AMSA Exemption Relating to Corrosive Properties of Solid Bulk Cargoes (Updated December 2022)

The Australian Maritime Safety Authority (AMSA) has been working with industry on issues identified with the repeatability and reliability of the modified C.1 test prescribed by section 9.2.3.7.3 of the IMSBC Code[1]. A refined Materials Hazardous only in Bulk (MHB) corrosivity (CR) test has been developed, which specifies testing of representative cargo samples at conditions representing their as-shipped properties. Amendments to be included in the 06-21 amendments to the IMSBC Code were finalised and agreed upon 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, AMSA has previously issued five exemptions relating to the corrosivity of solid bulk cargoes, the most recent being EX 5739 (issued 4 February 2019 and valid until 31 December 2022).
Due to the global pandemic, the finalisation of the 06-21 amendments to the IMSBC Code was delayed. The Maritime Safety Committee, at its 105th session, adopted the 06-21 amendments that will come into mandatory effect on 1 December 2023 and also approved a revised circular MSC.1/Circ.1600/Rev.1 Guidance for Conducting the Refined MHB (CR) Test that reflects those amendments. AMSA has therefore issued an Exemption 6343, valid until 30 November 2023, to allow shippers to use the revised circular until the 06-21 amendments to the IMSBC Code come into mandatory effect.
A shipper can use EX 6343 for any solid bulk cargo; hence it replaces all previously issued exemptions relating to the corrosivity of solid bulk cargoes (i.e. EX 5450, EX 5451, EX 5717, EX 5718 and EX 5739), regardless of the date of validity indicated on those certificates.

AMSA Approval for MHB categorisation related to self-heating properties of coal (Updated December 2022)

AMSA has been working with industry concerning issues identified with the repeatability and reliability of the N.4 test prescribed by section 9.2.3.3 of the IMSBC code to determine the self-heating properties of coal. While the research continues, they have issued Approval 8024, valid from 14 December 2022, which replaces the previously issued certificate of approval AP5620. This exemption permits the approval of coal, meeting certain criteria, to be MHB on the condition that extra precautions are taken. A copy of approval 8024 should be made available to Masters of vessels before loading if it is relied upon.

Exemptions and approvals for the handling, transport, and categorising certain cargoes can be found here

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For further information on these exemptions or approvals, or any other maritime transport compliance query please contact Davoren Environmental
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[1] International Maritime Solid Bulk Cargoes Code. Incorporating Amendment 05-19 and Supplement, 2020 Edition.

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:

• Exemption 5717 to section 334 of the Navigation Act 2012 and
• Exemption 5718 to section 334 of the Navigation Act 2012 

Both of which will expire on 30 June 2019.

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For further information on this exemption, or conducting the refined MHB (CR) corrosivity test, or for any other maritime transport compliance query please contact Davoren Environmental
[email protected]

​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 9.2.3.7.3 of the International Maritime Solid Bulk Cargoes Code (IMSBC Code[1]).
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:

• Exemption 5717 to section 334 of the Navigation Act 2012 was issued on 20 December 2018 and replaces EX5451 which is now revoked. As with EX5451 this exemption allows shippers of mineral concentrates and metal sulphide concentrates to use a modified C.1 test better suited to the properties of these materials. This exemption remains valid until 30 June 2019 unless altered or revoked by AMSA before this date.
• Exemption 5718 to section 334 of the Navigation Act 2012 was issued on 20 December 2018 and replaces EX5450 which is now revoked. As with EX5450 this exemption allows shippers of iron ore, iron ore fines, coal and bauxite to use an alternative method (i.e. DIN 50929-3) for evaluation of the localised corrosive properties of these cargoes for MHB (CR) classification. This exemption remains valid until 30 June 2019 unless altered or revoked by AMSA before this date.

For further information on these exemptions, or conducting the refined MHB (CR) corrosivity test, or for any other maritime transport compliance query please contact Davoren Environmental
[email protected]

[1] International Maritime Solid Bulk Cargoes Code. Incorporating Amendment 04-17 and Supplement, 2018 Edition.
 

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:

*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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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]

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:

• Amendments to Regulation 4 and 6 of Annex V require the shipper to declare whether cargo residues are classed as harmful to the marine environment (HME). A new Appendix I provides criteria for the classification of solid bulk cargoes (Resolution MEPC.277(70)).
•  The Form of Garbage Record Book is updated. The Record of Garbage Discharges is divided into Part I for the use of all ships and Part II, required for ships that carry solid bulk cargoes. 
• A new category of garbage “e-waste” is included. E-waste is defined in the 2017 Guidelines for implementation of MARPOL Annex V as electrical and electronic equipment used for the normal operation of the ship or in the accommodation spaces, including all components, sub-assemblies and consumables, which are part of the equipment at the time of discarding, with the presence of material potentially hazardous to human health and/or the environment.

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 6.1.2.1 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).

Davoren Environmental have extensive experience in classifying solid bulk cargoes according to these requirements. For this or for any other maritime transport compliance query please contact [email protected]

For further information on how we can assist your company with transport compliance requirements for solid bulk cargoes please contact Davoren Environmental  ​[email protected]

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

1. IRON ORE and IRON ORE FINES
2. COAL
3. BAUXITE

to use an alternative method for evaluation of the localised corrosive properties of these cargoes for Materials Hazardous in Bulk (MHB) classification.

What does the exemption mean?
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The exemption means that producers and shippers of the above listed cargoes may use the standard DIN 50 929 Part 3[1] 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 9.2.3.7.3 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

1. METAL SULPHIDE CONCENTRATES
2. MINERAL CONCENTRATES

to use a modification of the Test C.1 method for evaluation of the corrosive properties (uniform and localised) of these 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.

For further information for assessment of localised corrosion according to DIN 50 929 Part 3 (EX5450) or the modified Test C.1 (EX5451) or for any other maritime transport compliance query please contact Davoren Environmental  [email protected].

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[1] 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.
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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[1]

1. Acute Aquatic Toxicity, Category 1; and/or
2. Chronic Aquatic Toxicity, Category 1 or 2; and/or
3. Carcinogenicity[2]  1A or 1B combined with not being rapidly degradable and having high bioaccumulation; and/or
4. Mutagenicity[2]  1A or 1B combined with not being rapidly degradable and having high bioaccumulation; and/or
5. Reproductive Toxicity[2]  1A or 1B combined with not being rapidly degradable and having high bioaccumulation; and/or
6. Specific Target Organ Toxicity-Repeated Exposure[2]  (STOT-RE) Category 1 combined with not being rapidly degradable and having high bioaccumulation; and/or
7. Solid bulk cargoes containing or consisting of synthetic polymers, rubber, plastics, or plastic feedstock pellets (this includes materials that are shredded, milled, chopped or macerated or similar materials).

The most recent edition of the IMSBC Code[3] also now includes a new Section 14 Prevention of pollution by cargo residues from ships which specifically details the requirement of the shipper for classifying and declaring whether a cargo is HME.

For further information on how to classify your solid bulk cargo to address HME designation requirements or for any other maritime transport compliance query please contact Davoren Environmental [email protected]


[1] 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.

[2] 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

[3] International Maritime Solid Bulk Cargoes Code (IMSBC, 2016 Edition) Incorporating Amendment 03-15 and Supplement.