A practical review before loading solid bulk cargoes
The cargo declaration is the starting point for safe carriage, not a substitute for scrutiny. A document may be signed, complete in appearance and accompanied by a safety data sheet, yet still identify the wrong Bulk Cargo Shipping Name, omit a decisive test result or describe hazards that do not fit the declared cargo group.
Recent enquiries received by the Club show the same difficulty arising in different forms: pellets described only by a commercial name; mineral cargoes assigned to the less onerous schedule without the supporting particle-size or test information; and emerging biomass cargoes presented as Group C despite having no individual schedule in the International Maritime Solid Bulk Cargoes Code. The lesson is not that the Master must become a chemist or reclassify the cargo. It is that inconsistencies should be identified and resolved before loading begins.
The declaration has a safety function
SOLAS chapter VI and section 4 of the IMSBC Code require the shipper to provide the Master or the Master’s representative with appropriate written cargo information sufficiently in advance of loading. This is intended to allow the ship to plan safe stowage, loading, carriage and discharge, rather than to regularise the position after operations have started.
For a listed cargo, the declaration should use the correct BCSN and state the cargo group, applicable IMO class and UN number, quantity, stowage factor, bulk density, trimming information and other relevant properties. Depending on the cargo, this may include certificates of moisture content and transportable moisture limit, the potential to generate toxic or flammable gas, oxygen depletion, self-heating, corrosiveness, flammability, reaction with water and MARPOL Annex V status.
The Code also makes an important distinction between identification and description. A trade name or commercial label may be added, but it should not displace the BCSN where the cargo is listed. Correct identification links the cargo to the relevant schedule and therefore to the precautions, carriage conditions and emergency measures that follow from it.
Why apparently complete documents can still be unreliable
The most difficult declarations are not always those with an obvious blank. They are often documents in which the individual entries do not agree with one another. A Group C box may be ticked while the accompanying safety data sheet refers to self-heating, oxygen depletion, or toxic gas generation. A broad mineral description may be used even though the particle-size points to a Group A fines schedule. A document may quote extensive previous carriage experience but provide no competent authority authorisation for an unlisted cargo.
Group C should not be treated as shorthand for ‘harmless’. It means that the cargo is neither liable to liquefy as a Group A cargo nor possesses the chemical hazards that place a cargo in Group B. Group C cargoes may still present operational risks, including cargo shift, high density, dust, contamination, hold-cleaning difficulty or other cargo-specific concerns. More importantly, the declaration itself cannot establish Group C status where the underlying characteristics point to Group A or B hazards.
Recurring examples from the Code:
- Coal. Coal is to be classified as Group A and B unless it is classified as Group B only by a test determined by the appropriate authority or meets both particle-size criteria in the schedule: not more than 10% by weight below 1 mm and not more than 50% below 10 mm. A declaration stating only ‘COAL, Group B’ therefore needs supporting evidence. Without it, the omission changes more than the wording: it may remove the moisture and TML controls intended to address liquefaction.
- Bauxite and iron ore fines. The commercial names ‘bauxite’ and ‘iron ore’ are not sufficient on their own. The Code uses particle-size thresholds to distinguish BAUXITE from BAUXITE FINES and IRON ORE from IRON ORE FINES. The fines schedules are classified as Group A and engage moisture-content and TML requirements, subject to the specific exceptions and supporting declarations or certificates stated in the relevant schedules. The particle size distribution and any claimed exception should therefore be documented, not assumed from the trade description or visual appearance.
- Direct reduced iron. A description such as ‘DRI’, ‘HBI’, ‘pellets’ or ‘fines’ may conceal materially different cargoes. The Code separates hot-moulded briquettes, lumps or pellets and cold-moulded briquettes, dry by-product fines, and aged by-product fines with specified moisture into different DRI schedules. Form, density, particle size, production method, ageing and moisture can determine the applicable schedule and controls. The declaration should identify the exact BCSN and provide the schedule-specific information rather than rely on an umbrella commercial name.
- Wood pellets. The Code contains different schedules depending on whether additives or binders are present. A declaration that says only ‘wood pellets’ does not necessarily provide enough information to select the correct schedule. The shipper should identify the applicable BCSN and confirm the composition. The distinction matters because wood pellets can deplete oxygen and generate carbon monoxide and carbon dioxide, while the applicable schedule governs the required precautions. A generic safety data sheet should not be allowed to obscure the schedule-specific requirements.
- Unlisted biomass or agricultural residues. A shipper may provide a detailed declaration, an SDS, proposed carriage precautions and a record of uneventful previous voyages. These documents may be useful evidence, but they do not replace the process in section 1.3 when the cargo is not listed in appendix 1. Nor can a charterer’s or shipper’s commercial assurance that the cargo is Group C replace the competent authority’s assessment and certificate.
When section 1.3 of IMSBC Code applies
If a solid cargo is proposed for carriage in bulk and is not listed in appendix 1, the shipper must provide its characteristics and properties to the competent authority at the port of loading before loading. That authority assesses whether the cargo is acceptable for safe shipment.
If the cargo may present Group A or Group B hazards, advice is to be sought from the competent authorities at the port of discharge and of the Flag State; If the assessment is that the cargo presents no specific transportation hazards, the loading-port competent authority may authorize carriage and advise the other two authorities. In either case, the loading-port competent authority must provide the Master with a certificate stating the cargo characteristics and the conditions for its carriage and handling.
This is an authorisation process, not simply another form for the shipper to complete. A tentative BCSN, a declaration marked Group C or wording in an SDS that section 1.3 ‘applies’ does not demonstrate that the required assessment has actually taken place. The Master should receive the competent-authority certificate and check that its description, properties and conditions match the actual consignment and intended voyage.
Warning signs that justify stopping for clarification
- No exact BCSN. The declaration relies on a trade name, product code or broad description that does not match an individual schedule.
- The documents tell different stories. The declaration, SDS, laboratory certificate, contract description and terminal information differ on composition, particle size, production method or hazards.
- Group C conflicts with the stated properties. The papers refer to self-heating, oxygen depletion, toxic or flammable gases, corrosiveness, reaction with water or possible liquefaction, without explaining how the Group C conclusion was reached.
- The test report is detached from the shipment. The sample date, sampling method, laboratory, batch, stockpile or cargo quantity is unclear, or the result is not demonstrably representative of the cargo offered for loading.
- A favourable result is being used too broadly. One test is relied upon to override classification criteria based on composition, production method or another mandatory parameter.
- Past voyages are treated as proof. An incident-free record may be relevant operational experience, but it does not establish the properties of the present consignment or replace the Code’s certification and authorisation requirements.
- The cargo is unlisted but no section 1.3 certificate is produced. A shipper-prepared declaration or SDS is offered in its place.
- Material information arrives late. The cargo description, certificates or precautions change after the stowage plan is prepared or loading has begun.
A practical review before loading
| Check | What the review should establish |
| Identify the cargo precisely | Match the declared name against the BCSN in the applicable edition of the IMSBC Code. Check synonyms, commercial descriptions and physical form rather than relying on a keyword match. |
| Confirm the applicable Code position | At the time of writing, Amendment 07-23 is mandatory. Amendment 08-25 may be applied voluntarily from 1 January 2026 and becomes mandatory on 1 January 2027. Operators should confirm the position adopted by the vessel’s Administration and the competent authorities concerned. |
| Read across the complete document set | Compare the declaration with the SDS, certificates, test reports, product specification, loading instructions and any section 1.3 authorisation. Do not review each document in isolation. |
| Test the internal logic | Ask whether the group, class, UN number, production method, composition, moisture, particle size and stated hazards are mutually consistent and lead to the selected schedule. |
| Check recency and representativeness | Confirm what was sampled, when, where, by whom and under which approved procedure. For Group A cargoes, apply the Code’s detailed requirements for TML, moisture certification, sampling and rain or water exposure. |
| Verify vessel capability | Confirm that the vessel’s certification, equipment and procedures support the declared cargo and schedule, including gas detection, ventilation arrangements, fire protection, segregation and safe enclosed-space controls where applicable. |
| Resolve discrepancies in writing | Seek clarification and corrected documents from the shipper. Where the cargo’s identity or classification remains uncertain, involve the relevant competent authority, Flag State, Class and a suitably qualified cargo expert as appropriate. |
| Do not allow the loading schedule to decide the safety question | If the information is insufficient or contradictory, loading should not commence, or should be suspended, until the position is satisfactorily resolved. |
The Master is a gatekeeper, not the classifier
The Master and crew cannot be expected to reproduce laboratory work or determine a novel cargo’s classification onboard. Their role is to make a reasoned check that the required information has been provided, that the documents are internally consistent and that the proposed carriage complies with the applicable schedule or competent authority conditions.
Early challenge is important. Once loading has started, commercial pressure increases, samples may no longer represent the entire consignment and corrective options narrow. A short pause to reconcile the documents can prevent a much larger problem involving fire, liquefaction, harmful atmospheres, cargo damage, delay or an unsafe emergency response.
The safest question is therefore not simply, ‘Has a cargo declaration been received?’ It is: ‘Does the declaration, supported by the underlying evidence, accurately identify the cargo we are about to load?’
References and further reading
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