Section 8.8: Dangerous Goods in Solid Bulk Form (DG Code vs. IMSBC Code)

The maritime transport of dangerous goods is primarily governed by the International Maritime Dangerous Goods (IMDG) Code, which mainly addresses packaged dangerous goods and some solids in bulk. However, many solid bulk cargoes inherently possess hazardous properties that are specifically addressed by the International Maritime Solid Bulk Cargoes (IMSBC) Code. This section clarifies the relationship between these two vital codes, focusing on how dangerous goods, when intended for carriage in solid bulk form, are managed, and the Master’s responsibilities in ensuring compliance with all applicable regulations. Understanding this interface is crucial, as some cargoes listed in the IMSBC Code are also classified as dangerous goods under the IMDG Code, requiring adherence to provisions from both.

1. The International Maritime Dangerous Goods (IMDG) Code:

Primary Scope: The IMDG Code is the comprehensive international standard for the sea transport of dangerous goods in packaged form. It also includes provisions for some dangerous goods in bulk (solid and liquid), but its main focus is on packaged goods.

Classification: It classifies dangerous goods into 9 main classes based on their primary hazard (e.g., Class 1: Explosives, Class 4.1: Flammable solids, Class 4.2: Substances liable to spontaneous combustion, Class 4.3: Substances which, in contact with water, emit flammable gases, Class 5.1: Oxidizing substances, Class 6.1: Toxic substances, Class 8: Corrosive substances, Class 9: Miscellaneous dangerous substances and articles).

Key Information Provided: For each listed substance (identified by a UN Number and Proper Shipping Name – PSN), the IMDG Code provides detailed information on:

Classification and labelling.

Packing requirements.

Stowage and segregation requirements (from other dangerous goods and from foodstuffs).

Emergency response procedures (EmS – Emergency Schedules, MFAG – Medical First Aid Guide).

Documentation (Dangerous Goods Declaration).

Mandatory Status: The IMDG Code is mandatory under SOLAS Chapter VII (Carriage of Dangerous Goods).

2. The International Maritime Solid Bulk Cargoes (IMSBC) Code:

Primary Scope: The IMSBC Code specifically addresses the safe stowage and shipment of solid cargoes (including those possessing chemical hazards) when carried in bulk.

Classification (Groups): As discussed, it categorizes cargoes into Group A (liquefaction risk), Group B (chemical hazards – MHB: Materials Hazardous only in Bulk), and Group C (neither A nor B).

Key Information Provided: For each listed cargo (identified by a Bulk Cargo Shipping Name – BCSN), the IMSBC Code provides:

Description, characteristics, hazards.

Stowage, segregation, handling, ventilation, and emergency procedures specific to its carriage in bulk.

Mandatory Status: The IMSBC Code is mandatory under SOLAS Chapter VI (Carriage of Cargoes).

3. The Relationship and Overlap between IMDG Code and IMSBC Code:

Distinct Primary Focus: IMDG Code is primarily for packaged DG; IMSBC Code is for solid cargoes in bulk.

Overlap for Certain Group B Cargoes: Many solid bulk cargoes that are classified as Group B under the IMSBC Code (due to chemical hazards) are also classified as dangerous goods under one of the 9 classes of the IMDG Code.

Examples:

AMMONIUM NITRATE BASED FERTILIZER UN 2067 (IMSBC Group B, IMDG Class 5.1 or 9)

SULPHUR UN 1350 (IMSBC Group B, IMDG Class 4.1)

FERROUS METAL BORINGS, SHAVINGS, TURNINGS OR CUTTINGS UN 2793 (IMSBC Group B, IMDG Class 4.2)

DIRECT REDUCED IRON (DRI) (A) Briquettes, hot-moulded (IMSBC Group B, sometimes with IMDG Class implications if meeting certain criteria or if specific hazards are present).

IMSBC Code as the Primary Reference for Bulk Carriage:

SOLAS Chapter VII, Regulation 7-1 (Carriage of dangerous goods in solid form in bulk) states that such carriage shall be in compliance with the relevant provisions of the IMSBC Code.

The IMSBC Code itself, in its introduction (Section 1.4), clarifies that for a solid bulk cargo which is also listed in the IMDG Code, the provisions of the IMSBC Code should be primarily consulted for requirements related to its carriage in bulk.

However, the individual schedules in the IMSBC Code for such cargoes will often refer back to the IMDG Code for specific details like proper shipping name, UN number, IMO class, packing group (if relevant for defining hazard level), and sometimes for segregation from packaged dangerous goods or for emergency response information (EmS numbers).

4. Key Principles for Carrying Dangerous Goods in Solid Bulk Form:

Identification is Key: The first step is to correctly identify the cargo by its BCSN and determine if it has an individual schedule in the IMSBC Code. Then, check if this schedule also indicates it’s a dangerous good with a UN Number and IMO Class.

IMSBC Code Schedule Takes Precedence for Bulk Aspects: The specific instructions within the IMSBC Code individual schedule for that cargo regarding stowage, segregation (from other bulk cargoes), ventilation, handling, and specific bulk-related precautions are paramount.

IMDG Code for Additional Information:

Proper Shipping Name (PSN) and UN Number: These must be used in documentation if the cargo is classified under the IMDG Code.

IMO Hazard Class and Subsidiary Risks: Essential for understanding the nature of the hazard.

Segregation from Packaged Dangerous Goods: If the vessel is also carrying packaged dangerous goods, the segregation requirements between the bulk dangerous cargo and the packaged dangerous goods will be governed by the principles in the IMDG Code (using the segregation tables and specific substance instructions). The IMSBC Code schedule may provide guidance or refer to the IMDG Code.

Emergency Response (EmS): The IMSBC Code schedules for dangerous goods often list the relevant EmS Fire and Spillage schedule numbers (e.g., F-A, S-J). The detailed procedures for these EmS schedules are found in “The EmS Guide: Emergency Response Procedures for Ships Carrying Dangerous Goods,” which is a supplement to the IMDG Code.

Medical First Aid Guide (MFAG): The IMDG Code supplement also contains the MFAG, which provides guidance on medical first aid for incidents involving dangerous goods. The IMSBC Code schedule may refer to relevant MFAG table numbers.

Documentation:

Shipper’s Declaration: Must include all information required by the IMSBC Code, and if the cargo is also IMDG classified, it must additionally include the PSN, UN Number, IMO Class, and Packing Group (if assigned).

Dangerous Goods Manifest or Stowage Plan: SOLAS Chapter VII requires ships carrying dangerous goods (including in bulk) to have a special list, manifest, or stowage plan detailing the dangerous goods onboard, their location, and classification. This must be available to authorities.

Vessel Suitability and Certification:

Document of Compliance for the Carriage of Dangerous Goods: For ships carrying certain classes of dangerous goods in packaged form or some solid bulk dangerous goods, a Document of Compliance issued by the Flag State or Class may be required, certifying that the vessel’s construction and equipment comply with SOLAS Chapter II-2, Regulation 19 (Special requirements for ships carrying dangerous goods). This regulation details requirements for electrical equipment, ventilation, fire protection, bilge pumping, personnel protection, etc., in cargo spaces intended for dangerous goods. The specific IMSBC Code schedule for a dangerous bulk cargo will indicate if compliance with this regulation is necessary.

The Master must ensure the vessel holds the necessary certifications if carrying such cargoes.

5. Specific Considerations for Dangerous Goods in Bulk:

Stowage:

As per the individual IMSBC Code schedule.

Consider “away from heat sources,” “protected from sources of ignition,” “clear of living quarters/engine room bulkheads” as specified.

Segregation (from other bulk cargoes):

The IMSBC Code provides general segregation principles (Section 9.3) and specific requirements in individual schedules. For example, oxidizing substances must be segregated from combustible materials. Acids must be segregated from cyanides or alkalis.

The principle is to prevent dangerous interactions if cargoes were to mix due to leakage or spillage.

Ventilation: Critical for cargoes emitting flammable or toxic gases, or those that deplete oxygen. Must be as per the IMSBC Code schedule, using appropriate flame screens and ensuring vents do not lead to accommodation/machinery spaces.

Personnel Protection:

Strict adherence to PPE requirements (respirators, chemical suits, gloves, goggles) when handling or near these cargoes.

SCBAs and EEBDs must be readily available and crew trained in their use.

First aid equipment and knowledge of MFAG procedures are essential.

Fire Fighting:

Ensure fire-fighting equipment is appropriate for the specific hazards of the cargo (e.g., water may be unsuitable or dangerous for some Class 4.3 substances). The EmS fire schedule provides specific guidance.

Fixed fire-fighting systems (e.g., CO₂) must be suitable for the cargo.

Enclosed Space Entry: Extreme caution and strict adherence to procedures for any hold containing dangerous goods in bulk, due to risks of toxic/flammable gas or oxygen deficiency.

6. Master’s Responsibilities when Carrying Dangerous Goods in Bulk:

Verification of Documentation: Meticulously check the shipper’s declaration, ensuring all IMSBC and IMDG Code information is provided and correct.

Confirmation of Vessel Suitability: Ensure the vessel holds any necessary Document of Compliance for Carriage of Dangerous Goods and that its equipment (ventilation, fire-fighting, electrical fittings in holds) is appropriate for the specific dangerous cargo.

Strict Adherence to IMSBC Code and IMDG Code Provisions: Ensure all stowage, segregation, handling, ventilation, monitoring, and emergency preparedness measures are followed.

Crew Training and Awareness: Ensure the crew is fully aware of the hazards of the specific dangerous cargo being carried, the safety precautions, and emergency procedures (including EmS and MFAG). Conduct specific drills if appropriate.

Emergency Preparedness: Have the relevant EmS schedules and MFAG readily available. Ensure all emergency equipment is operational.

Reporting: Comply with all reporting requirements for dangerous goods (e.g., to port authorities).

Analysis for the Master (DG in Bulk): Carrying dangerous goods in solid bulk form adds a significant layer of complexity and responsibility.

Dual Code Compliance: The Master must be comfortable navigating both the IMSBC Code (for bulk aspects) and relevant parts of the IMDG Code (for DG classification, EmS, MFAG, and segregation from packaged DG).

No Compromise on Safety: The potential consequences of an incident involving dangerous goods are severe. There can be no shortcuts or compromises on safety procedures or regulatory compliance.

Information is Key: Accurate and complete cargo information from the shipper is even more critical for dangerous goods.

Consultation: If there is any doubt about the requirements for a specific dangerous bulk cargo, the Master must consult the company (DPA), Flag State, or Class society for guidance.

The safe carriage of dangerous goods in solid bulk form demands the highest level of diligence, knowledge, and adherence to international regulations. The Master’s role in ensuring that all requirements of both the IMSBC Code and, where applicable, the IMDG Code are met is paramount to the safety of the crew, the vessel, the cargo, and the marine environment.