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.