New risks in Amendments to IMSBC

International Maritime Solid Bulk Cargoes Code

The International Maritime Solid Bulk Cargoes Code (IMSBC)  is updated every two years. This is the way to reflect the changes in the nature and variety of solid bulk cargoes dedicated for shipment. As new cargo properties and dangers are discovered an amplification of SOLAS Chapter VI, Part B Special Provisions for Solid Bulk Cargoes comes into force.

Recent amendments (06-21) to the IMSBC Code, adopted by the IMO Maritime Safety Committee in res. MSC.500(105), will become mandatory from 1 December 2023 but may be applied by Administrations, voluntarily, from 1 January 2023. The present update, which includes important new controls for Ammonium Nitrate Fertilizer cargoes that may ignite and explode, is crucial for ship, crew, and safety, thus it impacts operations involved with bulk carriers.

Principal changes

Principal changes are involved with:

  • revisions to existing cargo schedules and deletion of the existing schedules for Ammonium Nitrate Based Fertilizer (non-hazardous) and Superphosphate (triple, granular),
  • the definition of Group A ‘cargoes which may liquefy’ has been extended to include ‘dynamic separation’ which is defined as follows:

“Dynamic separation means the phenomenon of forming a liquid slurry (water and fine solids) above the solid material, resulting in a free surface effect which may significantly affect the ship’s stability”.
“Cargoes (including bauxite and coal) which may undergo dynamic separation means cargoes which contain a certain proportion of fine particles and a certain amount of moisture and may undergo dynamics separation if shipped at a moisture content in excess of their Transportable Moisture Limit (TML)”.

Both Ammonium Nitrate Based Fertilizer and Superphosphate fertilizers are not classified as being hazardous in packaged/bagged form, which is why, they are not listed in the IMDG Code. They are now classified as Materials Hazardous in Bulk (MHBs) and are subject to a new special IMSBC testing regime.


Impact on IMSBC Certificates

In respect of the fact that deleted  SUPERPHOSPHATE (triple, granular), as group C, cannot be automatically accepted as the new SUPERPHOSPHATE (triple, granular), as group B, shipowners/operators should request their RO, e.g. PRS, for review and update of theirs IMSBC certificates. Additional changes to the requirements of twenty cargoes may not affect the carriage of solid bulk cargoes already permitted for ships in service.

Impact on certificates other than the IMSBC

It should also be noted that changes to the IMSB Code also have an impact on SOLAS Exemption Certificates for fixed gas fire extinguishing systems. If the below-mentioned cargoes:
AMMONIUM NITRATE-BASED FERTILIZER MHB
SUPERPHOSPHATE (triple, granular)
LEACH RESIDUE CONTAINING LEAD
are carried or intended to be carried, the exemption certificate will need to be replaced according to new solid bulk cargoes categorized as group B in Table 1 of Annex to MSC.1/Circ.1395/Rev.5. Mentioned MSC.1/Circ.1395/Rev.5 supersedes MSC.1/Circ.1395/Rev.4.

Actions to be taken

  1. Shipowners/operators should be aware of the deadline - 31st of December 2023 (but not later than the first periodic Safety Equipment Survey). They may request from their RO to re-issue IMSBC certificates in light of the deletion/addition of the listed cargo.
  2. Re-issuance of SOLAS Exemption Certificates for Fixed Fire-Extinguishing Systems should be made accordingly.
  3. Amendments may also be required if a ship carries a Group B cargo, and its carriage is entitled by the vessel’s ISM Code Document of Compliance (DOC).

As it is said, significant risks remain, and new risks are being continuously discovered, thus only revalidation of existing ship procedures and staff training will lead to improvement of crew safety, carriage by ship cargo, and environmental protection.