London Club: No Exemptions from IMSBC code
London Club says owners must not accept exemptions from IMSBC code for DRI cargoes.
THE London P&I Club has urged shipowners to be alert to any attempt by shippers and other cargo interests to claim exemptions from the International Maritime Solid Bulk Cargoes (IMSBC) Code in connection with the carriage of DRI (Direct Reduced Iron) cargoes.
Long-standing concerns about the carriage of DRI - involving the possibility of a chemical reaction between the cargo and water, leading to the risk of fire and explosion - prompted the introduction of specific provisions for the carriage of DRI in the IMSBC Code. Under these provisions, DRI cargoes should have a maximum moisture content of 0.3 per cent and be carried under an inert gas blanket, and ships carrying DRI should be capable of maintaining oxygen levels of below 5 per cent throughout the voyage. Attempts to allow certain grades of DRI – principally those shipped from Venezuela and Trinidad – to be carried with significantly higher moisture contents and/or without the need to deploy inert gas, have been rejected by IMO.
The London Club says that, despite this, it is aware that attempts have been made by a Trinidadian company to ship HBI Fines (now known as DRI C) without complying with the mandatory requirements of the IMSBC Code. The Trinidadian shipper apparently relied on a provision in Section 1.5 of the code, which contemplates the possibility of alternative carriage arrangements by stipulating, “Where this code requires that a particular provision for the transport of solid bulk cargoes shall be complied with, a competent authority or competent authorities (port state of departure, port state of arrival or flag state) may authorise any other provision by exemption if satisfied that such provision is at least as effective and safe as that required by this code.”
The Trinidadian shipper offered an exemption certificate from the competent authority in Trinidad for the carriage of DRI C with a moisture content above 0.3 per cent and suggested that the cargo could be carried safely if the holds were mechanically ventilated to prevent the build-up of hydrogen. But Ian Barr, a Claims Director with A Bilbrough & Co, the London Club’s management team, says the club doubts whether mechanical ventilation can ever be regarded as being ‘at least as effective and safe’ as the use of an inert gas blanket.
Writing in the latest issue of the club’s StopLoss Bulletin, Barr says, “As most bulk carriers likely to carry DRI will have only ‘natural’ ventilation, hold fans would have to be fitted at the load port. The club has seen documents suggesting that, on at least one occasion, the fans proposed were not certified ‘explosion-proof’, meaning that they had not been specifically designed for use in flammable atmospheres and could be a possible source of ignition. Also, the fans appeared to be too small and were badly sited, limiting their ability to prevent the accumulation inside the hatch coaming of any hydrogen given off by the cargo.”
The club has advised its members that any suggestion that an exemption from the requirements of the IMSBC Code will be invoked should be reported to it immediately.