Environmentally Hazardous Substances
A recent submission by the Australian Maritime Safety Authority (AMSA) to the IMO has highlighted that some metal sulphide concentrates can be classified as Environmentally Hazardous Substances (EHS) UN 3077 under the IMDG code, and that such classification is missing from the IMSBC Code at present.
AMSA have issued an M-Notice explaining their position on such cargoes.
Unfortunately Members have experienced difficulties in gaining approval for the carriage of cargoes described as UN3077. UN3077 cargoes will not be listed on the document of compliance due to their absence from the IMSBC Code.
Despite the attached M-Notice appearing to suggest that carriage as per the nearest IMSBC Code schedule should be sufficient in the interim, approval for carriage from authorities has proved difficult to obtain.
Significant delays to the vessel can occur whilst approval is sought from the authorities locally, those of the flag state and those at the port of discharge. Additionally, the authorities may not all see the situation in the same light which has the potential for further lengthy delays to occur.
Members should check in advance with charterers which cargoes they intend for the vessel if directed to Australian ports. If the cargo is to be declared UN3077 then flag state should be contacted well in advance of arrival in Australia in order to seek the necessary changes to the vessels document of compliance, or approval for carriage.
To view the recent submission click here
Source: North P&I Club