uniform natureof unprocessed ore cargoes, samplesfrom every single cargo need tobe submitted for laboratory TMLtesting. Shippers therefore need

to have a suitably equipped andqualified laboratory close at hand forTML testing to achieve acceptableturnaround times between samplingand certification. This differs fromshippers of concentrate cargoes,who only need to submit one sampleevery six months, and therefore donot find it onerous to courier samplesto reputable laboratories overseas.TML testing is a specialised task, andthere are few laboratories worldwidewho have a track record of obtainingreproducible results and participating ininter-laboratory comparisons over many

years. None of these are in the mainexporting countries of unprocessedores.

In India, shippers of iron ore fines usedto ignore their SOLAS obligations toprovide a TML certificate until quiterecently. Independent laboratoriesoffering TML testing have only startedto operate in the country after the2007 monsoons. Although there arenow many laboratories in India, all

of them were started quite recentlyand therefore there is little or noexperience data available to assesstheir reproducibility and consistencywith leading international laboratories.To date, there has been no centralisedaccreditation or inter-laboratory testingeffort to establish the soundness ofthe test procedures used by Indianlaboratories.

In Indonesia, the Philippines andNew Caledonia, mining locationsare typically very remote indeed,and loading takes place at natural

anchorages close to the mines,well away from any sophisticatedinfrastructure. The mines thereforegenerally operate their own flowtable for TML testing in their in-house laboratories rather than usingindependent laboratories. On closerscrutiny, many of these in-houselaboratories have been found tobe poorly equipped and to departsignificantly, and sometimes grossly,from the test procedures set out in theIMSBC Code.

Footnotes

1 See article Carriage of dangerouscargo - Questions to ask before yousay yes elsewhere in this issue of GardNews.2 SOLAS, Chapter VI, Regulation 2,Para. 2.2.3 SOLAS, Chapter VI, Regulation 6,Para. 2.4 The difference between moisturecontent and TML is a frequent sourceof confusion, leading to nonsensicalstatements such as The TML of thecargo increased because of rainfall.The TML of a cargo depends on thetype and composition of the cargo, but

is not affected by whether the cargo iswet or dry. The TML is similar to, say, aspeed limit on a road. The speed limitdoes not depend on how fast you drive,

but you break the law if you drive fasterthan the speed limit.5 The IMSBC Code may be appliedvoluntarily from 1st January 2009 andwill become mandatory under theprovisions of SOLAS from 1st January2011.6 IMSBC Code, Para. 4.2.2.2. The

IMSBC Code classifies cargoes that mayliquefy in cargo group A and requiresshipper to declare the cargo group.7 IMSBC Code, Appendix 3, Para. 2.1.8 IMSBC Code, Para. 4.3.2.9 IMSBC Code, Para. 4.4.1 to 4.4.4.10 IMSBC Code, Para. 4.4.4.Paras. 4.6.1 to 4.6.6 give a set ofrecommendations for concentratestockpiles that specify the minimumnumber of sub-samples to be takento make up the representativesample. For a cargo of (say) 40,000MT a minimum of 160 sub-samples isrequired. For cargoes that are more

inhomogeneous than concentrates,including iron ore fines and nickel ore,collecting a sufficiently large numberof sub-samples is even more importantthan for concentrates.11 IMSBC Code, Para. 4.5.2.12 IMSBC Code, Para. 4.3.3.13 IMSBC Code, Paras. 4.3.3 and 4.4.3.14 IMSBC Code, Paras. 4.1.4 and 8.3.Appendix 2 contains the actual testprocedures to determine the FMP andTML, including the flow table method inParas. 1.1.1 to 1.1.4.15 IMSBC Code, Appendix 2, Paras.1.1.4.2.3 and 1.1.4.3.

16 IMSBC Code, Para. 4.5.1.17 IMSBC Code, Appendix 2, Para.1.1.1.


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Intercargo publishesguide for the safe

loading of nickel oreThe International Association of DryCargo Shipowners (Intercargo) hasrecently published the Guide for theSafe Loading of Nickel Ore, whichaims to explain, through use of a flow-chart, how nickel ore can be safelyshipped, within limitations, whilst raisingawareness of the serious problem ofcargo liquefaction. It is targeted at thewidest possible audience within theindustry, including shippers, shipownersand masters.

In addition to a chart describing whatto look for when loading nickel ore, theguide recommends that:

Responsible shippers must notmisrepresent cargoes. In order toprovide accurate cargo declarationsshippers should have in placeprocedures for sampling, testingand controlling moisture contentof cargoes including procedures to

Gard Alert,February 2012

protect cargo on barges from anyprecipitation and water ingress.

Responsible shipowners must checkthat the cargo documentation isprovided as required in the IMSBCCode.

Before fixing, charteringdepartments should refer to theirown internal procedures regardingthe acceptance of nickel orecargoes.

Intercargo also points out that the so-called can test is insufficiently robustas a means of checking cargo safety onits own.

A copy of the guide can be foundhere: http://www.gard.no/webdocs/Intercargo_Nickel_Ore.pdf. We aregrateful to Intercargo for their kindpermission to reproduce the document.
http://www.gard.no/webdocs/Intercargo_Nickel_Ore.pdfhttp://www.gard.no/webdocs/Intercargo_Nickel_Ore.pdfhttp://www.gard.no/webdocs/Intercargo_Nickel_Ore.pdfhttp://www.gard.no/webdocs/Intercargo_Nickel_Ore.pdf


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Shifting solid bulkcargoes

Gard News 1501998

An explanation of the processes ofdangersSolid bulk cargoes can shift by slidingor liquefying, and whilst the factorsinvolved in each of these processesare different, the potentially disastrousconsequences are the same listing orcapsizing and/or structural damage.

Dense cargoes, e.g. ore concentrates,have by definition a relatively high mass

to volume ratio, so even a small amountof shifted cargo can have a largemass. Coupled with the momentumgenerated by a moving vesselconsiderable forces can act upon theships structure. This force will be evengreater when the cargo level within thehold is above the sea level outside thehold, so that the counter-acting forceof buoyancy is absent. Add to this thefrequent occurrence of multiple orrepetitive shifts and the result can beexcessive plate flexing increasing therisk of cracking and failure.

In terms of stability1, shifting cargo canhave numerous consequences. Theshift in cargo will cause a list if the cargodoes not return to its original positionwith subsequent vessel movement.Apart from increased draft concerns,the angle at which the vessel is listedwill, if uncorrected, become that aboutwhich the vessel rolls. This will usuallymean that the righting lever for anglesof heel towards the side the vesselis listed will be less than that whenthe vessel is heeled from her uprightposition, which in turn means that theforce returning the vessel from angles

of heel beyond the angle of list, backto the same angle, will be less thanthe force returning the vessel to theupright had she not been listed. Theangle of deck edge immersion willalso be closer than that for an uprightvessel and if this is reached stability willalso be reduced. A list will also tend tosubject the vessel to greater angles ofheel and this may give rise to a dominoeffect causing other cargo and objectsto break securings and/or to shift. Solidbulk cargoes that shift from one side ofthe vessel to the other with the rollingof the vessel, that is to say, cargoesbehaving like a liquid in a part-filledtank, will also give rise to a Free SurfaceEffect, and this again will reduce thevessels stability in a similar way to

that described above. The gravestconsequence of shifting is capsize ofthe vessel, and this can happen whenmultiple shifts occur with little returnof cargo to original positions. Thisprocess can be very quick and obviouslydisastrous.

Sliding occurs when the cohesivestrength, or stickiness of the cargo,is insufficient to withstand the effects

of rolling. Cohesive strength variesaccording to moisture content andthe height of the stockpile. A goodillustration of this is provided by sand.Wet or dry there is a limit on the heightof a pile of sand, but damp sand tendsto permit a higher sand pile. A commonexample of a cargo prone to sliding isgrain2, which is particularly free flowing.The International Maritime Organisation(IMO) Code of Safe Practice forSolid Bulk Cargoes 1991 states (atpara 5.2.4.2) that non-cohesive bulkcargoes having an angle of repose3less than or equal to 30 degrees flow

freely like grain and should be carriedaccording to the provisions applicableto the stowage of grain cargoes.The stowage and carriage of grain isgoverned by the IMO Grain Rules 1982which set out a number of requirementsincluding specific stability criteria.There is also some industry authority tosupport a theory that sliding can alsooccur when, due to downward moisturemigration, a saturated base layer(which need not be liquefied) is formedallowing the upper, relatively drier layer,to move against it.

Liquefaction of solid bulk cargoesdepends on particle size anddistribution as well as moisture content.The former determines whethermoisture can drain freely through thecargo, and will obviously change duringa vessels voyage due to vibration,rolling, pitching and twisting. Theeffect of this movement is to breakdown lumps of cargo and reduce thespace between particles effectivelycompacting the cargo. Moisture canthen become trapped between cargoparticles and if there is sufficientsaturation a flow state can develop.The point at which this occurs is calledthe Flow Moisture Point (FMP) and isusually expressed as a percentage ofthe moisture content. The IMO Bulk

Cargo Code referred to above adoptswhat is known as the TransportableMoisture Limit (TML), and this is themaximum moisture content of a cargodeemed safe for carriage by sea inships other than specially designedships. It is defined as 90 per cent ofthe FMP. Cargoes prone to liquefactionare those with a small particle size andthose which contain moisture as a resultof the way they are processed before

loading, e.g. iron ore concentrates andcoal slurry or duff4.

It is perhaps worth mentioning herethat solid bulk cargoes are increasinglybeing carried in Intermediate BulkContainers (IBC)5. The Associationsexperience with this type of carriagesuggests that the dangers of shiftingcargo can be just as real. Solid bulkcargoes which are prone to sliding havebeen known to force the sides of evenrigid IBCs to move and if there aregaps within the stow, or the sides of thestow are insufficiently shored, a general

collapse of the stow can occur.

A case example Liquefaction ofscale dustAn increasingly common solid bulkcargo is dust, commonly originatingfrom industrial chimneys. Industry hasfor some time been required to limitthe pollutants discharged into theenvironment and to this end chimneyscan be installed with filters. The materialcollected by these filters is generallytermed filter dust; material which buildsup on the inner chimney surfaces alsogives rise to another type of dust scale

dust. The contents of these substancesvary enormously and chemical hazardsare often associated with them. This isone of the reasons why many societiesin our greener world no longer allowthem to be left stored and forgottenon open slag heaps or in land-fill sites.The option to be considered in manyof todays societies is re-cycling and itis this which has, to some extent, led tothe water transport of dust.

The problems and dangers of wateryfilter dust were last mentioned in GardNews Edition 1046, and a recent caseinvolving scale dust suggests to usthat these problems and dangers arenot fully understood and that essentialprecautions are not being adhered to.


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The vessel in question loaded atAlgeciras, Spain, and the scale dustin bulk was to take up most of hercentre hold. The majority of the scaledust was noted by the master to bein open storage on land, unprotectedfrom the elements, and on closerexamination, was found to have a high

moisture content in parts. Whilst themaster was concerned as to the stateof the cargo, loading commenced, andsince this took place during periodsof rainfall, moisture levels increased.No documents were produced by theshippers to record the properties of thescale dust, and when the master didraise concerns with the various cargointerests, including their surveyors,he was told that the loading of thecargo during rain, and the wettingof the cargo, was normal and of noimportance with regard to the quality ofthe cargo.

The loading of the cargo seemed tobe completed without further eventor protest and clean bills of ladingwere issued. On the loaded passagethe vessel encountered moderatelyheavy weather, causing heavy rollingand pitching at times. Four days intothe passage a series of splashing andbanging noises were heard whichseemed to come from the holdcontaining the scale dust. Inspectionof this hold revealed that the scaledust had become fluid and wassplashing violently against the hold

sides. The inspection itself was notwithout danger as a 5 6 metre geysererupted from the booby hatch openedfor inspection. The resultant mess onthe ships superstructure was the leastof the worries facing the master asshortly afterwards the vessel took ona list. Fortunately the vessel was ableto compensate for this by careful andstrategic ballasting and was able toreach the discharge port without furtherserious incident.

Further inspection at the dischargeport revealed that the forces involved

with the shifting of the liquefied scaledust had resulted in the penetration ofthe cargo into an adjacent hold underand above a moveable transverse grainbulkhead. Problems ensued with theconsignees who held the vessel liablefor loss and damage to the cargo andthe extra costs of discharging andstoring the fluid cargo. The surveyorsappointed by the owners learnt thatthe surveyors appointed on behalf ofshippers, had issued a certificate ofthe moisture content at the loadingport and given this to the consignees,but not to the master. The certified

moisture content was said to be in theregion of 11 per cent but tests at thedischarge port determined a moisturecontent of nearly double this figure.

Lessons learned and precautionsto be takenIt is perhaps fair to say that theabove vessel was fortunate to havecompleted her voyage without moreserious incident. Having read the casesummary, the reader will probably beable to find a number of areas where

essential additional precautions couldhave been taken. Outlined below area number of points which should beconsidered when contemplating theloading of solid bulk cargoes suspectedof having a propensity to shift.(1) Carry out a visual examination ofthe cargo and enquire as to the extentand duration of exposure to moisture(unprotected stowage on wet ground orin wet weather).(2) Obtain and keep safe ships ownsamples (the quantity should besufficient for any necessary tests andbe properly labelled and recorded etc).

Do not just accept shippers samples,unless these are taken in your/yourrepresentatives presence.(3) Request in advance of the vesselsarrival, the shippers declarations withregard to FMP, stowage factor, TML,moisture content, angle of repose, anychemical hazards and details whichmay require safety precautions to betaken7. If such documentation is notforthcoming it should be demandedand a letter of protest to shippersand charterers should be issued. Themaster can and should refuse to loadthe cargo if the documentation is still

not forthcoming8. Remember that eachindividual cargo is unique. Details ofcargoes previously carried, even if fromthe same origin, should not be reliedon.(4) Check the details of the shippersdeclaration carefully. The details shouldbe accurate at the time the certificateis issued and the combination of apre-dated declaration and suspectedexposure to further moisture sincethe date of the certificate shouldraise concern. Some ports have raingauges to assist in the quantit

Documents

Dangerous Solid Cargoes in Bulk February 2012