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.
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.