The IMO SUB-Committee on Carriage of Cargoes and Containers (formerly DSC) held its 1st Session (CCC 1) from Monday 8 through Friday 12 September 2014. Mr Xie Hui (CHINA) was unanimously elected Chairman for the meeting as also was his Vice-Chairman, Mr Patrick Van Lancker (BELGIUM); both were subsequently re-elected for the second meeting of CCC in 2015. Delegations from Member Governments, United Nations and specialised agencies, observers from international organisations and non-governmental organisations in consultative status also attended.
During the course of the meeting, 3 Working Groups (WG) and 1 Drafting Group(DG) were formed and chaired as follows :
WG1 Development of International Code of safety for ships using gases or other low- flashpoint fuels (IGF Code), Mrs J Stemre (NORWAY)
WG2 Harmful to the Marine Environment (HME) substances within the IMSBC Code in relation to the Revised MARPOL Annex V, Dr S Ota (JAPAN)
WG3 Container Safety, Mr K Bradley (UK)
DG1 Revision of DSC/Circ 12, Mr S Webb (USA)
Salient points of particular interest to InterManager members are as follows:
- CONTAINER SAFETY. Issues identifying the further development of an ACEP (Approved Continuous Programmes) database were compiled as a list of Q & As for further clarification by BIC (International Container Bureau). Further, in respect of WG3, the Sub-Committee:
- Established a correspondence group to consider the best way forward in development of the ACEP database;
- Endorsed a recommendation to refer approved Informative material related to the CTU (Cargo Transport Units) Code to MSC 94 as an urgent matter;
- Directed that such Informative Material related to the CTU Code be made available on the public IMO website; that it be forwarded to UNECE for display on its website and to ILO for information; and
- Approved terms of reference for a correspondence group to consider roles of participants within the supply chain and further develop aids such as due diligence / supplier checklist to promote a necessary culture change.
- REVISED GUIDELINES FOR PACKING OF CARGO TRANSPORT UNITS. The Sub-Committee recalled that MSC 94 had approved the IMO / ILO / UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code), noting that the UNECE Inland Transport Committee endorsed the Code without change, whilst ILO approval is expected in November 2014. Further, MSC 93 decided to reinstate the existing output on ‘Revised guidelines for packing of cargo transport units’ to further improve the supplementary material in support of the CTU Code.
- SUPPLEMENTARY MATERIAL TO THE CTU CODE. In consideration of documents submitted by the Secretariat, SWEDEN and the UK, the Sub-Committee agreed that the IMO Model Course 3.18 (Safe Packing of CTUs) should be updated, in coordination with ILO and UNECE, inviting MSC 94 to endorse this recommendation.
- DEVELOPMENT OF INTERNATIONAL CODE OF SAFETY FOR SHIPS USING GASES OR OHER LOW-FLASHPOINT FUELS (IGF CODE). Following an extensive discussion in Plenary, WG1 was instructed to finalise the IGF Code and draft SOLAS amendments to make the Code Mandatory, taking into account MSC .1/ Circ. 1483 (on a trial basis) plus development of a work plan for the next phase of development. With regard to application of the IGF Code, the Sub-Committee agreed that SOLAS chapter II-1 (part G) and the IGF Code should not apply to cargo ships of less than 500 gross tonnage, whilst noting that the provisions of the Code could be applied to such ships on a voluntary basis in line with national legislation. It was also agreed that the IGF Code should not apply to gas carriers covered by chapter 16 of the IGC Code that do not use any other gas or low-flashpoint fuel, apart from vapour or boil-off from their cargo. In consideration of WG1’s subsequent report, the Sub-Committee:
- Endorsed a request for the Secretariat to develop text for ships built prior to the general application dates for inclusion in the draft SOLAS amendment;
- Agreed use of the supplement to the IAPP Certificate under MARPOL Annex VI for providing additional information on ships using low-flashpoint fuels and entrusted the Secretariat to advise MEPC 68 on the need to consider further actions, if any, regarding MARPOL certification;
- Agreed draft amendments to SOLAS for MSC 94 approval making the IGF Code mandatory;
- Will submit the draft IGF Code to MSC 94 for approval in principle and subsequent adoption at MSC 95, together with draft amendments to SOLAS;
- Forwarded document MSC 93/21/3 to MSC 94 on the interpretation by FRANCE for obtaining the required distance at the turn of the bilge for passenger ships as it is directly related to tank location;
- Endorsed a proposed work plan for the next phase of IGF Code development such as the need to consider additional fuels for inclusion in the Code;
- Agreed terms of reference in re-establishing the IGF Correspondence Group; and
- Noted the trial check / monitoring sheet and records produced in accordance with the Interim Guidance (MSC .1/Circ. 1483) for submission to MSC 94 together with draft amendments to SOLAS and draft IGF Code.
- REPORT OF THE EDITORIAL AND TECHNICAL GROUP (E&T). The Sub-Committee considered the report of E&T 21, which meeting took place from 28 April – 1 May 2014. It:
- Noted the on-going debate in seeking to establish a notational listing system for identifying MHB cargoes;
- Noted the group opinion that, in order to assess and assign an MHB category to future proposed schedules, amendment of MSC .1/Circ. 1453 should be conducted at E&T 22.
- Noted action taken by the group in relation to the inclusion of a new schedule for IRON ORE FINES and amendment to the existing schedule of IRON ORE;
- In regard to cargoes that may liquefy, agreed to draft amendments of Section 7 of the Code and the individual schedule for CLINKER ASH;
- Agreed a consequential amendment to para1.3 of MSC .1/Circ. 1454 on Guidelines for developing and approving procedures for sampling, testing and controlling the moisture content for solid bulk cargoes which may liquefy;
- Agreed that the definition for group A cargo could be improved to encompass accidental wetting of a cargo and circumstances where the cargo could liquefy if wet;
- Agreed to a consequential amendment (MSC .1/Circ. 1395/Rev. 1) on Lists of solid bulk cargoes for which a fixed gas fire-extinguishing system may be exempted or for which such a system is ineffective;
- Agreed draft amendments to section 13 of The Code which take cognisance of technical requirements and standards in the IMSBC Code; and
- Having noted the discussions regarding fire safety in conveyor belt spaces on self-unloading bulk carriers, agreed a draft amendment to Section 3 on ‘Safety of personnel and ship’.
- REPORT OF THE CORRESPONDENCE GROUP ON HME (HARMFUL TO THE MARINE ENVIRONMENT) SUBSTANCES. The Sub-Committee considered the CG report on HME substances as follows:
- Instructed the WG to prepare new non-mandatory requirements for cargo information on HME substances as a part of draft amendments to the Code, clarifying their recommendatory nature;
- Having considered draft indicative lists of solid bulk cargoes with regard to HME (i.e. a draft MEPC circular showing candidate cargoes in a black indicative list liable to be classified as HME, together with a white indicative list of non-HME cargoes), it was decided after lengthy discussion not to prepare any indicative lists at this stage but to seek the advice of MEPC 68;
- Information on provisions for solid bulk cargoes which may liquefy was provided as follows:
(1) New Caledonian Nickel Ones – FRANCE
(2) Manganese Ore Fines – BRAZIL
(3) Australian Coal Industry Liquefaction Research Project – AUSTRALIA
(4) Iron Ores – BRAZIL
- PROPOSALS FOR INDIVIDUAL SCHEDULES IN THE IMSBC CODE. Following introduction of relevant submissions to Plenary and subsequent discussion, proposals for individual schedules in the IMSBC Code were referred to E&T 22 for further consideration, namely:
- Oily vegetables and their processing by-products;
- Oily vegetables and their processing by-products (non-hazardous);
- Amorphous sodium silicate lumps;
- Spodumene (Upgraded) Group A;
- Iron oxide technical;
- Zircon kyanite concentrate;
- Iron silicate slag;
- Metal sulphide concentrates UN 1759; and
- Pig iron by-products.
- REPORT OF THE WORKING GROUP ON HME SUBSTANCES. As instructed, the WG prepared, and justified, non-mandatory cargo information requirements and draft amendments to the IMSBC Code related to HME substances, including a new section 14 of the Code.
The Sub-Committee endorsed a recommendation that the long-term implementation of the provisions of MARPOL Annex V concerning cargo residues can be facilitated and that it would be beneficial to develop a mandatory requirement for cargo declaration in the appropriate IMO instruments by:
- Giving mandatory status to HME criteria;
- Developing guidance for the application of GHS for classification of solid bulk cargoes as to whether or not they are harmful to the marine environment; and
- Giving mandatory status to shippers’ declarations of solid bulk cargoes as to whether they are HME or otherwise.
- STOWAGE OF POLYMERIZING SUBSTANCES. GERMANY submitted a full casualty investigation report conducted by the German Federal Bureau for Maritime Casualty Investigation (BSU) on the fire and explosion on board the container vessel MSC FLAMINIA on 14 July 2012. The report contained conclusions and recommendations regarding classification and stowage of substances within the IMDG Code that may polymerise, crew training for firefighting and abandoning ship, availability and on board location of first aid equipment as well as accessibility to water for firefighting in addition to Co2. Based on this report, GERMANY proposed amendments to the IMDG Code concerning the stowage of polymerising substances, such as assigning ‘Stowage Category C or D’ to such substances, other than gases, within the dangerous goods list, including potential UN numbers which would be affected by this proposed amendment. However, following discussion, the matter will now be considered by E&T 23.
- CONSIDERATION OF REPORTS OF INCIDENTS INVOLVING DANGEROUS GOODS OR MARINE POLLUTANTS IN PACKAGED FORM ON BOARD SHIPS OR IN PORT AREAS. The Sub-Committee was informed that, among 65,929 CTUs inspected, 8,751 were found with deficiencies equating to 13.27%. Total deficiencies were 10,734; of which by type, placarding and marking accounted for 41% whilst securing / stowage inside the unit came to 25%. Not surprisingly, concern was expressed about the high rate of deficiencies and on the lack of adherence to the provisions of the IMDG Code. Member States were therefore invited to continue submitting deficiency reports and those which had not yet carried out container inspection programmes were encouraged to do so.
- URGENT MATTERS TO BE CONSIDERED BY MSC 94. Due to the close proximity between CCC 1 and MSC 94 (17 – 21 November 2014), the Committee will consider only the following urgent matters emanating from this session:
- The draft IGF Code and associated SOLAS amendments;
- Draft Informative Material to the CTU Code; and
- Draft revisions of MSC .1/ Circ. 1352 on amendments to the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) and MSC .1/Circ. 1353 on Revised Guidelines for the preparation of the Cargo Securing Manual.
- MEASURES TO PREVENT LOSS OF CONTAINERS. The World Shipping Council (WSC) presented the findings of its member line surveys conducted in 2011 and 2014 which estimated that there were 546 containers lost at sea each year, not counting catastrophic events, and with such events included, these amounted to losses of 1,679 per year. FRANCE and SPAIN proposed measures additional to those already implemented in order to curtail avoidable losses but the Sub-Committee ruled that these went beyond the original scope of the output on Measures to prevent the loss of containers as agreed at MSC 89. Member States were therefore invited to submit proposals for a new unplanned output in accordance with the Committee’s Guidelines.
Captain Paddy McKnight