A refined Materials Hazardous only in Bulk (MHB) corrosivity (CR) test has been developed which prescribes testing of representative samples of the cargo at conditions representing their as-shipped properties. The International Maritime Organization (IMO) formally published this interim guidance in January 2019 MSC.1/Circ.1600 Interim Guidance for Conducting the Refined MHB (CR) Corrosivity Test. AMSA have recently issued exemption EX5739 which allows shippers to use this guidance in the circular until 31 December 2022 when it is agreed and finalised in the 06-21 amendments to the IMSBC Code, considering the mandatory entry into force would be 1 January 2023.
AMSA have previously issued two exemptions also relating to corrosivity:
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The Australian Maritime Safety Authority (AMSA) have been working with industry on issues identified with the repeatability and reliability of the modified C.1 test prescribed by section 22.214.171.124.3 of the International Maritime Solid Bulk Cargoes Code (IMSBC Code).
AMSA have previously issued two exemptions, namely EX5450 (issued 19 December 2016) and EX5451 (issued 21 December 2016) in respect of assessing the corrosive properties of solid bulk cargoes. Both of these exemptions were valid until the 04-17 amendment to the IMSBC Code came into mandatory effect from 1 January 2019.
Issues relating to use of the C.1 test for assessing the corrosive properties of Solid Bulk Cargoes have been progressed at meetings of the sub-committee for the Carriage of Cargoes and Containers (CCC) at the International Maritime Organization (IMO). A refined Materials Hazardous only in Bulk (MHB) corrosivity (CR) test has been developed which prescribes testing of representative samples of the cargo at conditions representing their as-shipped properties. Amendments to be included in the 06-21 amendments to the IMSBC Code were finalised and agreed during CCC 5 in September 2018. These were sent to the Maritime Safety Committee (MSC) in December 2018 for that committee to issue an MSC circular. Until that circular can be formally published, allowing AMSA to permit use of it, and to allow shippers a period to transition to the contents of the circular once it is formally published, AMSA has issued two exemptions valid until the end of June 2019, to replace those previously issued as detailed below:
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 International Maritime Solid Bulk Cargoes Code. Incorporating Amendment 04-17 and Supplement, 2018 Edition.
The IMSBC Code establishes international provisions for the safe loading, trimming, carriage and discharge of solid bulk cargoes when transported by sea, ensuring compliance with the provisions of the SOLAS Convention and identifies the risks associated with such cargoes with the aim of taking measures to minimise and control them. One of the risks identified is the risk associated with liquefaction of certain cargoes. Such cargoes are identified as Group A cargoes in the IMSBC Code. Group A Cargoes are defined as cargoes which may liquefy if shipped at a moisture content in excess of their transportable moisture limit (TML). The TML of a cargo means the maximum moisture content of the cargo which is considered safe for carriage in ships.
In accordance with paragraph 4.3.3 of the IMSBC Code, when a cargo which may liquefy is carried, procedures for sampling, testing and controlling the moisture content to ensure the moisture content is less than the TML when it is on board the ship, shall be established by the shipper. A Moisture Management Plan which verifies and documents these procedures should therefore be prepared by the shipper in line with established guidelines. This plan should be provided well in advance of shipment to the Competent Authority (CA), at the port of loading. The CA will review the procedures and once verified that they are in accordance with the relevant guidelines will issue an approval for transport of that cargo. This approval is then provided to the Master of the vessel intended to be loaded.
In the latest edition of the IMSBC Code, there are some notable amendments to existing schedules which relate specifically to their Group A designation:
*Shippers of Bauxite should also note that whilst this cargo is listed as a Group C cargo in the IMSBC Code (2016 and 2018 Editions), recent work conducted by the industry Global Bauxite Working Group (GBWG) in conjunction with CAs indicate that Bauxite represents a risk caused by moisture. As such, some Bauxite cargoes should be treated as Group A cargoes.
Pending adoption of changes into the IMSBC Code, the Australian Maritime Safety Authority (AMSA) have issued approval AP5456 to allow the test and schedules adopted by CCC-4 to be applied to Bauxite when shipped from Australia in solid form in bulk. These changes will be included in a future amendment to the IMSBC Code, which is expected to enter into force on 1 January 2021. Until such time, any bauxite cargoes should be classified as Group A or Group C and are to be carried in accordance with the draft procedures specified in AP5456 and with subsection 1.3 of the IMSBC Code.
Davoren Environmental have significant experience in preparing Moisture Management Plans in accordance with IMO guidelines for shipment approval.
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 The IMSBC Code & Supplement, 2018 Edition was released in March 2018. The latest edition incorporates amendment 04-17 (Resolution MSC.426(98)), which may be applied from 1 January 2018 on a voluntary basis, anticipating its envisaged official entry into force on 1 January 2019.
 Guidelines for developing and approving procedures for sampling, testing and controlling the moisture content for solid bulk cargoes which may liquefy. 15 June 2015. MSC.1/Circ.1454/Rev.1. International Maritime Organization.
 Coal shall be classified as Group A and B unless classified as Group B only by a test determined by the appropriate authority or where it has particle size distribution stated in 2018 Code schedule.
New MARPOL Amendments entered into force on March 1 2018.
Specific amendments relating to MARPOL Annex V Prevention of pollution by garbage from ships include the following:
Management of Solid Bulk Cargo Residues
With regard to HME classification, 2017 Guidelines to assist in the implementation of MARPOL Annex V have been published. Cargo residues are considered as HME and subject to regulations 4.1.3 and 126.96.36.199 of MARPOL Annex V if they are residues of solid bulk cargoes (other than grain) which are classified according to the criteria of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Other notable changes to the IMSBC Code include:
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Many materials produced or used in the mining and minerals processing industry are classified as hazardous according to the Globally Harmonized Classification System (GHS). The correct classification of these materials is therefore imperative to properly manage any potential health and environmental risks and ensure compliance with relevant legislative requirements, .
Davoren Environmental have significant experience working with the mining industry to conduct hazard assessments on a wide range of materials for classification against relevant transport codes. Some of the materials assessed include:
Our aim is to make the hazard assessment and classification process as simple and tailored as possible by:
1. Consulting with the client to:
a. Fully understand the material’s physical/chemical characteristics to identify the relevant hazards that apply, and consequently the applicable tests that need to be conducted; and
b. Confirming how this material will be transported to identify relevant legislation to be addressed.
2. Coordinate and manage this testing directly with laboratory;
3. Compile a comprehensive classification report based on results of 1 and 2 above which will clearly detail the hazard assessment and classification of the material against applicable transport regulations.
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 ICMM, 2014. Hazard Assessment of Ores and Concentrates for Marine Transport.
 Australian Government, 2016. Hazardous Material Management: Leading Practice Sustainable Development Program for the Mining Industry.
 Australian Code for the Transport of Dangerous Goods by Road and Rail (ADG) in Australia; International Maritime Dangerous Goods (IMDG) Code for maritime transport of packaged dangerous goods, including substances, mixtures and articles; and the International Maritime Solid Bulk Cargoes (IMSBC) Code and International Convention for the Prevention of Pollution from Ships (MARPOL Annex V) for shipment of solid bulk cargoes.
The Australian Maritime Safety Authority (AMSA) has issued two recent exemptions in respect of assessing the corrosive properties of solid bulk cargoes.
AMSA issued EX5450 on the 19th of December 2016, which allows shippers of the following solid bulk cargoes
What does the exemption mean?
The exemption means that producers and shippers of the above listed cargoes may use the standard DIN 50 929 Part 3 as an alternative method to evaluate localised corrosion of these cargoes. The rate of uniform corrosion shall still be evaluated using the UN Manual of Tests and Criteria, part III, Section 37 Test C.1 and as prescribed in Section 188.8.131.52.3 in the IMSBC Code, inclusive of the 03-15 amendments. This exemption replaces previously issued EX5389 which is now revoked and was specifically for IRON ORE and IRON ORE FINES only.
EX5451 was issued on the 21st of December 2016 and allows shippers of the following solid bulk cargoes
What are the modifications?
The main change is the use of steel coupons only which are considered to be more representative of ships’ structures. Other notable amendments in the modified test are the sealing of the test container to prevent air exchange, a specified air to solids ratio and more prescriptive guidance on sample introduction and compaction within the test container.
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 Corrosion of metals; probability of corrosion of metallic materials when subject to corrosion from the outside; buried and underwater pipelines and structural components. September 1985.
The International Convention for the Prevention of Pollution from Ships (MARPOL) is the main international convention governing the prevention of pollution to the marine environment by ships from operational or accidental causes. The MARPOL convention was adopted in 1973, whereas the actual protocol was adopted in 1978. The combined instrument MARPOL 73/78 entered into force in 1983, and has been subject to amendments over the years. In July 2011, the International Maritime Organization (IMO) adopted revisions to MARPOL Annex V that were of specific relevance to the transport of solid bulk cargoes.
In accordance with MARPOL Annex V, the management of the residues of solid bulk cargoes depends primarily on the classification of the solid bulk cargo as to whether it is Harmful to the Marine Environment (HME) or non-HME. In 2012, the Marine Environment Protection Committee (MEPC) of IMO, adopted the 2012 Guidelines for the implementation of MARPOL Annex V (resolution MEPC.219(63)) to assist in the implementation of requirements for MARPOL Annex V.
Residues are considered as HME if they are classified against any one of the following seven parameters according to the criteria of the UN GHS
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 Refers to the 4th revised edition of the Globally Harmonized System of Classification and Labelling of Chemicals, published by the United Nations as document ST/SG/AC.10/30/Rev.4.
 Products that are classified for Carcinogenicity, Mutagenicity, Reproductive Toxicity or STOT-RE for oral or dermal hazards or without specification of the exposure route in the hazard statement
 International Maritime Solid Bulk Cargoes Code (IMSBC, 2016 Edition) Incorporating Amendment 03-15 and Supplement.
The International Maritime Solid Bulk Cargoes (IMSBC Code) 2016 Edition - What's new with MHB classification and how it will impact shippers
The principal aim of the IMSBC Code is to enable the safe stowage and shipment of solid bulk cargoes by providing information on the dangers associated with the shipment of certain types of solid bulk cargoes and instructions on the practices and procedures to be followed when planning to ship solid bulk cargoes.
The IMSBC Code is subject to updates every two years to keep pace with the nature and variety of solid bulk cargoes presented for shipment, and developments in understanding regarding the safest ways to carry established solid bulk cargoes.
In June 2015, the IMO’s Maritime Safety Committee (MSC) adopted the most recent amendments Resolution MSC.393 (95) specifying forthcoming changes to the IMSBC Code. Amongst the adopted amendments (03-15) are included specific changes to Section 9 of the Code Material Hazardous only in Bulk (MHB).
According to the adopted amendments, where a cargo is found to meet one or more of the chemical hazards for MHB designation as defined below, a notational reference for each hazard must be included in the “Class" cell. A summary of the notational references to be used is presented below:
Summary of Notational References for Classification of Relevant MHB Hazards
Resolution MSC.393(95), incorporating amendment 03-15, may be applied from the 1st of January 2016 on a voluntary basis, anticipating its envisaged official entry into force on the 1st of January 2017.
* Where deviations from the chemical hazards described in 184.108.40.206 to 220.127.116.11 of IMSBC Code have been determined (Other hazards (OH)), they shall be properly recorded with justifications. Other hazards are to be included in the section for “hazard” in the individual schedule.
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