The preparation and maintenance of cargo holds are very important for the bulk cargo trade. As Kate Richards, Senior Solicitor (FD&D), North Club explains, “when holds are not ready for their intended cargo, a number of different types of claim may arise”.
Taking a look at the risks associated with bulk cargo trade, Ms. Richards looks at some of the most frequent topics, aiming to help operators avoid them and dealing better with these types of dispute.
Standards of Hold Cleanliness
Although not standardised across jurisdictions, the standards are broadly as follows:
#1 Hospital Clean
This is the most stringent. This requires all hold surfaces to have 100% intact coatings.
#2 Grain Clean
- The holds must be clean from previous cargo residue, odours, insects, loose rust scale and paint flakes.
- Atmospheric rusting of exposed steel is generally accepted.
- Prior to loading, holds must be clean-swept, washed down with fresh water, dried and well-ventilated.
#3 Normal Clean
The holds must be swept to remove residues of the previous cargo, washed down and ready to receive a similar cargo.
#4 Shovel Clean
The holds do not require washing but should be swept down.
Disposal of cargo residues and excess cargo
Continuing, Ms. Richards explains that any excess cargo, cargo residues, washwater and cleaning products must be disposed of in accordance with MARPOL and local regulations.
A practical consideration is how these are disposed. Although the technical considerations are outside the scope of this article, factors to consider are:
- Is there a cargo residue clause in the charterparty?
- Who is responsible for disposal?
- Is there any indication on the cargo declaration that the cargo is harmful?
- Are any of the cleaning agents used in the hold harmful?
- Are there any disposal restrictions in port (such as whether the vessel in a MARPOL Special Area)?
- Does any wash water need to be disposed of in a reception facility?
- Does the vessel require a garbage/residue management plan?
