Section 4.2 Shipper’s Declaration and Cargo Information

The safe carriage of solid bulk cargoes begins long before the first grab-load is lowered into the hold. It starts with the provision of accurate, comprehensive, and timely information about the cargo from the entity that knows it best: the shipper. The IMSBC Code, under the umbrella of SOLAS Chapter VI (Carriage of Cargoes), Regulation 2 (Cargo Information), unequivocally places the responsibility on the shipper to furnish the Master or his representative with all pertinent details concerning the cargo. This information, typically provided in a formal “Cargo Information Form” or “Shipper’s Declaration,” is the foundational document upon which the Master will base critical decisions regarding the suitability of the vessel, stowage planning, handling precautions, and emergency preparedness. Accepting this document passively is not an option; for the Master, diligent scrutiny and verification are paramount.

1. The Shipper’s Obligation – A Cornerstone of Safety:

The IMSBC Code (Section 4.2) is explicit: “The shipper shall provide the master or his representative with appropriate information on the cargo sufficiently in advance of loading to enable the precautions which may be necessary for proper stowage and safe carriage of the cargo to be put into effect.” This is not a mere recommendation but a mandatory requirement. The shipper, having direct knowledge of the cargo’s origin, composition, and properties, is in the best position to declare these accurately. This obligation is fundamental to the entire safety chain.

2. Essential Information Required in the Shipper’s Declaration:

The IMSBC Code (Section 4.2.2) specifies the minimum information that must be included in the cargo declaration. While the exact format may vary slightly, the content must cover the following:

  1. The Proper Bulk Cargo Shipping Name (BCSN): As listed in Appendix 1 of the IMSBC Code. If the cargo is not listed, its composition and properties must be provided.
  2. The IMSBC Code Group (A, B, A and B, or C): This critical classification dictates the primary hazards and precautions.
  3. IMO Class and UN Number (if the cargo is classified as dangerous goods): For Group B cargoes that also fall under the IMDG Code.
  4. Total Quantity of the Cargo Offered: Usually in metric tonnes.
  5. Stowage Factor: The volume occupied by one tonne of the cargo (e.g., in m³/tonne).
  6. The Need for Trimming and, if Necessary, the Trimming Procedures: As per Section 5 of the IMSBC Code.
  7. Likelihood of Shifting: Including the angle of repose if less than 35°, or other relevant information for cargoes prone to shifting.
  8. Chemical Properties (especially for Group B cargoes or if not readily apparent from the BCSN): This should include information on:
    1. Whether the cargo is liable to emit flammable or toxic gases.
    2. Whether it is liable to self-heat or spontaneously combust.
    3. Whether it is liable to deplete oxygen.
    4. Its corrosivity.
    5. Its reactivity with water or other substances.
  9. For Group A Cargoes (Cargoes which may liquefy):
    1. Certificate of Transportable Moisture Limit (TML): Stating the TML.
    2. Certificate of Moisture Content (MC): Stating the actual moisture content of the cargo as loaded or to be loaded.
    3. The TML and MC certificates must be issued by an entity recognized by the competent authority of the port of loading as being capable of performing the required tests.
  10. Other Certificates of Test (as required by individual schedules): For example, weathering certificates for certain types of coal, or certificates indicating the results of tests for self-sustaining decomposition for certain fertilizers.
  11. Harmful to the Marine Environment (HME) Status: Whether the cargo is designated as HME under MARPOL Annex V. This impacts garbage management and disposal of cargo residues.
  12. Emergency Procedures: Information on actions to be taken in an emergency involving the cargo, often referencing the relevant EmS (Emergency Schedules) numbers if the cargo is also dangerous goods.
  13. Contact Information: Name, address, telephone, and email of the shipper or their representative who can provide additional information if needed.
  14. A Declaration: A statement signed by the shipper (or their authorized representative) confirming that the information provided is correct and complete to the best of their knowledge.

3. The Form and Timing of Information:

  1. Form: While the IMSBC Code specifies the content, it doesn’t mandate a universal form. Many shippers use a standardized “Cargo Information Form” or “Shipper’s Declaration for Solid Bulk Cargoes.” Regardless of the format, all legally required information must be present.
  2. “Sufficiently in Advance”: This phrase is crucial. The Master must receive this information early enough to:
    1. Review it thoroughly.
    2. Consult the IMSBC Code and other relevant publications.
    3. Assess the suitability of the ship for the cargo.
    4. Plan the stowage.
    5. Identify any necessary special precautions or equipment.
    6. Raise any queries or concerns with the shipper or company before loading commences. Receiving the declaration just as loading is about to start is unacceptable and puts undue pressure on the Master.

4. Certificates of Test – The Objective Evidence:

For many cargoes, particularly Group A and certain Group B types, the shipper’s declaration must be accompanied by certificates of test issued by a competent authority or a laboratory recognized by them. These certificates provide objective, scientific data about critical cargo properties.

  1. For Group A (Liquefiable Cargoes):
    1. TML Certificate: This document states the Transportable Moisture Limit, which is the maximum gross water content (by weight) that a cargo is considered safe to carry on a ship not specially designed or fitted for such cargoes. The TML is determined by one of the test methods prescribed in Appendix 2 of the IMSBC Code (e.g., Flow Table Test, Penetration Test, Proctor/Fagerberg Test). The certificate must specify the test method used.
    2. Moisture Content (MC) Certificate: This states the actual average moisture content of the cargo consignment at the time of testing, just prior to loading.
    3. Critical Comparison: The Master must compare the certified MC with the certified TML. If MC ≥ TML, the cargo must NOT be loaded unless the vessel is a “specially constructed or fitted cargo ship” as defined in Section 7 of the IMSBC Code, and all conditions therein are met.
    4. Sampling and Testing Interval: The IMSBC Code emphasizes that the samples for these tests should be representative of the consignment and that testing should be conducted as near as practicable to the time of loading. The Code provides guidance that, for some cargoes, the interval between testing and loading should not exceed 7 days. If significant rain or snow occurs after testing, re-testing may be necessary.
  2. For Group B (Chemically Hazardous Cargoes):
    1. Depending on the specific cargo schedule, certificates may be required for properties like:
      1. Liability to self-heat (e.g., for coal, DRI).
      2. Methane or other flammable gas emission rates (e.g., for coal).
      3. Results of tests for self-sustaining decomposition (e.g., for certain fertilizers).
      4. Material Safety Data Sheet (MSDS) or Safety Data Sheet (SDS) can also provide valuable hazard information, though the IMSBC Code declaration is the primary regulatory document for carriage.

5. The Master’s Scrutiny – A Non-Delegable Responsibility:

The Master’s role in reviewing the shipper’s declaration and accompanying certificates is active, not passive. It involves critical assessment and due diligence.

  1. Check for Completeness: Is all the information required by Section 4.2.2 of the IMSBC Code provided?
  2. Verify BCSN and Group: Does the Bulk Cargo Shipping Name match a name in the Code? Is the declared Group (A, B, C) consistent with the cargo and its properties described?
  3. Examine Test Certificates:
    1. Are they from a recognized competent authority/laboratory?
    2. Are they dated reasonably close to the loading period?
    3. For Group A, is the MC clearly stated as being less than the TML?
    4. Is the test method for TML specified and one of the approved methods?
  4. Cross-Reference with IMSBC Code Schedules: Compare the information provided by the shipper with the specific requirements and precautions outlined in the individual cargo schedule for that BCSN in the IMSBC Code. Are there any discrepancies?
  5. Assess Stowage and Trimming Information: Is the advice provided for trimming adequate and in line with Code requirements (e.g., for cargoes prone to shifting)?
  6. Evaluate Declared Hazards: Do the declared hazards align with the Code’s description for that cargo? Are the emergency procedures provided adequate?
  7. Question Ambiguities: If any information is unclear, ambiguous, contradictory, or seems implausible, the Master must seek clarification from the shipper. This should be done formally and documented.
  8. The Right and Duty to Refuse Cargo: SOLAS and the IMSBC Code empower the Master to refuse to load cargo if they are not satisfied that it can be carried safely. If the shipper fails to provide adequate information, if test certificates are missing or invalid, or if the cargo’s condition (e.g., moisture content exceeding TML) makes it unsafe for carriage on that particular vessel, the Master has a duty to refuse loading until the issues are resolved. This decision, while potentially having commercial implications, is paramount for safety.

6. Consequences of Inadequate or False Information:

As highlighted previously, if the shipper provides inaccurate, misleading, or incomplete information, the consequences can be dire:

  1. Incorrect risk assessment by the ship’s crew.
  2. Inappropriate stowage or handling procedures being adopted.
  3. Failure to take necessary safety precautions (e.g., ventilation, gas monitoring).
  4. Increased likelihood of cargo-related incidents (liquefaction, fire, structural damage, health hazards to crew).

7. Practical Advice for Masters:

  1. Develop a Checklist: Use a checklist based on IMSBC Code Section 4.2.2 to ensure all required items on the shipper’s declaration are reviewed.
  2. Insist on Early Provision: Work with charterers and agents to ensure cargo information is provided well in advance of the vessel’s arrival at the load port.
  3. Document Everything: Keep copies of all declarations, certificates, and any correspondence with shippers regarding cargo information. Note any concerns or actions taken in the ship’s log or a dedicated cargo log.
  4. Independent Verification (If in Doubt): In cases of serious doubt about the cargo’s properties, especially for Group A cargoes, the Master may have grounds (and support from P&I Clubs) to request independent sampling and testing before loading.
  5. Utilize Company Support: If unsure about any aspect of the cargo information or its implications, consult the company’s designated person ashore (DPA) or technical department.
  6. Stay Updated: Ensure the latest edition of the IMSBC Code and any amendments are onboard and used.

The shipper’s declaration is the first line of defense in ensuring the safe carriage of solid bulk cargoes. The Master’s diligent and informed scrutiny of this document is a professional obligation that directly safeguards the vessel, its crew, and the environment. It is a testament to the principle that an informed Master is a prepared Master.

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