Moisture Management Plan for Group A Cargoes

The IMSBC Code[1] 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[2]. 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.
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In the latest edition of the IMSBC Code, there are some notable amendments to existing schedules which relate specifically to their Group A designation:

Cargo	IMSBC Code 2016 Listing	IMSBC Code 2018* Listing
Coal	B (and A)	B (and A[3])
Ilmenite Sand	A or C	A

*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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Want More Information?

For further information on how we can assist your company with preparation of Moisture Management Plans or for any other transport compliance requirements please contact Davoren Environmental  [email protected]

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[1] 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.

[2] 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.

​[3] 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.