Following amendments to the IMO’s IMSBC Code, coal cargoes could be subject to new testing and classification
It is a shocking statistic that an estimated half of all the seafarer lives lost in dry bulk shipping over a 10-year period were due to cargo failure.
In its most recent report covering 2008-2017, Intercargo, a trade body for dry cargo shipowners, points out that 101 lives and nine bulk carriers were likely lost due to cargo failure, compared with a total of 202 lives lost in 53 vessel casualties. Of the nine bulk carrier losses, six were vessels loaded with nickel ore from Indonesia, two with laterite (clay) iron ore from India, and one with bauxite from Malaysia.
Liquefaction of bulk cargoes therefore remains a major concern for the industry. Problems associated with nickel ore and iron ore fines, are perhaps the best known, but now the IMO’s International Maritime Solid Bulk Cargoes (IMSBC) Code has been amended to include coal, increasing pressure on coal shippers to sample their cargo prior to loading.
The IMSBC Code describes coal as a natural, solid, combustible material, consisting of amorphous carbon and hydrocarbons.
Although coal is best known for its flammable and self-heating properties, certain coal cargoes may also be liable to liquefaction. Penelope Cooke of law firm Brookes Bell, points out that the amendments to the Code concern the criteria under which coal cargoes are considered Group A (i.e. liable to liquefy) in addition to the Group B chemical hazards that apply to all coal cargoes, such as potential self-heating or methane emissions.
Coal may therefore require the same transportable moisture limit (TML) and moisture certification as other Group A cargoes, such as concentrates, nickel ore and iron ore fines.
There are two ways in which shippers may demonstrate that the coal is not Group A. The first is if the coal has a particle size distribution such that no more than 10% is less than 1mm, and not more than 50% is less than 10mm.
Both factors apply#
Cooke emphasises the use of ‘and’, which means that cargoes exceeding either of these limits will not be exempt from Group A requirements. This differs from (and covers a wider range of cargoes than) the equivalent size criteria for iron ore fines.
Alternatively, the competent authority of the country of loading can specify laboratory criteria to assess whether or not a coal cargo possesses Group A properties. Such criteria would most likely be based on the outcome of the test methods for Group A cargoes in Appendix 2 of the IMSBC Code.
New test method
For cargoes that are Group A (and B), shippers can now test the cargo for its TML using a newly developed test method for coal. The coal TML method is a modified Proctor/Fagerberg (PF) procedure that is significantly different from the existing PF methods (e.g. those modified for iron ore fines), in that there is a new procedure on how to deal with lumps over 50mm in the sample. Drying ovens should have forced circulation or use an inert gas, unlike ovens used for the other TML test methods.
However, Cooke says that suitable TML test facilities will not be widely available in commercial coal laboratories, at least in the short term.
Some loading locations, such as in Indonesia, have remote access and shippers might not have specialist lab facilities at loading ports. All TML testing and certification should be completed prior to the start of loading. However, it ight not be possible to achieve either the sizing or TML testing at the load port should there be any dispute.
As with all solid bulk cargoes, the IMSBC Code requires all proper documentation to be provided to the master prior to loading, and this will now include the information on the coal classification.
The rationale for shippers declaring a cargo as either Group B only, or Group A and B, will need to be clearly stated. The sizing criteria could be included on the cargo declaration, or it could be issued as a separate certificate. If there are no sizing criteria provided, the coal should be assumed to be both Group A and B, and hence require a TML and moisture certification prior to loading.
As with all Group A cargoes, if the coal has a TML certificate then it must be protected from rain in shore stockpiles and barges during loading, and the moisture content will need to be rechecked after any rain at the loading port.
None of the above has any bearing on the other hazards of coal, such as self-heating or methane emissions, and these will still need to be monitored and controlled for each cargo.
Although there was no reported loss of life or loss of ship attributed to liquefaction in 2018, Intercargo is urging all stakeholders to remain vigilant as cargo liquefaction continues to pose a major threat to the life of seafarers.
Ship operators need to be especially cautious when loading during a wet season, a regular occurrence in South East Asia. However, it is paramount that shippers and local authorities fulfil their obligations as required by the IMSBC Code.