It has been a while since I wrote here. Things have been madcap busy at Sheard Scientific. There’s just enough time now after digesting another turkey lunch for me to digest the contents of a new edition of the IMSBC Code, which landed on our doormat here at Sheard Scientific this month. I will start with this article by outlining what is in the Code and how it all works. Tomorrow, I will set out what has changed.
This tips the scales at a hefty 2.2kg. Quite a weighty document – the bulky code perhaps!
There is of course a reason for this. When the old BC Code morphed into the first version of the IMSBC Code and became mandatory under SOLAS, it contained schedules for individual bulk cargoes and a mechanism for missing or incorrect schedules to be identified and added. Those processes have been in place now for a number of years, and on each new edition, the Code gets bigger and bigger, and heavier.
The concept was that any cargo carried in bulk (other than grain cargoes, and many don’t properly understad why they are not covered) will have its own schedule. In that schedule will be a listing of the properties and hazards of the material and guidance regarding carriage.
The amendment timetable has been disturbed a little by Covid. The new edition is now available in print, and can be applied on a voluntary basis from 1st January 2023 and becomes fully mandatory on 1st December. This pattern – of publication followed by a period of voluntary applicability and then full force has been the case for previous amendments.
It is important to note that the concept of “voluntary” applicability is voluntary in the sense that the relevant Competent Authority/participating governmental body to IMO can decide that the new Code applies. It is not left to be a voluntary decision by individual shipowners, ship Masters, or indeed cargo shippers.
As the amendments to a document such as the IMSBC Code by definition represent best practice in the industry, it should in my view be in everyone’s interest for the amendments to be adopted as soon as practicable.
It is worth taking a quick look through the material making up the Code as published. Some things are in surprising places – this is to an extent a legacy of a shake-up of organisation as the material which used to be in various locations in the BC Code is mostly still to be found, just not necessarily where you might think it would be.
Sections 1-13 are where procedures, rules and regulations, and definitions are to be found. Material specifically relevant to liquefaction for instance can be found in sections 4, 7, 8, but you might also need to check section 5, which relates to trimming. There really is no substitute to reading through these sections carefully even if just to know what can be found where.
The next part of the Code is the appendices. Unlike most books, the appendices to the IMSBC Code are a fundametal part of the contents. Appendix 1 on its own is nearly 400 pages long, and contains the individual schedules for bulk cargoes, listed alphabetically by Bulk Cargo Shipping Name. These schedules are the part of the Code which a vessel’s Master will spend most time looking through, and this is the part of the Code which enlarges on each amendment as additional schedules are added.
Appendix 2 contains test methods applicable to bulk cargoes. This includes all six tests for Transportable Moisture Limit along with other tests.
Appendix 3 is headed “Properties of solid bulk cargoes” and is a curious mixture of seemingly unconnected but very important sections. One important point to bear in mind is that the contents of this appendix are not legally mandatory under SOLAS whereas some other parts of the Code are.
- Appendix 3 point 1 is a list of non-cohesive cargoes (as contrasted with other cargoes which are considered cohesive) and some provisions which flow out of this property.
- Appendix 3 point 2 is a single paragraph which describes the types of cargoes which might undergo liquefaction or dynamic separation. This paragraph is often quoted in disputes, so I will quote it here.
Many fine-particled cargoes, if possessing a sufficiently high moisture content, are liable to flow. Thus any damp or wet cargo containing a proportion of fine particles should be tested for flow characteristics prior to loading.
IMSBC Code Appendix 3 paragraph 2.1
- Appendix 3 point 3 is a provision which states that where a Competent Authority has to be consulted prior to shipment (i.e. substances not listed in the Code or substances with hazards which differ from that listed in the Code), the corresponding authorities at the loading and discharge port should be consulted. This is to ensure that all potentially involved in the carriage of a substance with chemical hazards are aware and agree with the precautions being taken.
Appendix 4 is the Index. However, it is much more than just an index. As stated above, the list of schedules in Appendix 1 is arranged alphabetically and so acts as its own index to an extent. In Appendix 4, the Index also includes entries which cross-reference to a BCSN. These can be found in lower case entries in the Index whereas entries in capital letters are the BCSNs themselves. As an illustration of how this works, the fourth entry in the Index is ALUMINA HYDRATE, a Group A&B cargo. The capital letters denote that ALUMINA HYDRATE has a schedule under that name in Appendix 1. Lower down on the same page can be found Aluminium hydroxide. As this is in lower case, it isn’t a BCSN and there is no schedule in Appendix 1 for Aluminium hydroxide. However, the entry says “see ALUMINA HYDRATE” and so the reader is thus informed that aluminium hydroxide and alumina hydrate are synonymous from the viewpoint of the entries in the Code. There are many other examples of this type of cross-referencing in the index.
Appendix 5 is similar to an Index but contains BCSNs from the Code in English, French and Spanish.
The rest of the book as published is the Supplement to the Code, and this amounts to a further 150 pages.
The documents making up the Supplement are all also published separately in their own right or as IMO circulars. They cover a wide range of topics, starting with the BLU Code (Code of Practice for the Safe Loading and Unloading of Bulk Cargoes) and ending with an alphabetic list by country of the designated Competent Authorities.
More or less in the middle of the Supplement can be found the document “Recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo holds” which is also published as IMO Circular 1264. This is a vitally important set of guidelines and recommendations which is essential reading for any becoming involved with shipboard fumigation, whether that is carried out in port or when continued in transit. I mentioned this circular earlier this year in the context of a serious incident involving fumigation.