The IMO Sub-Committee on Carriage of Cargoes and Containers held its 6th Session (CCC 6) from 9 – 13 September 2019.  Mrs Maryanne Adams (MARSHALL ISLANDS) took the Chair together with her Vice Chair, Mr David Anderson (AUSTRALIA), both for the first time, and following commendable performances during CCC 6, the duo were re-elected for 2020.

Three Working Groups (WG) and two Drafting Groups (DG) were formed and chaired as follows:


WG1  Amendments to the IGF Code and Development of Guidelines for Low-flashpoint Fuels,

Mr C Allgeier (GERMANY)


WG2  Suitability of High Manganese Austenitic Steel for Cryogenic Service,



WG3  Amendments to the CSS Code with regard to Weather-dependent Lashing,

Mr G Szemier (SWEDEN)


DG1  IMSBC Code Matters,

Dr S Ota (JAPAN)


DG2  Inspection Programme Amendments for Cargo Transport Units carrying Dangerous Goods,

Mr I Lancaster (NEW ZEALAND)


The meeting was attended by representatives from 78 Member States, 1 Associate Member, 1 United Nations Agency, 1 Inter Governmental Organisation and 35 Non-Governmental Organisations.


Items of particular interest to InterManager members are as follows:


ADDRESS BY SECRETARY GENERAL.  The Secretary General gave his customary welcoming address to all present which he opened by expressing sincerest sympathy to the delegation of Indonesia regarding the loss of 25 crew manning the bulk carrier Nur Allya carrying a cargo of nickel ore in the Banda Sea, off Indonesia on 20 August.  He also mentioned with great sadness the deadly fire on a commercial diving vessel, Conception, near the Southern Californian coast of the United States coast resulting in 34 casualties and total loss of the vessel whilst Golden Ray, listing off the coast of Georgia, United States, reported four crew members missing and was subject to a USCG rescue operation in which all four were subsequently extricated alive through an opening created in the upturned hull.  His final condolences were expressed to the Bahamas delegation for the lives lost, currently 43, and damage caused by Hurricane Dorian.


Mr Lim next outlined the arrangements for World Maritime Day celebrations at IMO on Thursday 26 September, this year’s theme being “Empowering women in the maritime community”, whilst the annual parallel event will take place from 15 to 17 September in Cartagena, Colombia.


Going on to the most important items in the agenda of CCC 6, he viewed these as being:


  • The development of technical provisions on alternative low-flashpoint fuels under the IGF code, encompassing proposals for four different kinds of low-flashpoint fuels;


  • Development [and finalisation] of draft interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel, also those for ships using fuel cell power installations;



  • Validation of a new Model Course on Safe Handling and Transport of Solid Bulk Cargoes;
  • Bearing in mind plant health and pest control associated with the movements of CTUs and their cargoes, a revision of inspection programmes for cargo transport units carrying dangerous goods; and,


  • Finalisation of amendments to the Code of Safe Practice for Cargo Stowage and Securing (CSS Code).


Closing his address, the Secretary-General extended his best wishes to all for every success in their deliberations during the week ahead.



AMENDMENTS TO THE IGF CODE AND DEVELOPMENT OF GUIDELINES FOR LOW-FLASHPOINT FUELS.  An extensive debate took place in Plenary on the subject of Low flashpoint diesel informed by a Formal Safety Assessment paper to accommodate its use as amendments to the IGF Code New part A-2).  However, this did not find favour as it did not fully address the fundamentals of fire safety and the working group subsequently inclined towards interim guidelines rather than a formal amendment to the IGF Code.  The report of the Correspondence Group established by CCC 5 related to the development of the interim guidelines regarding fuel cells, draft amendments to the IGF Code, and the provisions on low-flashpoint oil fuels was given thorough consideration by the Sub-Committee, following which WG 1 was established, having been given specific terms of reference on which to focus.  In consideration of the WG’s subsequent report, the Sub-Committee approved it in general, and in particular:


  • Agreed to the draft interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel, and the associated draft MSC circular, with a view to approval by MSC 102;
  • Noted the progress made in the development of the Interim guidelines for the safety of ships using fuel cell power installations;
  • Approved, in principle, draft amendments to regulations 9.4.8, 6.1, 11.3.1, 11.6.2, and of the IGF Code, noting the work outstanding on the scope of application;
  • Agreed to the development of amendments to the IGF Code to include safety provisions for ships using low-flashpoint fuels and to their development by the CG for entry into force by 1 January 2024;
  • Agreed to the development of interim guidelines on safety provisions for ships using LPG fuels, to be further developed by the CG;
  • Endorsed the new work plan prepared by the Group for the next phase of the development of the IGF Code;
  • Agreed the Group’s request to allocate more meeting time in order to achieve the target completion dates in the new work plan;
  • Endorsed the change of status of the existing output on Amendments to the IGF Code and development of guidelines for low flashpoint fuels to be “continuous”;
  • Noted the discussion on the draft unified interpretations (UIs) of paragraphs 9.2.2 and 9.3.1 of the IGF Code, tasking the CG to discuss further; and,
  • Re-established the CG on Development of Technical Provisions for the Safety of Ships using Low-flashpoint Fuels.



AMENDMENTS TO THE IGC AND IGF CODES TO INCLUDE HIGH MANGANESE AUSTENITIC STEEL AND RELATED GUIDANCE FOR APPROVING ALTERNATIVE METALLIC MATERIAL FOR CRYOGENIC SERVICE.  CCC 5 re-established the CG on Suitability of High Manganese Austenitic Steel for Cryogenic Service and instructed it to develop guidance on the procedure for examining and approving alternatives.  In considering the CGs report on the development of the draft guidelines for alternative metallic materials for ships carrying liquefied gases in bulk, also ships using gases or other low-flashpoint fuels, and the provision of draft amendments to the IGC and IGF Codes, a Working Group was established and tasked to conduct further evaluation of the subject.  Following due deliberation by the Group (WG 2), the Sub-Committee approved its report in general, and in particular:


  • Agreed to the draft Guidelines for the acceptance of alternative metallic materials for cryogenic service in ships carrying liquefied gases in bulk and ships using gases or other low-flashpoint fuels, and the associated draft MSC circular for approval by MSC 102;
  • Agreed to the consequential revision of the Interim guidelines on the application of high manganese austenitic steel for cryogenic service (MSC.1/Circ.1599) for approval by MSC 102 subject to the submission of a satisfactory fatigue test result;
  • Noted WG 2’s discussion on expanding the application scope of the MSC Circular, also the Groups consideration on draft amendments to the IGC and IGF Codes; and,
  • Approved a recommendation to re-establish the CG in order to further progress the work.



AMENDMENTS TO THE IMSBC CODE AND SUPPLEMENTS.  Discussion in Plenary on this subject included the report of E&T 30; a proposed amendment to the definition of “group A”; amendment 05-19 to the IMSBC Code; reclassification of ammonium nitrate based fertiliser (non-hazardous); a draft new model course on safe handling and transport of solid bulk cargoes; proposed amendments 06-21 of the IMSBC Code seeking to introduce a substance identification number for bulk cargoes; analysis of bulk carrier-related accidents 2009-2018; a progress update on the Australian Industry Self-Heating Research project; harmonisation of IMSBC and IMDG Codes for FISHMEAL; proposed new individual schedules for Lead concentrate, leach product, also Brown fused alumina; and, consideration of the draft IP Code. Of particular importance to InterManager, document CCC/5/6 proposed the adoption of a number of specific hazard identification, risk assessment and control procedures aimed at reducing the continuing loss of life and serious accidents involving solid bulk cargoes, particularly the IMSBC Code group B cargoes.  The document takes into account relevant recommendations in ‘Revised recommendations for entering enclosed spaces aboard ships (resolution A.1050(27)’ and ‘Recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo holds’.  With regard to enclosed spaces, MSC 101 (MSC 101/24, para 21.17) agreed to include in the 2020-2021 biennial agenda of the CCC Sub-Committee and its provisional agenda for CCC 7, an output on “Revision of the Revised recommendations for entering enclosed spaces aboard ships(resolution A.1050(27))”.  The proposals to amend A.1050(27) may require an expansion to the newly agreed output.


Following robust Plenary discussion, DG 1 was established and its subsequent report approved in general. In particular, the Sub-Committee:


  • Endorsed the decisions taken by the Group to validate the draft IMO model course on safe handling and transport of solid bulk cargoes; and,
  • Noted the editorial modifications and the draft individual schedules for ammonium nitrate-based fertiliser prepared by the Group for technical discussion by E&T 33



AMENDMENTS TO THE IMDG CODE AND SUPPLEMENTS. This item covered a rambling selection encompassing a wide range of subjects as follows:


  • Draft editorial corrections to the English and French versions of amendment 39-18 to the IMDG Code which was forwarded to E&T 32 for consideration;
  • Draft amendment 40-20 to the IMDG Code including segregation requirements for strong acids, alcoholates and liquid organic substances;
  • Classification and transport of carbon, subsequently referred to E&T 32;
  • Non-declaration and mis-declaration of dangerous goods – special provisions in the IMDG Code, following which a CG has been established to Review the Maritime Special Provisions (SPs) under the coordination of Germany, starting from 900 onwards in chapter 3.3 of the IMDG Code, reporting to CCC 7;
  • Transport of naturally occurring radioactive material (NORM) for which IAEA advice will be sought;
  • Classification of UN portable tanks (multimodal transport) and ADR/RID tanks (inland transport) which will be referred to E&T 32 for further consideration;
  • New provisions for data loggers and tracking devices were discussed following which the Sub-Committee agreed to refer draft new provisions to E&T 32 for further consideration and inclusion in the IMDG Code, inviting ISO to provide more information to CCC 7;
  • Clarification of paragraph of the IMDG Code regarding the draft interpretation of IACS of “public access” on life-saving appliances, duly referred to the Secretariat for a draft UI based on document CCC 6/6/18;
  • Amendments to the Medical First Aid Guide (MFAG) which will be submitted to MSC 102 for approval, subject to the concurrent approval of WHO and ILO;
  • In considering the draft IP Code for ships carrying industrial personnel, carriage of dangerous goods in packaged form, in particular the thresholds of number of persons in relation to the requirements of the IMDG Code, were explored. Proposed text in paragraphs 7 and 8 of document CCC 6/2/3 by IACS was subsequently agreed; and,
  • Authorisation was given to E&T 32 to finalise the draft amendments (40-20) to the IMDG Code with a view to submitting the draft amendments to MSC 102 for consideration and adoption and to submit a written report to CCC 7.



AMENDMENTS TO THE CSS CODE WITH REGARD TO WEATHER-DEPENDENT LASHING.  The Sub-Committee had for its consideration the CG report on Weather-dependent Lashing.  It endorsed the view that annex 13 should be expanded to cover heavy cargo items and with regard to semi-standardised cargoes, agreed that the scope should be expanded to cover such vehicles on ro-ro ships.  Subsequently, WG 3 was established with regard to Weather-dependent Lashing and instructed accordingly.  The report of the Group was approved by the Sub-Committee in general, and in particular, it:


  • Noted the Group’s discussion regarding containers on non-container ships, which are not defined and regulated in the CSS Code or in rules established by the recognised organisations;
  • Agreed the draft amendments to annex 13 of the CSS Code and the associated MSC circular;
  • Agreed draft consequential amendments to MSC.1/Circ.1353/Rev.1 on the Revised guidelines for the preparation of the Cargo Securing Manual for submission to MSC 102;
  • Agreed draft consequential amendments to resolution A.581(14) on Guidelines for securing arrangements for the transport of road vehicles on ro-ro ships for submission to MSC 102 for approval and subsequent adoption by the Assembly; and,
  • Agreed draft consequential amendments to the Code of Safe Practice for Ships Carrying Timber Deck Cargoes, for submission to MSC 102 for approval.



UNIFIED INTERPRETATION OF PROVISIONS OF  IMO SAFETY, SECURITY AND ENVIRONMENT-RELATED CONVENTIONS.  Extensive discussions took place on a number of Unified Interpretations (IUs) to provisions of IMO safety, security and environment-related Conventions.  These comprised:


  • Tee welds in type A or type B independent tanks and welds of type C independent bi-lobe tank with centreline bulkhead;
  • UIs on the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code);
  • Follow up to discussions at CCC 5 regarding UIs in relation to the IGC Code;
  • UI of Part A-1, para 9.2.2 of the IGF Code;
  • Draft UI of para 9.3.1 of Part A-1 of the IGF Code;
  • Draft updated version of the UI on paras and of Part A-1 of the IGF Code;
  • Ventilation of cofferdam spaces between cargo tanks in membrane gas carriers; and,
  • Application of the opening or access between the machinery space of category A and a Gas Valve Unit room located in the machinery space of a gas carrier.



CONSIDERATION OF REPORTS OF INCIDENTS INVOLVING DANGEROUS GOODS OR MARINE POLLUTANTS IN PACKAGED FORM ON BOARD SHIPS OR IN PORT AREAS. The Sub-Committee thanked Member States for their submissions on results of container inspection programmes, recalling also that the Secretariat has developed a GISIS functionality permitting submission of such reports online through the GISIS platform.  The Sub-Committee was informed that, of the 72,408 CTUs inspected, 5653 CTUs were found to have deficiencies, which means that 16.44% of the CTUs inspected were deficient, a significant increase from 8.38% for the previous year.  Placarding and marking accounted for 57.12%, followed by securing/stowage inside the unit (16%) and marking/documentation (15.12%).



REVISION OF THE INSPECTION PROGRAMMES FOR CARGO TRANSPORT UNITS CARRYING DANGEROUS GOODS.  It was recalled that MSC 100 agreed to include an output on “Revision of the inspection programmes for cargo transport units carrying dangerous goods”.  FAO also affirmed that CTU cleanliness was an integral part of the Code of Practice for Packing of Cargo Transport Units (CTU Code) and that FAO and the Secretariat of the International Plant Protection Convention (IPPC) had proposed to include CTU cleanliness among the selection criteria for the container inspection programmes to be developed.  Following Plenary discussion, it was agreed, in principle, to amend the inspection programme, in order to;


  • Further clarify that the selection criteria should be applied equally to CTUs carrying all types of cargoes, rather than being specifically on those declared to be carrying dangerous goods;
  • Adequately refer to the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU Code); and,
  • Cover the reports from non-governmental organisations.


Following a proposal by FAO that cleanliness be included in the items to check in CTU inspection programmes as it would assist in determining the number of instances of pest contamination,  concern was expressed by the Industry on a proposal by Member Governments of IPPC to promulgate a mandatory IPPC standard stipulating that all empty and packed export containers be certified clean by third parties as a condition for vessel loading.  However, following much discussion, it was decided to hold a decision in abeyance.  Instead, the Drafting Group (DG 2) was instructed to prepare terms of reference for a CG, with a view to further consider the related proposals and advise CCC 7 on the best way forward.


DG 2 was then established and instructed accordingly.  On completion of its work, the Group reported back to Plenary, gaining approval in general, and in particular, the Sub-Committee:


  • Noted the progress made by the Group with regard to the draft amendments to MSC.1/Circ.1442 and that the draft amendments need further work before their finalisation;
  • Encouraged Member States to undertake CTU inspections and report their findings to the Organisation;
  • Endorsed the proposal to allow third party inspection data to be submitted to the Organisation when collected to the satisfaction of the Member State; and,
  • Agreed the proposed terms of reference for the correspondence group prepared by WG 2.



ANY OTHER BUSINESS.  There were a number of minor items discussed as follows;


  • The Sub-Committee considered document CCC 6/13/1 (ICHA, WNTI and NI) providing a list of categories where either there is none, or insufficient, training, currently available through IMO and IAEA, to support the development of an IMO model course in training materials for the safe and efficient transport of IMDG Code Class 7 radioactive materials by sea. The Secretariat undertook to compose a suitable response reflecting the discussion;
  • MSC 100 instructed the Sub-Committee to consider whether model courses on Safe packing of CTUs and that on Dangerous, hazardous and harmful cargoes, require revision. It was concluded that minor updates are necessary; and,
  • The Sub-Committee expressed appreciation to BIC for its continued commitment to maintaining and running the Global ACEP Database, and urged CSC 1974 Contracting Parties to make their ACEP information publicly available, communicating to the Secretariat the location where the ACEP information had been posted.



DATE OF NEXT MEETING.  The next meeting, CCC 7, is currently scheduled to take place from 14 through 18 September 2020.



END                                                                                                              Captain Paddy McKnight
















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