[ID] => 8832
[post_author] => 34
[post_date] => 2017-12-04 09:20:17
[post_date_gmt] => 2017-12-04 09:20:17
[post_content] => The International Maritime Organisation’s (IMO) Sub-committee on Carriage of Cargoes and Containers (CCC) held its fourth session from 11 to 15 September 2017 in London. The meeting had plenty on its plate, not least the updating of the International Maritime Dangerous Goods (IMDG) Code.
To this end, CCC reviewed the work of the Editorial & Technical (E&T) Group, which had finalised corrections to Amendment 38-16 of the International Maritime Dangerous Goods (IMDG) Code as well as the changes that will appear in the next Amendment, 39-18.
For reference, Amendment 38-16 takes mandatory effect on 1 January 2018, though it has been available for use since 1 January 2017. Similarly, those subject to the Code will be able to use Amendment 39-18 as from 1 January 2019 and it will become mandatory on 1 January 2020.
For the most part, CCC agreed the corrections and amendments to the IMDG Code as well as revisions to the Emergency Schedules, subject to a final review by the E&T Group at a meeting held just after the CCC session. The final text of Amendment 39-18 will need to be ratified by the Maritime Safety Committee (MSC) at its 99th session in May 2018; only after that can IMO’s publications department get on with the serious work of laying out the final text for the printers.
CCC’s work on Amendment 39-18 began with a look at the decisions already made, to which some further changes were agreed. To the list of items assigned to Class 9 in 22.214.171.124 was added an entry for UN 3548 Articles containing miscellaneous dangerous goods nos.
The headings in 126.96.36.199 and other references to segregation groups were aligned so that there is no space between ‘SGG’ and the following number (eg SGG1, SGG1a, etc). The segregation groups for UN 1971 (SGG8) and UN 1908 (SGG5) were confirmed and the square brackets removed from those entries in column (16b) of the Dangerous Goods List.
In packing instruction P403, special packing provision PP31, “, except for solid fused material” was deleted. It is likely that P403 and P410 will need a review at a forthcoming session.
A new definition for IMO type 9 tanks was added in the Note to the transitional provisions for the use of portable tanks at 188.8.131.52:
IMO type 9 tank means a road gas elements vehicle for the transport of compressed gases of class 2 with elements linked to each other by a manifold, permanently attached to a chassis, which is fitted with items of service equipment and structural equipment necessary for the transport of gases. Elements are cylinders, tubes and bundles of cylinders, intended for the transport of gases as defined in 184.108.40.206.
While CCC and the E&T Group had by now adopted most of the amendments in the 20th revised edition of the UN Model Regulations into the new edition of the IMDG Code, following a recent decision by the UN Sub-committee of Experts on the Transport of Dangerous Goods (TDG), reference to a 2-mm line around labels was removed from 220.127.116.11.1.1.2. In 18.104.22.168.2 and 22.214.171.124.1 reference to ‘bulk container’ is inserted after ‘transport units’. The last sentence of the revised 126.96.36.199 was deleted and a textual change was made in 188.8.131.52 for clarity.
NEW IDEAS FOR THE CODE
Discussion then moved on to a number of new submissions. Many of these were put forward by Germany, whose head of delegation, Gudula Schwann, is chair of the E&T Group and, as from this session, vice-chair of CCC.
The first proposed a clarification in SP 963, which is specific to the maritime mode, that nickel metal hydride (NMH) cells, whether packed with or contained in equipment, or button cells packed separately, are not subject to the provisions of the IMDG Code. This was accepted, with a change also made in the Dangerous Goods List against UN 3496.
A rather more complex proposal involved the applications of the segregation requirements of SG1 apply to UN 2956; SP 133, which applies to this entry, required a Class 1 label to be applied, although the primary hazard for UN 2956 is Division 4.1. There was some support for the change, although the proposed wording was not thought sufficient. After some work, CCC accepted a revised text for the description in SG1 in 7.2.8:
For packages carrying a subsidiary hazard label of class 1, segregation as for class 1, division 1.3. However, in relation to goods of class 1, segregation as for the primary hazard.
Another issue in respect of segregation had arisen following the recent addition of a Division 6.1 subsidiary hazard for uranium hexafluoride, as explained in papers from Germany and the World Nuclear Transport Institute (WNTI). Again, there was broad support for the changes but further work was needed before an acceptable solution could be found. This involved creation of a new SG78 for UN 2977 and 2978:
Stow “separated longitudinally by an intervening complete compartment or hold from” division 1.1, 1.2 and 1.5.
SG68 was removed from those two entries. For UN 3507, SG77 was amended to read:
Segregation as for class 8. However, in relation to class 7, no segregation needs to be applied.
France felt that a change was needed to SP 363, the fourth indent of which is specific to the IMDG Code. It currently includes a requirement to apply a marine pollutant mark of 100 x 100 mm for UN 3530 but the proposal sought the use of a larger, 250 x 250 mm, mark in cases where the engine on machinery involved contains more than 60 litres of fuel and has a capacity of more than 3,000 litres, to be consistent with requirements in the UN Model Regulations for other placards. The US identified a gap in the proposal concerning engines or machinery containing more than 60 litres of fuel but with a capacity of less than 3,000 litres.
Both points were taken into account by the E&T Group, which drew up a new sub-paragraph 10 for SP 363 as part of a larger revision and expansion of that special provisions.
Peru returned with further proposals on the fumigation of cargoes of fish meal, arguing for lower levels of ethoxyquin to be added to and to be residue in cargoes both in packaged and bulk form. Such a move is necessary to comply with EU requirements that will enter into force in 2019. There was support in principle at CCC, leaving the E&T Group with the task of finalising the textual changes. This was done by revising SP 308 to read:
Stabilization of fish meal shall be achieved to prevent spontaneous combustion by effective application of ethoxyquin, BHT (butylated hydroxytoluene) or tocopherols (also used in a blend with rosemary extract) at the time of production. The said application shall occur within twelve months prior to shipment. Fish scrap or fish meal shall contain at least 50 ppm (mg/kg) of ethoxyquin, 100 ppm (mg/kg) of BHT or 250 ppm (mg/kg) of tocopherol based antioxidant at the time of shipment.
At the suggestion of the Dangerous Goods Advisory Council (DGAC), a note was added:
For the transport of fish meal in bulk, see the IMSBC Code.
As a consequence, SP 945 was deleted.
A rather more extensive proposal envisaged the restructuring of section 5.5.2, which deals with fumigated cargo transport units (CTUs). The proposal generated considerable discussion and, in the end, there was little agreement at CCC other than MSC.1/Circ.1361 is in need of revision.
The E&T Group was invited to look at the proposals in more detail. It was evident from the discussions that there is an issue insofar as the IMDG Code is designed to deal with cargo during maritime carriage (other than the relatively recently included provisions for the training of shoreside personnel), whereas issues surrounding the safety of fumigated CTUs relate largely to their handling within container terminals and at their destination.
To some extent this had been foreseen when 5.5.2 was originally drawn up: it was intended to work as a standalone provision that could be copied for reference by shoreside workers, albeit their safety is normally overseen as part of occupational safety and health regulations within their national jurisdiction.
Further concerns emerged surrounding the potential for those who fumigate cargoes to become dangerous goods shippers, which would mean a requirement for training and legal responsibilities as regards placarding and the completion of a dangerous goods transport document. It was pointed out that some of these concerns apply equally to section 5.5.3 on the use of conditioning treatments in CTUs. It was agreed that the UN TDG Sub-committee should be consulted on this and on the necessity to specify what “adequate ventilation” means in practice.
In the end very few changes were agreed, other than the deletion of 184.108.40.206.2 (with renumbering of the following paragraphs) and the revision of what is now 220.127.116.11.3 to read:
Cargo transport units shall be fumigated in accordance with the requirements determined by the competent authority, to ensure a sufficient period has elapsed to attain a reasonable uniform gas concentration throughout the cargo in it. Twenty-four hours is normally sufficient for this purpose.
While there was general agreement on the need for MSC.1/Circ.1361 to be revised, there was little agreement on what actually needs to be done. After discussion, interested delegations were invited to make submissions to CCC’s next session.
China proposed a mode-specific special provision to require that batteries, wet, non-spillable, installed in CTUs for the operation of equipment in the CTU, meet similar provisions to those applied to lithium batteries under SP 389. There were questions but few answers at CCC and the E&T Group also failed to reach a consensus. Some felt this was a question for the UN TDG Sub-committee.
The European Chemical Industry Council (Cefic) submitted a proposal building on prior discussions on the transport of battery-vehicles on shortsea vessels. The concept of ‘battery-vehicle’ clearly confused some delegations – this is a concept defined in ADR but largely absent outside Europe. Battery-vehicles are not battery-powered and are not the same as multiple-element gas containers (MEGCs).
Eventually a definition for a new IMO type 9 tank was agreed (see above). After much debate, a new 18.104.22.168 was agreed, with provisions for road gas elements vehicles for compressed gases of class 2 (IMO Type 9). This sub-section includes general provisions (22.214.171.124.1), requirements for design and construction (126.96.36.199.2) and provisions for approval, testing and marking (188.8.131.52.3). The title of Chapter 6.8 was changed to “Provisions for road tank vehicles and road gas elements vehicles”.
A full list of the changes that will appear in Amendment 39-18 to the IMDG Code will be included in an issue of HCB later in the year, once they have been formally adopted.
BULKS AND GASES
Aside from IMDG-related issues, CCC also had other matters to discuss. It continued with its work to update the International Maritime Solid Bulk Cargoes (IMSBC) Code, the next edition of which will be a consolidated version. This is expected to be prepared by the E&T Group at its meeting in the spring of 2018 for final adoption by MSC at its 101st session in 2019.
Draft amendments were agreed to Part A-1 of the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), relating to protection of the fuel supply for liquefied gas fuel tanks, aimed at preventing explosions. Further progress was also made in developing safety provisions for ships using fuel cells, which will appear in a new Part E in the IGF Code.
CCC also agreed unified interpretations to the IGF Code and the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) relating to testing of high-level alarms and level indicators in the bilge well of tank connection spaces of independent liquefied gas storage tanks.
Also relating to gas ships, discussions continued on the suitability of high-manganese austenitic steel for cryogenic service. It was agreed that draft interim guidelines will be developed for the use of such steels in cryogenic services and a correspondence group was re-established for this purpose.
Two specific hazards were also addressed by CCC. The first involved the carriage of bauxite and CCC was moved to issue new guidance in the form of a revision to CCC.1/Circ.2. As a result of work carried out over the past two years, CCC noted that some bauxite cargoes should be classified as Group A, with a shipping name of ‘bauxite fines’.
During its session CCC finalised draft test procedures for determining the transportable moisture limit (TML) of bauxite cargoes, the draft individual schedule for Group A bauxite and draft amendments to the individual schedule for Group C bauxite. Group A bauxite should be carried in accordance with sub-section 1.3 of the IMSBC Code. These drafts are expected to be adopted by MSC at its 101st session in 2019 for entry into force on 1 January 2021.
The revised circular invites governments to note that those bauxite cargoes deserving of a Group A classification pose a risk to ships and seafarers and suggests that maritime administrations pass this message on to vessel operators, agents, terminals and others involved in the transport of bauxite by sea.
The second specific hazard addressed during the meeting was ammonium nitrate-based fertilisers (non-hazardous), following incidents involving the vessels Purple Beach (in 2015) and Cheshire (in 2017). CCC noted that investigations are not yet complete but felt that the risks inherent in the transport of this cargo in bulk deserved prompt recognition; a new circular CCC.1/Circ.4 was issued.
During the two incidents mentioned, the cargo gave off clouds of toxic gas large enough to envelop the ship, hindering the safe abandonment of the vessels and rescue and firefighting efforts. The circular notes that, during such events, cargo decomposition may continue for several days and result in temperatures within cargo holds of as much as 500˚C. The best protection against such incidents is the early identification of any cargo decomposition through regular monitoring of the cargo throughout the voyage.
[post_title] => IMO: Freight all kinds
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[post_name] => imo-freight-kinds
[post_modified] => 2017-12-03 19:28:01
[post_modified_gmt] => 2017-12-03 19:28:01
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[guid] => https://www.hcblive.com/?p=8832
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IMO's CCC Sub-committee has almost completed work on the next IMDG Code, Amendment 39-18. Just as well, too, as it has other Codes on its plate