IMO MARPOL GHS

International Maritime Organisation MARPOL Annex V and IMSBC Code Developments

In 2012, the IMO adopted new guidance to cover the development of more systematic hazard assessments for solid bulk cargoes. The two relevant regulations that suppliers/shippers of solid bulk materials need to comply with are, firstly, MARPOL Annex V, designed to prevent pollution of the marine environment, and secondly, the International Maritime Solid Bulk Cargoes Code (IMSBC), set up to ensure the safe transport of solid bulk cargoes.

The consequences of this work are that, firstly, residues of cargoes meeting certain criteria can no longer be discharged into the sea from 1st January 2013*. Dry residues and/or wash water have to be discharged at “adequate port reception facilities”. Secondly, if no such facilities are available, the shipmaster can refuse to ship the cargo.

Shippers have to declare whether or not their cargoes are harmful to the marine environment. Such declarations have to be included in the shipping documents and the competent authority of the port state of loading has to be notified. Suppliers, customers and shipping companies need to work together to assess whether adequate port reception facilities are available at the port of unloading, or at the next port of loading.

In December 2012, ECI completed a project to help the global copper industry (producers, traders and customers) to meet these obligations. Specifically, the project assessed how to appropriately classify bulk cargoes, such as copper concentrates, matte, slags and scrap, and how to then identify which solid bulk cargoes need to be classified as “Harmful to the Marine Environment” under MARPOL Annex V from 1st January 2013 onwards and which solid cargoes meet the IMSBC-MHB criteria from 1st January 2015 onwards.

A 2-page IMO guidance note on provisional classifications is available here.

* At its meeting of May 16th 2013, the IMO’s Marine Environment Protection Committee agreed that, until 31st December 2015, cargo hold wash water from holds previously containing solid bulk cargoes, classified as HME, may be discharged outside special areas, providing:

  • the master determines that there are no adequate reception facilities either at the receiving terminal or at the next port of call;
  • the ship is en route and as far as practicable from the nearest land, but not less than 12 nautical miles;
    before washing, solid bulk cargo residue is removed (and bagged for discharge ashore) as far as practicable and holds are swept;
  • filters are used in the bilge wells to collect any remaining solid particles and minimize solid residue discharge; and
  • the discharge is recorded in the Garbage Record Book and the flag State is notified utilizing the Revised Consolidated Format for Reporting Alleged Inadequacies of Port Reception Facilities (MEPC.1/Circ.469/Rev.2). 

Click here for the 2-page IMO communiqué on this compliance extension.