Due to some historic high-profile cases involving the loss of vessels and crews when carrying Indian Iron Ore Fines, vessels heading to Indian ports to load iron ore fines will need to ensure they comply with both the IMSBC code and all local requirements.

Local Requirements

There are four circulars from the Indian authorities that outline local requirements in the region which has created some confusion about the actual requirements currently are. The circulars are:

• Directorate General of Shipping, Ministry of Shipping Circular No2 of 2017.
• Merchant Shipping Notice No9 of 2010 – Safe Loading, Stowage, Carriage and Discharging or Iron Ore Fine on Ships from Indian Ports in Fair and Foul Season
• Merchant Shipping Notice No34 of 2009 – Safe Loading of Solid Bulk Cargo especially Iron Ore Fines from Indian Ports.
• Merchant Shipping Notice No31 of 2009 – Safe Loading of Solid Bulk Cargo with Special Reference to Iron Ore Fines from Indian Ports.

The circulars outline the responsibilities of all main parties involved including the ship owner, ship, port facility and shipper. Here we will bring all the requirements together to assist members when heading to Indian Ports to load a Group A cargo.

Master / Ship / Ship Owner Responsibilities:

• All crew to be competent and qualified, proficient in English or the local language of the port of cargo handling.
• Ensure crew adequate in number to monitor cargo ops and support master as required by the vessel’s SMS.
• Conduct a vessel inspection as per IMO resolution A.866 (2) Guidance to ship’s crew and terminal personnel for bulk carrier inspections.
• Ensure bilge lines, sounding pipes or any other service pipes in the holds are in good condition in case they are in contact with cargo handling equipment during operations.
• Ensure deck equipment and associated safety features are in good working order.
• Confirm hatch covers and vents are weather tight and fully operable.
• Ensure any ship cranes or cargo handling is in good working order.
• Have an approved stability booklet / computer and comply with the requirements.
• Ensure hatch identification markings are clear and match those indicated in the loading sequence.
• Ensure hatch covers are of an adequate size and operation for the intended loading method.
• Make the required declaration to the relevant Mercantile Marine Department at the port as per section C (2) of circular No2 of 2017.
• Ensure you comply with the IMSBC code at all times.
• Ensure that prior to loading all shipper’s cargo declarations and documentation is received and reviewed.
• Cargo plans should where possible fill holds as full as practicable.
• Ensure that the angle of repose and trimming requirements are discussed with the terminal / shipper and agreed and understood.
• Ensure that ship and terminal understand actions in the event of rain. The ship’s agent should confirm to the MMD that loading will not be undertaken in rain, the master should stop loading and close all hatches in the event of rain.
• Conduct regular can tests as per section 8 of the code. This can be done alongside the speedy moisture test that is often used locally. This must be done at regular intervals throughout loading.
• The master should not hesitate to stop cargo operations if there are any potential hazards or issues, exercising their overriding authority as per 34-1 of SOLAS Chapter V.

Shippers Responsibilities

• Representatively sample and test the cargo to determine the TML and moisture content. As per the IMSBC code, this is the shipper’s responsibility alone.
• Ensure all testing is conducted in an accredited laboratory.
• Declare that the samples taken are indeed representative of the cargo to be loaded.
• The cargo must be properly declared, and the documentation presented to the master is good time prior to loading. This should include the transportable moisture limit, moisture content, angle of repose and stowage factor.
• Allow the master or their representative access to the stockpile to witness sampling and check the condition of the stockpile. The stockpile should be covered and protected from the environment and have an adequate drainage system in place.

NorthStandard Guidance

The local circulars are clear that it is the shipper’s responsibility to sample and test the cargo, a requirement in line with the content of the IMSBC code.

It does however require the ship to consider their P&I club guidance when risk assessing the carriage of the group A cargoes. Given the risks involved in the carriage of any group A cargo, NorthStandard recommends members always appoint an independent surveyor, this surveyor should:

• Attend the stockpile and witness the shippers sampling for moisture content testing. They should also check the general condition of the stockpile; has it been covered? What is the size of the stockpile? What is the general condition of the cargo?
• Assist the master in checks to the cargo documentation, ensure they are in line with both the IMSBC code and local requirements.
• Check the general condition of the vessel is in line with circular requirements.
• Provide up to date weather forecasts to the master frequently.
• Assist the master with can testing the cargo at regular intervals. Many local surveyors in the region use speedy moisture tests as well, this is fine but does not alleviate the requirement to conduct regular can tests throughout loading as per section 8 of the IMSBC code.
• Provide members and the club with regular feedback reports throughout loading.
• Assist the master to ensure all local requirements imposed on owners are met.

Members are encouraged to familiarise themselves with the IMSBC code requirements and the local requirements outlined in the two linked circulars: MS Notice 31-2009 and MS Notice 34-2009

Other useful information can be found here:

• Liquefaction