The IMO Sub-Committee on Carriage of Cargoes and Containers held its 4th Session (CCC 4) from 11 – 15 September 2017.  Mr Xie Hui (CHINA) took the Chair together with his Vice Chair, Mr Patrick van Lancker (BELGIUM), the latter’s last meeting prior to his impending retirement.  Mr Hui was subsequently re-elected and Mrs Gudula Schwan (GERMANY) promoted as Vice-Chair. Three Working Groups (WG) were formed and chaired as follows:


  • WG1 Amendments to the IGF Code and Development of Guidelines for Low-flashpoint Fuels,  Mr G Szemler (SWEDEN)
  • WG2 IMSBC Code Matters, Dr S Ota (JAPAN)
  • WG3 Suitability of Materials for Cryogenic Service, Dr G An (REPUBLIC OF KOREA)


The meeting was attended by representatives from 75 Member States, 1 Associate Member of IMO, 2 Inter Governmental Organisations and 32 Non-Governmental Organisations.


Items of particular interest to InterManager members are as follows:


ADDRESS BY SECRETARY-GENERAL.  Mr Lim opened his address by offering condolences to all countries affected by recent natural catastrophes.  He drew a link between the theme of last year’s and this year’s World Maritime Day arguing that ‘Connecting Ships, Ports and People’ naturally follows on from that of 2016’s ‘Shipping: indispensable to the world’.  The Secretary-General highlighted some key issues to be discussed at the meeting, most notably amendments to the IMDG (International Maritime Dangerous Goods) Code for the current two-year revision cycle, evaluation and carriage of Bauxite, schedules for Seed Cake and updating the IMSBC (International Maritime Solid Bulk Cargoes) Code against the backdrop of potential instability of Bauxite cargoes.  He also referred to work related to the IGF Code (International Code of Safety for Ships using Gases or other Low-flashpoint Fuels), encouraging that of developing the requirements for fuel cells as well as technical provisions for the safe use of methanol and ethanol as fuel on ships.  These might provide important alternative technologies enabling the industry to meet its sulphur oxides (SOx) nitrogen oxides (Nox) and carbon reduction targets.


AMENDMENTS TO THE IGF CODE AND DEVELOPMENT OF GUIDELINES FOR LOW-FLASHPOINT FUELS.  The Sub-Committee considered the report of the Correspondence Group on Development of Technical Provisions for the Safety of Ships using Low-flashpoint fuels with regard to development of draft amendments to the IGF Code regarding fuel cells and the development of draft technical provisions for the safety of ships using methyl/ethyl alcohol as fuel.  Having approved the report in general, extensive discussion took place in Plenary on the detail contained therein, which included:  fuel storage and its terminology;  equipment boundaries;  safety concept for fuel cells;  a draft new part E of the IGF Code relating to fuel cells;  draft technical provisions for the safety of ships using methyl/ethyl alcohol as fuel (encompassing definitions), fuel standards, and safety concept for methyl/ethyl alcohol in machinery spaces; standards for methyl/ethyl fuel couplings; operational issues;  toxicity of methyl alcohol;  check/monitoring sheets;  protection of gas pipes and pipes for cryogenic liquefied gas;  separation of fuel preparation rooms and type C tanks from high fire risk rooms;  explosion relief valves;  loading limit;  and, low-flashpoint oil.


Having considered these matters, suitable terms of reference were drawn up for WG1 which subsequently submitted a detailed report to the Sub-Committee.  The report was approved in general, and in particular, the Sub-Committee:


  1. Endorsed draft amendments to Part A and A-1 of the IGF Code for approval by MSC 99;
  2. Endorsed WG1’s recommendation to correct pertinent numbering errors under paragraph 6 and 7 of the IGF Code;
  3. Noted progress made on development of draft amendments to the IGF Code regarding fuel cells;
  4. Noted the check/monitoring sheets and the record format for draft amendments to the IGF Code regarding fuel cells;
  5. Noted that owing to time constraints, WG1 was unable to draft Technical Provisions for the Safety of Ships using methyl/ethyl alcohol as fuel but which task will be finalised by the re-established Correspondence Group;
  6. Endorsed draft unified interpretations (UI) of provisions 6.8.2 and 11.3.3 of the IGF Code for inclusion as part of a draft MSC circular on UIs of the IGF Code prepared at this session;
  7. Noted WG1’s view that technical issues with regard to provision 11.3.2 of the IGF Code should be addressed by means of amendments to the Code;  and
  8. Approved re-establishment of the CG on Development of Technical Provisions for the Safety of Ships using low-flashpoint fuels (as already mentioned in para 5 above).


It should be noted that during final Plenary discussions of terms of reference on re-establishing the CG, interventions by a number of Member States resulted in agreement that consideration of methyl/ethyl fuel should be treated with the same priority as that accorded to fuel cells.


SUITABILITY OF HIGH MANGANESE AUSTENITIC STEEL FOR CRYOGENIC SERVICE AND DEVELOPMENT OF ANY NECESSARY AMENDMENTS TO THE IGC CODE AND IGF CODE.  Following Plenary consideration of the report submitted by a Correspondence Group to develop test acceptance criteria for high manganese austenitic steel for cryogenic service and documents submitted largely by the Republic of Korea and commented on by Japan, WG3 was instructed to convene.  On completion of WG3’s deliberations, the Sub-Committee examined its report, approved it in general, and in particular:


  1. Endorsed the Group’s decision that consideration of the suitability of high manganese austenitic steel for cryogenic service should be limited to steel plates;
  2. Endorsed the comprehensive list of technical points for assessing its suitability for same;
  3. Endorsed the information required to address the technical discussion points for assessing suitability and draft test acceptance criteria;
  4. Endorsed draft interim guidelines for application in preference to making amendments to the IGC and IGF Codes
  5. Endorsed justification for expansion of the existing output for consideration by CCC 5; and
  6. Endorsed re-establishment of the Correspondence Group on Suitability of High Manganese Austenitic Steel for Cryogenic Service with terms of reference as stipulated.


AMENDMENTS TO THE IMSBC CODE AND SUPPLEMENTS.  Following a lengthy debate in Plenary, WG2 was formed to consider IMSBC Code amendments in depth which included topics such as:  draft new individual schedules for Direct Reduced Iron;  ammonium nitrate based fertiliser (non-hazardous);  definition of materials hazardous only in bulk (MHB);  Seed Cake cargo classification;  draft individual schedules for MHB and Group C cargoes;  evaluation of Bauxite properties;  hazards and criteria for Group A and Group C cargoes;  new phenomenon-dynamic separation;  draft new test procedure for determining the TML for Bauxite cargoes;  draft individual schedules for Group A and Group C cargoes;  proposals for amendment to the IMSBC Code;  self-heating coal research project;  test methods to determine corrosivity for solid bulk cargoes;  IMSBC Code guidance to administrations commencing a Tripartite Agreement;  and, proposed new individual schedules for metal sulphide concentrates, self-heating, UN 3190 also Brucite, all of which will be considered at E&T 29.


The Sub-Committee approved WG2’s comprehensive report in general and in particular:


  1. Endorsed the draft test procedure for determining the TML for Bauxite, with a view to inclusion in the draft amendment (05-19) to the IMSBC Code;
  2. Instructed E&T 29 to make necessary editorial modifications to the characteristics table of the draft new individual schedule for Bauxite of Group A;
  3. Endorsed the draft individual schedule for Bauxite of Group A, with a view to inclusion in the draft amendments (05-19) to the IMSBC Code and similarly for Group C;
  4. Agreed in principle to the draft consequential amendments to appendix 2 of the Code regarding Bauxite cargoes;
  5. Approved a draft CCC.1 circular on Carriage of Bauxite which may liquefy;
  6. Approved a draft CCC.1 circular on Carriage of Ammonium Nitrate-based fertiliser (non-hazardous);
  7. Noted possible confusion in the loading section of the draft individual schedules for MHB and Group C Seed Cake cargoes caused by inappropriate application of the words ‘exclusion’ and ‘exemption’;
  8. Took note of the need for the IMSBC Code to provide necessary guidance on the test method for assessment of the cohesive properties of solid bulk cargoes;
  9. Agreed, in principle, to the draft individual schedule for MHB Seed Cake cargoes and inclusion in the draft amendments (05-19) to the IMSBC Code and similarly for Group C Seed Cake cargoes;
  10. Agreed that the draft amendments to section 9 of the IMSBC Code should not be further developed/finalised at present; and
  11. Agreed, in principle, to the draft amendments to individual schedules for Seed Cake UN 1386(b) and Seed Cake UN 2217.


Finally, on this agenda item, in response to a question from the BAHAMAS delegation as to whether it is time for an IMO Model Course on Bauxite loading, the Chairman stated that the Secretariat are currently working on the subject.  It will be referred to HTW and the Sub-Committee will be kept informed of progress.  A Secretariat paper for the next session is envisaged following which a panel of experts will be formed.


AMENDMENTS TO THE IMDG CODE AND SUPPLEMENTS.  The Sub-Committee agreed, in principle, to the draft editorial corrections to amendments 38-16 to the IMDG Code, as prepared by E&T 27 (Editorial and Technical Group).  Following discussion in Plenary, the following issues will be forwarded to E&T 28 for their consideration:


  1. Provisions for batteries installed in cargo transport units;
  2. Sea transport of battery-vehicles for compressed gases;
  3. Various documents relating to Fish meal;
  4. A proposed amendment to SP 963 in order to clarify the exemption provided for nickel-metal hydride cells or batteries packed with, or contained, in equipment;
  5. Amendment to the description of segregation code SG1 in order to clarify its intention and meaning;
  6. Segregation provisions for uranium hexafluoride;
  7. Review the structure and content of the provisions on fumigated cargo-transport units; and
  8. Segregation groups in the Dangerous Goods list.


The Sub-Committee authorised E&T 28 to finalise the draft amendments (39-18) to the IMDG Code based on the forwarded documents with a view to submission at MSC 99 for adoption.


INSPECTION PROGRAMME FOR CARGO TRANSPORT UNITS CARRYING DANGEROUS GOODS.  The Sub-Committee was informed that, among the 73,400 CTUs inspected, 8,324 (11.34%) were found to have deficiencies.  Of these, placarding and marking accounted for 42.9%, securing/stowage inside the unit 26.2%, and marking/labelling of packages 18.8%.  Member States were encouraged to continue submitting the results of container inspection programmes and towards this end, the Secretariat updated the Sub-Committee on the demonstrated feasibility of developing a GISIS functionality enabling the filling out of an electronic version of the form to report results of inspection programmes.


PREVENTING THE USE OF COUNTERFEIT REFRIGERANTS.  The Air Conditioning, Heating and Refrigeration Institute (AHRI) determined that a level not exceeding 300 PPM of R-40 contamination in refrigerant gas supplies is acceptable and this figure has been included in AHRI Standard 700-2016.  The usage of the halide torch test or other tests with similar sensitivity, as previously recommended by the Informal Industry Correspondence Group, will ensure levels of R-40 in conformance with the AHRI findings and will be re-named as Industry best practice for preventing the use of counterfeit refrigerants.


MEASURES TO PREVENT THE LOSS OF CONTAINERS.  ISO reported on the progress of the revision of ISO standards 1161 and 3874 following a request by DSC 18 to revise ISO 3874 in regard to the equipment used on board ships to secure containers whilst also taking into account the report of the Lashing@ sea project.  The updated ISO 3874 will include design and strength characteristics for automatic twistlocks whilst ISO 1161 (Series 1 freight containers – corner fittings – specifications) revised and published on 11 July 2016, may be re-visited, subject to a new work item proposal being communicated to the ISO Secretariat.  The final issue of ISO 3874 (Series 1 freight containers – handling and securing) will hopefully be published this autumn.  The revised standard takes into account the increase of the maximum gross weight of the containers global fleet and incorporates a new chapter on automatic twistlocks.


ESTIMATE OF CONTAINERS LOST AT SEA.  Surveys conducted by WSC give an estimate of the number of containers lost at sea on an annual basis as follows:


  1. For the combined nine-year period from 2008 to 2016, on average, 568 containers were lost at sea each year, not counting catastrophic events and 1,582 when including them;
  2. On average, 64% of containers lost during this period were attributed to a catastrophic event;
  3. Based on the 2017 survey results for the years 2014, 2015 and 2016, on average there were approximately 612 containers lost/year not counting catastrophic events which is about 16% less than the 733 units lost for the preceding three-year period;  and
  4. When catastrophic losses are included, an average total loss per year of 1,390 containers was estimated for the years 2014, 2015 and 2016 (i.e. a 48% reduction from the annual total losses of 2,683 estimated in 2014.


DATE OF NEXT MEETING.  The next meeting, CCC 5, has been provisionally scheduled for 10 – 14 September 2018.


Captain Paddy McKnight                                                                                                        End







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