London Club noted that slots on container ships have at times become scarce and increasingly expensive. For this reason, operators with bulk carriers have been approached to carry containerised goods in their bulk carrier cargo holds or above deck.
London Club explains that it should be kept in mind that bulk carriers are in the most part not designed for the carriage of containers. This is particularly the case for hopper hold bulk carriers where there is no prospect of any lashing and securing points being in place.
The situation is made even more difficult by the presence of the bottom hopper tanks, which means that containers cannot be stowed up to the edge of the hold
Furthermore, carriage of containers above deck, including carriage on top of hatch covers, can also be problematic in that the customary deck sockets will not be present.
Indeed, the hatch covers may not be suitable to carry such a load while maintaining the design compression and weathertight integrity of the hatch cover system in a seaway. This could make the defence of any resulting water ingress claims difficult.
It is highly unlikely that the Ship’s Cargo Securing Manual will have any instructions on the carriage of ISO containers. In these circumstances, suitable lashing eyes and dunnage should be fitted to meet the requirements of CSS Code, along with an assessment of tank top loading and hatch cover loading, depending on the planned stowage
What is more, London Club mentions that it is vital that the stowage plan meets the requirements of the CSS Code, and a detailed lashing and securing plan is drawn up to ensure that the method and lashing equipment used is compliant.
It is also recommended that expert advice is sought at the planning stage and that suitable assessment of the physical modifications inside the hold/on deck are verified as being capable of withstanding the securing loads that are prescribed for the containers to be loaded.
Moreover, to remain seaworthy at the beginning of the voyage under the provisions of The Hague Visby Rules, the carrier must show verification of compliance with the CSS Code and show that the weathertight integrity of the hatch cover system was not compromised by the stowage as planned.
In all cases whether by design or by modification, the ship must be Classed for the Carriage of Containers and therefore the earliest involvement of the Ship’s Classification Society is recommended