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.

Want more information?
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
maria@davorenenvironmental.com.au

​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
maria@davorenenvironmental.com.au

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

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 maria@davorenenvironmental.com.au

For further information on how we can assist your company with transport compliance requirements for solid bulk cargoes please contact Davoren Environmental  ​maria@davorenenvironmental.com.au

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[1], [2].
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[3].  Some of the materials assessed include:

• Bauxite, alumina and aluminium
• Coal
• Copper
• Iron Ore
• Lead
• Mineral Sands
• Nickel

In addition to the materials listed above we also conduct hazard assessment and classification of industry by-products (e.g. carbon filter cakes) for subsequent transport compliance for resource recovery.

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.
 
Want More Information?
For further information on how we can assist your company with transport compliance requirements please contact Davoren Environmental  maria@davorenenvironmental.com.au


[1] ICMM, 2014. Hazard Assessment of Ores and Concentrates for Marine Transport.

[2] Australian Government, 2016. Hazardous Material Management: Leading Practice Sustainable Development Program for the Mining Industry.

[3] 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.