The Swedish Club informs that by 1 January 2019 there will be a supplementary IMSCB (International Maritime Solid Bulk Cargoes Code) for coal. Namely, coal will not only be categorized as a chemical hazard cargo (Group B) but will also fall into Group A (liquefaction).
For a Group A cargo TML and FMP always need to be established by the shipper and provided to the vessel according with the Code before loading.
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However, if the particles are large enough to prevent liquefaction, then they will not be a Group A cargo. Nevertheless, it may be difficult to get within the exception. In fact, no more than 10% can be less than 1 mm and no more than 50% can be less than 10 mm. For this reason, both criteria must be met.
Additionally, without a cargo certificate showing particle distribution that meets the criteria, then operators would return to the starting point of coal automatically being a Group A cargo, requiring TML and FMP to be established for safe loading.
This means that the ship should:
- Either receive (i) a cargo certificate that meets the criteria for the exception; or
- Be handed a ‘TML certificate’.
Without one of the two documents, loading cannot begin. In addition to time being lost, ships could stay on-hire, and the Time Charterers could claim against Voyage Charterers and they will in turn claim against Shippers.
In order to testing coal for TML, the use of a modified Proctor/Fagerberg procedure is needed.
