Fourth session of the IMO’s Sub-Committee on Carriage of Cargoes and Containers (CCC 4) 11 - 15 September 2017

ICS Brief

ITEM 1: PROVISIONAL AGENDA

1 PROVISIONAL AGENDA Secretariat

1/1 ADOPTION OF THE AGENDA Secretariat

1/2 Arrangements for working and drafting groups at CCC 4

Secretariat

The Chair of the Sub-Committee proposes that the following working groups be established at this session:

1.Working Group on Amendments to the IGF Code and Development of Guidelines for Low-flashpoint Fuels (agenda items 3 and 7 (IGF Code related interpretations));

2.Working Group on Suitability of High Manganese Austenitic Steel for Cryogenic Service (agenda item 4).The establishment of this working group will depend on discussion in Plenary; and

3.Working Group on IMSBC Code matters (agenda item 5). The Working Group on IMSBC Code matters, if established, will only be released after all documents under agenda item 5 have been considered in Plenary.

Drafting group(s) may also be established during the session, as necessary.

The Sub-Committee will consider the proposed arrangements and take action, as appropriate.

It will be appreciated if Members attending the meeting advise the secretariat of the working groups that they plan to attend.

Members attending the meeting are invited to raise any concerns arising, either with a member of the secretariat or at the ICS bench in plenary.

ITEM 2: DECISIONS OF OTHER IMO BODIES

The Sub-Committee will be informed of relevant decisions made, and actions taken, by other bodies of the Organization and will take action, as appropriate, under the relevant agenda items.

2 DECISIONS OF OTHER IMO BODIES Secretariat

The Secretariat provides the outcome of MEPC 70 and MSC 97 with respect to the work of the Sub-Committee.

2/1 DECISIONS OF OTHER IMO BODIES Secretariat

The Secretariat provides the decisions made by MSC 98 relevant to the work of the Sub-Committee.

2/2 DECISIONS OF OTHER IMO BODIES Secretariat

The Secretariat provides the decisions made by MEPC 71 and C 118 relevant to the work of the Sub-Committee.

ITEM 3: AMENDMENTS TO THE IGF CODE AND DEVELOPMENT OF GUIDELINES FOR LOW-FLASHPOINT FUELS

The Sub-Committee will consider the report of the Correspondence Group on Amendments to the IGF Code and Development of Guidelines for Low-flashpoint Fuels (CCC 4/3), together with any other relevant documents submitted to this session. A working group may be established to deal with the matter

Papers:

3 Report of the Correspondence Group Sweden

Sweden provides the correspondence group report on the Development of Technical Provisions for the Safety of Ships using Low-flashpoint Fuels.The report contains the following salient developments for consideration by the Sub-Committee:

With regards to finalizing the draft amendments to the IGF code regarding fuel cells:

A draft generic definition for fuel reformers;

The exclusion of electrical power conditioning from the definition of fuel cell power installation. The inclusion of buffer/intermediate tanks in the definition of fuel cell power installation and three new definitions for synthesis gas, oxidation gas and air purification is left for future consideration;

The draft introductory text for the new Part E which addresses the specific requirements (e.g. fuel storage) for fuel cell installations on which Part A is applicable;

An updated version of the generic fuel cell system diagram;

The amendments to risk assessment requirements specific to fuel cell systems needs further consideration;

The proposal to allow dedicated fuel cell power systems enclosures within conventional machinery spaces needs further consideration;

Both safety concepts for arrangements of fuel cell spaces (i.e. "gas safe fuel cell space" and "Emergency Shutdown (ESD)-protected fuel cell space") could be suitable for fuel cell spaces and, therefore, they should both be allowed;

Monitoring requirements for fuel cell systems and provisions for hydrogen and hydrogen-rich piping need further consideration; and

The draft new text of the proposed amendments to the IGF Code containing the abovementioned considerations.

With regards to further development of draft technical provisions for the safety of ships using methyl/ethyl alcohol as fuel:

New definitions of ethyl and methyl alcohol to address the fact that no commercial product would be 100% pure;

Replacing the term “interbarrier space” and the development of definitions for the new terms: Cofferdam, Secondary barrier, spaces not normally entered and units not normally accessed;

The proposals to include the ESD safety concept for machinery spaces could not be finalized and needs further consideration;

Further consideration needed to decide if provisions for inerting should be left to the designer and if the quantity of inert gas should be based on the quantity of fuel on board;

With regard to non-destructive testing of piping, butt welding shall be subject to 100% non-destructive testing, while sleeve welds shall be subject to at least 10% liquid penetrant testing (PT) or magnetic particle testing (MT);

Recommendation of the group is to request the ISO to develop a standard for methyl/ethyl alcohol fuel couplings;

Toxic properties of methyl alcohol need to be further considered in the context of the draft technical provisions for safety of ships using methyl/ethyl alcohol as fuel; and

Development of guidance for bunkering should be further discussed at the next session in a working group, if established.

The group also identified various safety provisions of the draft technical provisions for the safety of ships using methyl/ethyl alcohol as fuel to be forwarded to PPR, SDC and SSE Sub-Committees.

3/1 Proposed amendments to the IGF Code IACS

IACS provides the following proposals for amendments to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code):

1. Paragraph 9.5.1 is amended to clarify that the requirement for a ventilated duct or a double wall piping system is only applicable for fuel in the gaseous state. New paragraphs have also been proposed to clarify application of secondary enclosure requirements for fuel in the liquefied state while exempting bunkering lines on open deck from this requirement. This exemption is proposed on the basis that the bunkering lines do not permanently contain liquefied gas and the

bunkering operation is a controlled and monitored operation.

2. Fuel preparation rooms have been included in paragraph 11.3 on Regulations for fire protection. The requirement for a cofferdam or A-60 insulation between fuel containment systems is removed and for a type C tank located directly above machinery spaces of category A or other rooms with high fire risk, a cofferdam is made mandatory.

3. Paragraph 10.3.1 on the requirements for the exhaust system of internal combustion engines of piston type to have explosion relief ventilation is amended to include the provision that explosion relief valves should be fitted to the exhaust systems of gas and DF engines unless designed to withstand the worst case overpressure or justified by the safety concept for the engine.

4. The allowance for storage tanks having a second system for pressure maintenance to have a higher loading limit than calculated using the reference temperature is removed from paragraph 6.8.2.

At CCC 3, IACS submitted draft Unified Interpretations (UIs) for the IGF Code in document CCC 3/10/1. For paragraphs 6.3.10, 9.2.3 and 11.3.3 of the IGF Code. In response to this submission, the CCC 3 Sub-Committee had confirmed that interested Member States and international organizations could propose amendments relevant to the provisions in these paragraphs of the IGF Code, for consideration by the Sub-Committee at its next session. IACS has submitted this proposal in response to this invitation.

With regards to point 1: IACS proposes the removal of the requirement for ventilated ducts for liquefied fuels and the acceptance of secondary enclosures instead. This is based on practical challenges of implementing the ventilated ducts like icing and material selection. ICS supports this goal based approach to leakage protection of pipes provided that a leakage detection system is also incorporated in all cases.

With regards to point 4: IACS provides the same conclusion and its justification in the paper CCC 4/7. Section on CCC 4/7 contains more details along with ICS comments.

ICS would like to thank IACS for the proposed amendments to the IGF code regarding the use of Natural Gas as fuel.

Comments on Point 1: With respect to the suggested amendments to paragraph 9.5.1 regarding the provisions for fuel distribution outside of machinery space; While ICS welcomes the goal based approach to achieve protection measures for pipes carrying liquefied fuels, we have some concern over removing the requirement for leak detection. Detection should be an integral safety feature in any fuel leak containment system. ICS, is therefore unable to support this proposal.

3/2 Proposed amendments and corrections to the IGF Code

China

Along with corrections to a paragraph numbering error, China proposes the following amendments to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code):

1. The definition of the value fv, which is used to determine the acceptable location of fuel tanks is changed to refer to the probability that any damage is extending vertically above the lowermost boundary of the fuel tank. The previous definition meant that fvreferred to the probability that the damage does not extend.

2. Paragraph 15.8.1.3 on the requirement to have permanently installed gas detectors fitted in machinery spaces containing gas piping, gas equipment or gas consumers should be changed to exempt gas safe machinery spaces from the requirement.

Comments on point 2: ICS thanks China for the submission. As highlighted in the proposal, a gas safe machinery space is designed in such a way that a single failure cannot lead to release of fuel gas into the machinery space. ICS considers that there should be measures to detect possible dangerous situations of multiple failures in a gas safe space and the use of gas detectors achieve this goal. ICS further considers that this requirement is neither onerous nor extortionate and is unable to support this proposal.

3/3 Proposed structure of the draft fuel cell section of the IGF Code

Marshall Islands

The Marshall Islands proposes structural additions to the proposed part E of the IGF code on fuel cells, as developed by the Correspondence Group, in order to accommodate various types of Fuel Cell Power Installations.

Through this document the Marshall Islands propose changing the overall structure of the code to clearly identify that:

1. Some systems do not use "hydrogen rich fuel";

2. Some systems do not require "reforming" process; and

3. Systems in a "gas-tight enclosure" may have unique arrangements for ventilation, insulation and entry, which have proven safety records.

The proposed amendments are based on using 375 kW as a threshold for differentiating fuel cell systems within a gas-tight enclosure in order to align with the definition of a category A machinery space.

ICS thanks the Marshall Islands for this submission. The 375KW threshold in SOLAS, that is referenced as justification for a similar

provision in the IGF code, applies only to internal combustion machinery used for purposes other than main propulsion. Engines used for propulsion, boilers and other oil fuel units do not have this exemption. There should thus be valid technical justification for this threshold to be applicable to fuel cells. Notwithstanding this, the submission raises the valid issue of addressing the fire safety provisions for fuel cell power system in sealed containers. The proposed amendments thus require careful consideration by the working group on amendments to the IGF Code.

3/4 Boundaries for methyl and ethyl alcohol-fuelled ships

Germany

Germany proposes modifications to the draft technical provisions for the safety of ships using methyl/ethyl alcohol as fuel with regards to structural fire protection boundaries.

The proposed document provides a visual interpretation of the text in reference to boundaries between different spaces and highlights some aspects for the attention of the CG.In reference to paragraphs 39, 40 and 43 of the report of the CG (CCC 4/3) dealing with the new definitions and spaces of "cofferdam", "secondary barrier", "spaces not normally entered" and "units not normally accessed", and for the purpose of illustration and further discussion of the requirements on boundaries and arrangement, a drawing was prepared to illustrate the different potential boundary configurations required below deck for a methyl/ethyl alcohol-fuelled ship. Germany proposes to align the draft technical provisions more closely with the concept of SOLAS regulation II-2/9 and to allow unambiguous assigning of fire risk categories to the new spaces. Related textual changes in the draft provisions are proposed.

3/5 Use of low-flashpoint diesel Germany

Germany proposes a course of action with respect to the use of low-flashpoint diesel in the context of amending the IGF Code.

In an attempt to establish whether there is a particular risk related to low-flashpoint diesel,Germany presented the findings of a study in CCC 4/INF.11. One of the conclusions of this study was that the flashpoint criterion is not commonly used in other industry sectors. Hence, it may be necessary to develop a further study in the format of a formal safety assessment.

Germany proposes that the study results and conclusions be debated within the CCC 4 Sub-Committee with the objective to clarify where further information would be needed within the proposed Formal Safety Assessment (FSA) study to be submitted to the Sub-Committee at a later session.

This document attempts to reopen the discussions on a probable SOLAS amendment to the minimum allowed flash point for marine fuels. CCC 4/3/INF.7 is submitted as a supporting document which contains the result of

study conducted for Germany.

MSC 98 had emphasized that the requirement in SOLAS chapter II-2 for the flashpoint ofoil fuel remained at 60ºC for ships that did not comply with the IGF Code. The Committee had also reiterated that the use of oil fuel with a flashpoint below 60ºC was limited toships that complied with the IGF Code, except as otherwise permitted inSOLAS regulation II-2/4.2.1.

In May 1966, MSC 13, after considering the accident reports related to engine room fires on MS Skaubryn and the Viking Princess, instructed the Sub-Committee on Fire Protection (FP) to devote special attention to the fire protection and extinction in the engine room in future passenger ships. After considering more than 170 other ship fire casualty records the decision was made to increase the minimum flash point requirement to 60°C. A package of passenger ship fire safety requirements based on this flash point limit value was developed and, after extensive consideration by fire protection experts, accepted into SOLAS 1974. These requirements are an integral part of SOLAS today in the form of various fire safety regulations. FP 5 noted that any reduction in the minimum flash point requirement would necessitate a complete re-appraisal of all of these requirements. This is what is being achieved by the IGF code and thus any marine fuel with a flash point lower than 60ºC should follow a similar procedure.

The International Safety Guide for Oil Tankers and Terminals (ISGOTT) classifies liquids having a closed cup flash point of below 60ºC as volatile. The guide advises that “Since less stringent precautions are appropriate for non- volatile liquids, it is essential that under no circumstances is a liquid capable of giving a flammable gas/air mixture ever inadvertently included in the non-volatile category. Therefore, the dividing line must be chosen to make allowance for such factors as the misjudging of the temperature, inaccuracy in the flashpoint measurement and the possibility of minor contamination by more volatile materials. The closed cup flashpoint figure of 60ºC makes ample allowances for these factors.”

CCC 4/3/INF.7 contains the findings of the new study.

The following are ICS comments to the various findings of the study:

The study begins by pointing out the flash point requirements in those countries that have requirements below 60ºC. But, it ignores the position of those countries that have flash point requirements of equal to or greater than 60ºC e.g. Australia, Singapore, Sri Lanka, China and Norway. The risks associated with operating automobiles using very low flash point fuels are well known and there are documented cases of lives lost in explosions following collisions involving vehicles carrying such fuels.

Lower Explosive Point (LEP) is a more accurate representation of the temperature beyond which explosive vapours are produced. The study correctly identifies that LEP is lower than the Flash Point. In reality in

many cases the LEP is as much as 15K lower than the flash point. The practical difficulties in measuring the LEP is what made the flash point to become the accepted representation of the risk associated with vapour formation from volatile fuels. This should be in itself a proof to encourage the stringent application of the flash point limit as any more reduction would mean a reduction in the LEP and thus a significantly increase in explosion risk.

The study fails to highlight the fact that the suggested parameters of Upper Explosion Limit and Lower Explosion Limit are dependent on the volume of the compartment. By considering these factors, it is being suggested to consider engine rooms with live human beings as if they were working inside a cargo tank in an oil tanker.

Statements like “the formation of fuel vapours may be a rather theoretical risk in some cases”, shows how disjointed the study is from the actual operating conditions on a ship and a disregard for the risk assessment procedures on a ship which are based on sound theoretical principles.

It is suggested to design venting and inerting measures according to the evaporation rate of the fuel. This is already being done with low flash point fuels as part of the IGF code and thus gives further credibility to the fact that Low Flash Point Diesel should only be used as per guidance to be developed as part of the IGF code.

The conclusions of the study using a fuel tank model was developed using the below diagram representing evaporation rate vs time.

Contrary to what is being inferred, the diagram above indicates that the evaporation rate for the lower flash point fuel is considerably higher (approximately 4 times that of the higher flash point fuel) and results in a richer (higher explosive vapour concentration) mixture inside the tank.

If the evaporation rate was considered as a factor for assessing the risk associated with a fuel leak in the engine room as proposed by the study, it would mean that just because the lower flash point fuel has an

“evaporation rate” similar to a higher flash point fuel (which would not have started evaporating at the same temperature), it is deemed to be of similar safety standard. Effectively, this infers thatthe presence of explosive vapours is acceptable provided that these flammable vapours are vented off quickly enough. ICS is unable to support this argument and considers it to be based on unacceptable principles.

This intervention is necessarily long because CCC 4/INF 11 did not become available on IMODOCs until the 21July 2017; the deadline for submission of comment papers.

ICS thanks Germany for these submissions related to low flash point diesel fuels. ICS is concerned that this submission would reopen discussions regarding the lowering of the minimum flash point requirements in SOLAS. ICS recalls that MSC 98 had emphasized that the requirement in SOLAS chapter II-2 for the flashpoint of oil fuel remained at 60ºC for ships that did not comply with the IGF Code.

With regards to the findings of the so-called new study on this issue, ICS has the following comments:

There are a significant number of countries where the required minimum flash point for automobile fuels is greater than or equal to 60°C. e.g. Australia, Singapore, China, Norway. In many of those countries listed in the submission, where flash point limits are lower than 60, there are well documented cases of vehicle collisions causing explosions in ruptured fuel tanks containing low flash point fuels resulting in multiple fatalities. This is contrary to the study paper suggestions when it says that these are theoretical risks.

ICS agrees that the Lower Explosive Point (LEP) is a more accurate parameter to consider when analysing risks associated with volatile fuels. However, the practical difficulties in measuring LEP means that Flash point provides a measurable and dependable approximate safety indication.

It is proposed to consider upper and lower explosive limits and to design venting and inerting systems as per the quantity of explosive gases present. This would result in ship’s personnel being expected to work in an atmosphere the same as is found in a cargo tank of an oil tanker. This is then justified as being safe because any explosive vapours generated by these low flash point fuels at ambient temperature would be vented off continuously.

ICS considers that for non IGF ships operating on residual or distillate fuel oil, the initial formation of explosive vapours must be prevented and even the lowest concentration of explosive vapours in a habitable space should be deemed dangerous and

unacceptable. Flash point of a fuel is thus the only measurable, pragmatic and time tested parameter which can determine if fuel handling on board is safe or unsafe.

ICS would like to highlight an incorrect interpretation of data obtained through the study. Even though the graph plotted from the fuel tank study shows approximately 4 times more evaporation rate for the lower flash point fuel, which would result in a 4 times higher explosive vapour concentrationinside the tank, the study states that this will not cause additional or higher risks.

Other than advising an expected resultant increase in the availability of fuel oil that meets the new sulphur limits in 2020, the new study lacks justification for the use of low flash point fuels outside the provisions of the IGF code. ICS is unable to support this proposaland urges the Sub-Committee to very carefully consider the intention of this proposal that would have significant safety implication.

3/6/Rev.1

Comments on documents CCC 4/3/1 and CCC 4/7 relating to IGF Code fuel tank loading limit requirements

United States

The United States comments on proposals made by the International Association of Classification Societies (IACS) to amend the IGF Code, and create IACS Unified Interpretations to that section of the IGF Code containing requirements for fuel tank loading limits.

While the United States supports, in principle, the recommendation to amend the IGF Code, the United States does not fully agree with the rationale given, and therefore does not support the proposed IACS Unified Interpretation.

The proposed amendment in question relates to the IACS interpretation that that the last two sentences under paragraph 6.8.2 of the IGF Code are unclear and open for misinterpretation and the proposal to delete these sentences. The IACS views on this issue are explained in documents CCC 4/3/1 and CCC 4/7.

The United States raise the following issues with the rationale provided by IACS:

The ability of a fuel tank to satisfy the holding time requirement in paragraph 6.9.1.1, which is evaluated under normal operating conditions, should not be used as a factor in allowing the higher loading limit under paragraph 6.8.2 of the IGF Code to be applied. A fuel tank is required to meet the holding time requirement regardless of whether or not it is allowed a higher loading limit. The higher loadinglimit determination should only be based on the probability of the tank contents to be heated up owing to an external fire or insulation failure.

The proposed IACS Interpretation that paragraph 6.8.2 of the IGF Code should only apply where a fuel tank is "located in a fuel storage hold space separated from potential fire loads by cofferdams or surrounded by

ship spaces with no fire load" may be overly restrictive. While this may be one of the means of ensuring low probability that a fire would heat up the contents of a tank, it would prevent a tank located on open deck from applying the higher loading limit provisions of paragraph 6.8.2, regardless of whether the arrangement poses no credible risk of fire exposure to the tank.

In order to allow a higher loading limit under paragraph 6.8.1, the related risk assessment should address the probability of contents being heated up owing to an external fire and find that the probability is very small based on tank location and effectiveness of tank insulation.

ICS thanks the United States for the submission. ICS shares the concerns raised by the United States. The circumstances proposed by IACS where higher loading limit is allowed appeareither unnecessarily restrictive or are already a requirement for normal loading conditions.

3/INF.7

Supplemental edits to annex 1 to document CCC 4/3 regarding the proposed structure of the draft fuel cell section of the IGF Code

Marshall Islands

Marshall Islands presents the amendments to the draft IGF Code requirement on fuel cells that were proposed in paragraph 5 of and the annex to document CCC 4/3/3 in tracked changes.

This is an accompanying document to CCC 4/3/3.

3/INF.11

Use of low-flashpoint diesel Germany

Germany presents the findings of a study relating to the use of low-flashpoint diesel.

The study provides, inter alia, the following observations:

As implemented in the SOLAS convention today, the Flash Point (FP) limit may reduce the fuel flexibility of ship owners which may be needed to comply more easily with current and future challenges regarding the standards in sulphur regulations. A change of the flash point limit in the SOLAS convention may thus create a winning situation for all parties.

Flash point exceeds the Lower Explosive Point (LEP) and may serve as a rough first estimate of the LEP.

The critical concentration (LEL/UEL) range is wider at the auto ignition point.

Fuel data provides the indication that higher FP-Hydrocarbons have lower auto ignition temperatures.

The safety parameters Upper Explosive Limit/Upper Explosive Point and

Lower Explosive Limit/Lower Explosive Point provide a sound basis to evaluate, if an atmosphere at a certain temperature is explosive or not.

The flash point may be roughly correlated with the LEP. However, it’s qualification as the exclusive safety parameter is questionable since in praxis its values exceed those of the LEP.

In many cases the question of the critical time needed for an explosive mixture to form is as important as the finding, that formation is possible at all (which may be a rather theoretical risk in some cases).

Measures taken to prevent hazardous situations like venting or flushing with inert gases are designed according to the evaporation rate of the fuel.

Low flash point fuels tend to have slightly higher evaporation rates.

A simple model of the concentration in the headspace of a vented service tank is implemented to show that use of flashpoint in diesel fuels from 60°C to 52°C will not cause additional or higher risks, since the hazard of explosive atmospheres in the headspace is well known and appropriately handled.

This is an accompanying document to CCC4/3/5. Refer to section on CCC4/3/5 for comments on this paper.

3/INF.15

Study on the use of fuel cells in shipping European Commission

The European Commission provides the final results of a study commissioned by the European Maritime Safety Agency (EMSA) on the use of fuel cells in shipping. The study offers a technology review, summary of recent and ongoing research projects, regulatory gap analysis and a Safety Assessment on different concept fuel cell installations for both passenger and cargo ships.

The study is publicly available in EMSA's website, http://emsa.europa.eu/emsa-documents/latest/item/2921-emsa-study-on-the-use-of-fuel-cells-in-shipping.html

ITEM 4: SUITABILITY OF HIGH MANGANESE AUSTENITIC STEEL FOR CRYOGENIC SERVICE AND DEVELOPMENT OF ANY NECESSARY AMENDMENTS TO THE IGC CODE AND IGF CODE

The Sub-Committee will consider the report of the Correspondence Group on Suitability of High Manganese Austenitic Steel for Cryogenic Service (CCC 4/4), together with any other relevant documents submitted to this session. A working group may be established to deal with the matter.

Papers:

4 Report of the Correspondence Group Republic of Korea

Korea provides the correspondence group report on the suitability of high manganese austenitic steel for cryogenic service.

It is reported that the correspondence group has considered test and acceptance criteria for these steels, with many participants stating that internationally recognised material standards are also necessary. In general the correspondence group is supportive of accepting high manganese austenitic steels for cryogenic service with the questions raised being for the purposes of clarification and definition of standards and requirements rather than as objections.

Korea advises that the correspondence group did not manage to consider possible draft amendment to the IGC and IGF Codes as a result of time constraints.

As well as requesting that the sub-committee approves the report, the report also provides draft terms of reference for a working group to be established at this session. The proposed terms of reference are to:

further develop test acceptance criteria for high manganese austenitic steel for cryogenic service, re-examining the items in table 1 of annex 3 to document CCC 3/WP.4;

further consider the suitability of high manganese austenitic steel for cryogenic service, taking into account the information in annex 1 to document CCC 3/8, documents CCC 3/8/1 and CCC 3/J/7, and any relevant documents submitted to CCC 4;

develop draft amendments to the IGC and IGF Codes to include high manganese austenitic steel for cryogenic service, if appropriate.

The correspondence group has actively considered a wide range of potential issues associated with high manganese austenitic steels and ICS is satisfied with the degree of rigour and technical competence displayed by the group’s participants. Subject to further work to clarify outstanding issues and to confirm the actual performance of existing cryogenic tanks manufactured from the material, ICS supports in principle amending the IGC and IGF Codes to allow the use of high manganese austenitic steel for cryogenic service.

ICS is supportive of both the work of the correspondence group and the proposal to establish a working group to further consider the use of high manganese austenitic steel for cryogenic service. This could potentially reduce the cost of cryogenic tanks if compared to constructing tanks from high nickel content steels.

4/1 Observations on the comments from the participants of the Correspondence Group on Suitability of High Manganese Austenitic Steel for Cryogenic Service

Republic of Korea

Korea provides detailed observations to comments made by members of the correspondence group. These observations provide detailed and comprehensive responses to the comments made and will be provide useful assistance to the proposed working group.

The Korean observations address the comments made by participants of the correspondence group and provide detailed technical answers which address the majority, but not all, of the outstanding concerns raised. These observations should facilitate further progress on this agenda item by the proposed working group.

4/2 Comments on the report of the Correspondence Group on Suitability of High Manganese Austenitic Steel for Cryogenic Service

Japan

Japan considers the summation of comments in document CCC 4/4 to be insufficiently precise and offers further detailed technical comments. In particular, Japan proposes suspending further consideration of the suitability of high manganese austenitic steel for cryogenic service until its safety has been verified using the safety records of actual LNG, having noted that Korean companies have already manufactured cryogenic tanks from this material.

Japan draws attention to some points of concern which still need to be addressed and/or clarified. Verifying the properties of high manganese austenitic steel by reviewing the records of actual tanks would be beneficial and it would facilitate a speedy completion of this work if such records were to be made available to the working group. ICS does not, however, support suspending work on this agenda and considers that work should continue. The proposed working group should be allowed to continue working to progress resolution of outstanding concerns.

ICS thanks Japan for their submission. Japan has identified several concerns which require further clarification, in particular ICS supports the Japanese proposal that the safety records of actual tanks should be considered. However, we are confident, based on

the high standard of expertise evident in the correspondence group’s deliberations, that with further work and access to data for existing tanks, all of the outstanding concerns can be resolved and that work should continue on this important agenda item. Therefore whilst we support the Japanese call for safety records for actual tanks to be made available before finalising any proposed amendments to the IGC and IGF Codes, we cannot support the proposal to suspend work on this item.

4/3 Wide plate test results and draft amendments to the IGC and IGF Codes

Republic of Korea

Korea provides the necessary text to amend the IGC and IGF Codes to allow the use of high manganese austenitic steel for cryogenic tanks.The submission also provides a ductile fracture instability analysis report based on CTOD-R (crack-tip opening displacement – resistance) curves and wide plate tests. The results are provided so as to demonstrate that CTOD-R testing can be used to give safer design margins than if relying on wide plate testing. This report should be read in conjunction with CCC 4/Inf.3.

Korea has provided suitable text should the sub-committee agree to recommend inclusion of high manganese austenitic steel for cryogenic tanks within the IGC and IGF Codes. This is to be confirmed following further deliberation and consideration of outstanding concerns as highlighted by Japan in 4/2.

4/Inf.2 Answer Sheets from the Correspondence Group onSuitability of High Manganese Austenitic Steel for Cryogenic Service

Republic of Korea

Korea provides the answer sheets received by the correspondence group coordinator.

4/Inf.3 Updated Technical Information for High Manganese Austenitic Steel for Cryogenic Service

Republic of Korea

Korea provides detailed technical information on the physical properties of high manganese austenitic steel, to assist the sub-committees decision making process. This includes information on material testing requirements and acceptance criteria.

The comprehensive and detailed information provided should assist the proposed working group to resolve many of the outstanding concerns about the use of high manganese austenitic steel for cryogenic service.

4/Inf.17 Design and Fabrication of LNG Tanks Using High Manganese Austenitic Steel forCryogenic Service

Republic of Korea

Korea provides two case studies of using high manganese austenitic steel to design and construct cryogenic tanks, a prismatic type B tank and a type C independent tank. The submission includes a copy of the classification society design approval for the type B prismatic tank.

The information provided is useful in demonstrating the design, manufacturing and testing processes which have been used by Korean companies which have already used high manganese austenitic steel to construct cryogenic tanks. As such it should be useful in assisting the proposed working group to resolve outstanding concerns about the use of the material for cryogenic service.

ITEM 5: AMENDMENTS TO THE IMSBC CODE AND SUPPLEMENTS

The Sub-Committee will consider the report of the Editorial and Technical (E&T) Group at its twenty-sixth session (CCC 4/5) and any other relevant documents submitted under this agenda item. It is expected to instruct E&T 29 to prepare the draft amendments (05-19)to the IMSBC Code for consideration at CCC 5.

The Sub-Committee will also consider the report of the Correspondence Group on Evaluation of Properties of BAUXITE and revision of individual schedules for SEED CAKE (CCC 4/5/1). A working or drafting group may be established to deal with these matters.

Papers:

5 Report of the twenty-sixth session of the Editorial and Technical Group

Secretariat

The Secretariat provides the report of the E&T 26, which met from 12 to 16 September 2016 under the chairmanship of Ms.DanischaRamdat (Netherlands).

The Sub-Committee is invited to:(paragraph 6.1)

.1 note that the Group finalized the draft amendment 04-17 to the IMSBC Code for circulation in accordance with SOLAS article VIII, for adoption by MSC 98 (paragraph 3.21 and annex 1);

.2 note that the Group agreed to some consequential amendments to MSC.1/Circ.1395/Rev.2 on Lists of solid bulk cargoes for which a fixed gas fire-extinguishing system may be exempted or for which a fixed gas fire-extinguishing system is ineffective and requested the Secretariat to prepare the draft MSC.1/Circ.1395/Rev.3 for submission to MSC 98 for approval (paragraph 3.22 and annex 2);

.3 note the Group's invitation to interested Member States and international organizations to submit proposals on a separate individual schedule for FISHMEAL Group C (paragraph 3.4 and annex 2);

.4 endorse the Group’s view that additional consideration is needed with regard to the draft new individual schedule for Palm kernel shells, and note Group's invitation to interested Member States and international organizations to submit new proposals to CCC 4 (paragraphs 3.27 to 3.30 and annex 3);

.5 note the discussions and deliberations of the Group with regard to the draft new individual schedule for Direct Reduced Iron (D), and the Group's invitation to interested Member States and international organizations to submit new proposals to CCC 4 (paragraphs 3.31 to 3.34 and annex 4);

.6 note the Group urged the industry to provide more data and information on AMMONIUM NITRATE BASED FERTILIZER (non-hazardous), in particular on the different types of fertilizer and their specific properties that are beingshipped under this schedule and on the necessity of the existing requirements for these different types of fertilizer, and the Group's invitation to interested Member States and international organizations to submit new proposals to CCC 4 (paragraphs 3.35 to 3.38);

.7 endorse the decision of the Group to keep the references within the Code as simple as possible and to improve consistency within the Code for this aspect at a future stage, possibly when preparing a consolidated version of the IMSBC Code (paragraphs 4.1 to 4.3);

.8 agree to the draft amendment related to table for "Characteristics", with a view for inclusion in draft amendment 05-19 to the IMSBC Code (paragraph 4.8.1 and annex 6);

.9 agree to introduce the amended table for "Characteristics" in all existing individual schedules in appendix 1 of the IMSBC Code, for inclusion in draft amendment 05-19 to the IMSBC Code (paragraph 4.8.2 and annex 6);

.10 endorse the Group's recommendation to follow a similar approach to that of the IMDG Code and to prepare a consolidated version of the IMSBC Code, starting from amendment 05-19 to the IMSBC Code (paragraph 4.9);

.11 note the Group could not reach an agreement on the need to amend the definition of Materials hazardous only in bulk (MHB) (paragraph 4.10);

.12 note the discussions and deliberations of the Group with regard to the revision of individual schedules for SEED CAKE (paragraphs 5.1 to 5.2);

.13 note the Group identified an editorial correction in the resolution MSC.393(95), i.e. in the paragraph 7.3.1.2, the reference to "4.2.2.9, 4.2.2.10" should be replace by "4.2.2.1.9, 4.2.2.1.10" and requested the Secretariat to issue a corrigendum accordingly (paragraph 5.3); and

.14 approve the report in general.

5/1 Report of the Correspondence Group on Evaluation of properties of BAUXITEand revision of draft individual schedules for SEED CAKE

Japan

Japan provides the first part of the report of the Correspondence Group on Evaluation of properties of BAUXITE and revision of draft individual schedules for SEED CAKE.

Part 1 – Revision of draft individual schedules for SEED CAKE

The Sub-Committee is invited to:(paragraph 49)

.1 finalize the draft individual schedules for MHB and Group C cargoes, considering the following issues, where the Group could not agree or had not fully discussed (paragraph 36 and annexes 2 and 3);

.1 Bulk Cargo Shipping Names (paragraph 7);

.2 Application provisions (paragraphs 8 and 9);

.3 Description (paragraphs 10 and 11);

.4 Characteristics - Class of MHB cargoes (paragraph 17);

.5 Hazard (paragraph 20);

.6 Loading – Certificate (paragraphs 25, 26 and 27);.7 Precautions - Temperature monitoring and related actions for MHB cargoes (paragraph 29); and.8 Clean-up (paragraph 34);

.2 note (paragraphs 13 and 48):

.1 the absence of guidance for determining whether a cargo is cohesive or non-cohesive;. 2 that consequential amendments to appendix 3 to the Code may be required; and.3 that the Group agreed these topics were outside of the scope of the Correspondence Group;

.3 consider the recommendation on inviting interested Member States and international organizations to provide information on the properties or hazards of these cargoes with regard to dust explosion (paragraph 18);

.4 consider the draft amendments to section 9 of the Code (paragraphs 37 and 38 and annexes 4 and 5);

.5 note an error in the authentic text and take action as appropriate (paragraph 39);

.6 consider the amendments to the sections for "Precautions" of

individual schedules for UN 1386 (b) and UN 2217 with regard to closure of hatches (paragraphs 40 and 41);

.7 review the provisions on the use of carbon dioxide in the sections for "Precautions" of the individual schedules for UN 1386 (b) and UN 2217 (paragraphs 42 and 43);

.8 consider the mandatory application provision of the individual schedule for UN 2217 (paragraphs 44 to 46 and annex 6);

.9 invite interested Member States to submit proposals on the amendments to the UN Model Regulations for harmonization of the IMDG and IMSBC Codes with the UN Model Regulations (paragraph 47); and

.10 consider the establishment of a working group in order to finalize the draft individual schedules.

5/1/Add.1

Report of the Correspondence Group on Evaluation of properties of BAUXITEand revision of draft individual schedules for SEED CAKE

Japan

Japan provides the second part of the report of the Correspondence Group on Evaluation of properties of BAUXITE and revision of draft individual schedules for SEED CAKE.

Part 2 – Evaluation of properties of BAUXITE

The Sub-Committee is invited to:(paragraph 25)

.1 consider the section for Hazard in the draft individual schedule for Group A cargo (paragraphs 5 and 6 and annex 2)

.2 agree, in principle, the criterion of Group A and Group C cargoes proposed by the GBWG and agreed by the CG (paragraphs 7 and 8);

.3 consider the mandatory application provisions in the individual schedules for Group A and Group C cargoes (paragraph 9 and annexes 2 and 3);

.4 note the recommendation by the GBWG and comment on the recommendation (paragraphs 10 and 11);

.5 agree to include the new test procedure for determining TML for bauxite cargoes in appendix 2 to the IMSBC Code (paragraphs 12 and 13);

.6 agree, in principle, with the draft new test procedure for determining TML for bauxite cargoes and finalize the draft test procedure (paragraph

14 and annex 1);

.7 consider the texts in section for Loading of the draft individual schedule for Group A cargoes (paragraph 17)

.8 consider the texts in section for Carriage of the draft individual schedule for Group A cargoes (paragraph 18);

.9 consider the texts in section for Precautions of the draft individual schedules for both Group A and Group C cargoes (paragraph 19);

.10 finalize the draft individual schedules for Group A and Group C bauxite cargoes (paragraph 20 and annexes 2 and 3);

.11 agree, in principle, with the draft consequential amendment to appendix 2 to the Code and take action as appropriate (paragraph 22);

.12 note that the consequential amendment to appendices 4 and 5 to the Code is necessary with regard to the addition of the new individual schedule for Group A bauxite cargoes and take action as appropriate (paragraph 23); and

.13 consider establishment of or instruction to a working group, in order to consider the issues related to bauxite cargoes and seed cakes in detail (paragraph 24).

5/2 New Individual Schedule for METAL SULPHIDE CONCENTRATES, SELF-HEATING, UN 3190

Australia

Australia proposes a new individual schedule for METAL SULPHIDE CONCENTRATES, SELF-HEATING, UN 3190, in the IMSBC Code.

Australia considers that irrespective of the fact that this cargo is "normally" carried with a moisture content far below its Transportable Moisture Limit (TML), it should be classified as a Group A cargo if there is a risk of liquefaction when transported with a moisture content higher than the TML (DSC 17/4/2, paragraph 6.55). Details of the cargo properties and test information are provided in documents CCC 4/INF.5 and CCC 4/INF.6.

Australia provides a draft new individual schedule for METAL SULPHIDE CONCENTRATES, SELF-HEATING, UN 3190, in the annex of the document.

5/3 Self-Heating Coal and Information Regarding the Australian Industry Self-Heating Coal Research Project

Australia

Australia provides information regarding self-heating properties of coal and the ongoing coal self-heating research project being undertaken in Australia.

Australian Coal Industry's Research Program (ACARP), in consultation with AMSA, have initiated a project to carry out further research into the self-heating properties of coal and to consider whether the sample preparation in the N.4 test can be, or should be, adjusted to provide consistent and reliable results when coal is to be shipped in solid bulk form. If the research identifies a particular test or similar procedure as appropriate for determining the self-heating properties of a coal cargo shipped in solid bulk form, Australia would be able to provide further information, with proposals for any action, to the next session of the Sub-Committee.

A summary of the need for the research and the project goals is provided in annex 1 of the document.

Australia has already issued a determination, as an interim measure, which allows coal to be declared as MHB (SH), based on the results of test carried out in accordance with section 33.3.1.6 of the UN Manual of Tests and Criteria. This does not permit coals that provide consistent results as being self-heating dangerous goods to be shipped in solid bulk form. The determination includes additional requirements to ensure safe shipping.

A copy of the approval is provided in annex 2 of the document.

5/4 Comments on the report of the twenty-sixth session of the Editorial and Technical Group

China

China provides comments on document CCC 4/5 regarding amendment of the definition of the Materials hazardous only in bulk (MHB) and the table for "Characteristics".

Definition of MHB – China considers that the concept of MHB was established to enable the crew to give adequate attention to the safety risks of the cargoes which did not reach the classification criteria of dangerous goods in the International Maritime Dangerous Goods (IMDG) Code, but still possessed chemical hazards when carried in bulk or had caused accidents for their chemical hazards, and to take the necessary measures. China also considers that the MHB definition in the IMSBC Code is a different system from the classification system in the IMDG Code, which was established based on the experience of transportation and accidents. MHB means a cargo is dangerous goods ONLY in bulk form but not in packaged form. Although the criteria of MHB have been established in the IMSBC Code, it has not changed the classification systems in the IMSBC Code and IMDG Code. Therefore, China therefore considers that the "only" in the definition of MHB is a landmark word which should not be easily modified before having enough reviews and assessments.

"MHB" box of the amended "Characteristics" table – China notes that in the discussion of the E&T Group, there was a tendency to add the note "see 'hazards' section" in the "MHB" box of the amended "Characteristics" form for the solid bulk cargoes which do not have MHB characteristics or whose MHB characteristics are unknown. China draws the attention of the Sub-Committee to the fact that the "MHB" box of the "Characteristics" table is legally treated as a mandatory instrument under the SOLAS Convention according to paragraph 1.4.2 of the IMSBC Code and paragraph 2 of annex 6 of document CCC 4/5, while the "hazards" section is recommendatory or informative. Therefore, China calls the Sub-Committee's attention to the legal obstacle of directly referencing recommendatory or informative content in the mandatory section.

“MHB” classification of existing individual schedules – China notes that the E&T Group recommended that the Sub-Committee fully adopt the new "Characteristics" table in the draft amendments to IMSBC Code (05-19). Reviewing the process of adding a notational listing system for identifying MHB cargoes, it was decided that the notational reference only applies to the new individual schedules. For the existing individual schedules, a notational reference will be added only when amending these existing individual schedules. China considers if comprehensively amending the "Characteristics" table of all existing individual schedules, it would be necessary to add the notational reference to the MHB cargoes. This may lead to a reassessment of the existing MHB cargoes which may result in a significant amount of work and also an amendment to MSC.1/Circ.1453/Rev.1. Such a large workload may take a long time and a lot of resources. China doubts whether there is enough time and resources to complete this task.

China proposes:(paragraph 6)

.1 to prudently deal with the modification of the MHB definition, and not take action before reviewing the enactment process of the BC Code and accessing the effect of amending the definition of MHB;

.2 instead of directly referencing the "see 'hazards' section" in the "MHB" box of the amended "Characteristics" table, add the following content after the form of IMSBC Code 9.2.3.1.5:

"If there is a "-" in the 'MHB' box of 'Characteristics' table, refer to the description in the 'hazards' section."

.3 when the new “Characteristics table” enters into force, for existing individual schedules in appendix 1 of this Code:

.1 evaluate the MHB classification only when the relevant schedules are amended;

.2 display "MHB" in the amended table for those displayed only "MHB" in the existing schedules; .3 display "-" in the amended table for those displayed as Class and Subsidiary risk(s) in the existing schedules.

ICS notes the comments by China address the action points found at .8, .9 and .11 of document CCC 4/5. For ease of reference, these items are reproduced below with relevant additional information.

.8 agree to the draft amendment related to table for "Characteristics", with a view for inclusion in draft amendment 05-19 to the IMSBC Code (paragraph 4.8.1 and annex 6);

.9 agree to introduce the amended table for "Characteristics" in all existing individual schedules in appendix 1 of the IMSBC Code, for inclusion in draft amendment 05-19 to the IMSBC Code (paragraph 4.8.2 and annex 6);

.11 note the Group could not reach an agreement on the need to amend the definition of Materials hazardous only in bulk (MHB) (paragraph 4.10);

The E&T Group had some discussions on the amendment of the definition of Materials hazardous only in bulk (MHB). However, during the discussion, the views on the need to amend the definition were divided. Although some delegations noted the possible merit of introducing more clarity on the definition of MHB from the technical aspect, the E&T Group could not reach an agreement on the need to amend the definition of Materials hazardous only in bulk (MHB).

5/5 New individual schedule for Brucite China

China proposes a new individual schedule for Brucite in the IMSBC Code.

China provides a new draft individual schedule for Brucite, as a Group C cargo in the IMSBC Code, in the annex of the document.

This document is related to the test reports provided by China in CCC 4/INF.8.

5/6 Review of the test methods given in the IMSBC Code for classifying materialswhich evolve flammable gas when wet

United Kingdom

The United Kingdom (UK) draws the attention of the Sub-Committee to some limitations with the testing requirements given in the IMSBC Code for classifying bulk materials which emit flammable gas when wet, MHB(WF).

In January 2017, a general cargo ship at a UK port experienced an explosion on board after loading a solid bulk cargo which was unassessed and did not have a schedule within the IMSBC Code. It was found that the explosion was caused by a build-up of hydrogen gas in the cargo hold, and that the shipper had not approached any competent authority to seek approval for shipping. As such, the cargo had not undergone any of the testing required for assessing carriage requirements.Immediately after the incident, UK prevented further loading of this product.

The first test results stated there was 'no observable gas', indicating that the cargo did not meet the criteria for MHB(WF). The tests had been conducted in line with the United Nations Manual of Tests and Criteria, part III, 33.4.1, as required by provision 9.2.3.4 of the IMSBC Code. There appeared to be a disparity between the UN test requirements for classifying MHB(WF) and MHB(WT) and the application of these tests when applied to heterogeneous solid bulk cargoes.Given the contradiction between the test results and the facts established after the incident, UK considers further consideration is needed regarding the parameters of the tests required by provision 9.2.3.4 of the IMSBC Code.

The UK proposes that provisions 9.2.3.4.2 and 9.2.3.5.2 of the IMSBC Code could be revised to require the MHB tests to use a larger sample (i.e. 1 kg), and to request that the test substance be fully saturated during the course of the test. Additionally, these sections could include a requirement for replicate tests to be performed (i.e. three replicates).

5/7 Proposal to enhance the guidance given within the IMSBC Code to Administrations who are commencing a Tripartite Agreement

United Kingdom

The UK proposes that the IMSBC Code is amended to include more detailed guidance on the method used by a Competent Authority (CA) to initiate a tripartite agreement (TPA) that establishes the preliminary conditions of carriage for transporting an unscheduled solid bulk cargo.

Section 1.3 of the IMSBC Code gives instructions for arranging the carriage of unscheduled solid bulk cargoes. It requires the CA of the port of loading to assess the characteristics and properties of the cargo. If the CA assesses that a cargo may present a hazard then the CA of the port of loading, port of

unloading, and flag State should set the preliminary conditions for the carriage of the cargo, establishing a tripartite agreement (TPA). Currently, the IMSBC Code does not define the method for establishing a TPA, and a number of interrelated aspects also go undefined.

The International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code) has a well-established process for the provisional assessment of liquid substances transported in bulk (MEPC.1/Circ.512), which covers the method by which IBC Code TPAs are established.

It is proposed that the IMSBC Code could benefit from following a similar arrangement as the IBC Code. Defining a process by which TPAs are agreed could help establish:

The duration over which a TPA is valid;

The process to amend and recirculate a TPA, should new evidence come to light regarding the hazard properties of a cargo;

Tacit agreement from flag States in the absence of an interim or final response to a TPA request. Currently, a CA or shipper has no recourse should it fail to receive any communication from a flag State (see paragraph 4.12 of MEPC.1/Circ.512);

Where responsibility lies for providing the ship's master with information. Currently, the IMSBC Code makes the CA of the port of loading responsible. A TPA with a long duration and frequent shipments might benefit from this responsibility passing to the shipper;

A process to follow if a TPA is rejected by another stakeholder (see paragraph 4.13 of MEPC.1/Circ.512); and

A process to follow if a schedule submitted to CCC is rejected. Rejection of a schedule suggests the proposed conditions of carriage are not adequate, yet the current IMSBC Code allows the carriage to continue under the pre-existing, and unaltered TPA.

It is also proposed that the IMSBC Code could benefit from creation of a platform on the IMO website where IMSBC Code TPAs are made available to IMO stakeholders (like the section of the IMO website which hosts IBC Code TPAs).

The Sub-Committee is requested to:

Consider if additional guidance should be provided within the IMSBC Code for the methods by which parties can commence and track a tripartite agreement; and

Should it be decided that additional TPA guidance is to be issued,

consider if this might be supported by an online platform for hosting TPAs.

ICS recommends support for providing guidance on tripartite agreements and arrangements for the safe carriage of unscheduled solid bulk cargoes. ICS concurs that the IMSBC Code could benefit from the establishment of a similar process and arrangements as developed under the IBC Code concerning tripartite agreements,including an appropriate online platform for hosting tripartite agreementsto ensure availability to all relevant stakeholders. In that regard, development of the process, and associated online platform, should ensure any lessons are learned from the IBC Code process and arrangements to date.

5/8 The Global Bauxite Working Group Final Report

Australia, Brazil and Malaysia

The Global Bauxite Working Group (GBWG) was established to provide a peer reviewed report on the nature of Bauxite (CCC 3/15, paragraph 5.37 and 5.38), and inform the development of suitable Group A and Group C schedules for BAUXITE by the Correspondence Group (CG) on Evaluation of Properties of BAUXITE and revision of draft individual schedules for SEED CAKE (CCC 3/15, paragraph 5.80).

The co-sponsors advise that, since the final report of the GBWG was provided to the CG, some necessary editorial correctionswere subsequently made by the GBWG to its final report. The final report of the GBWG, with details of the corrections, is provided in the annex to document CCC 4/INF.10.

The co-sponsors explain that the corrections require consequential amendments to the report submitted by the CG. Specifically, it is necessary to incorporate these amendments into the proposals of the CG provided in annex 1 to document CCC 4/5/1/Add.1 containing a Draft new test procedure for determining the TML for BAUXITE. The proposed amendments to the report of the CG in the annex of the document.

The Sub-Committee is invitedinter alia to:(paragraph 16)

.2 note the information provided in document CCC 4/INF.10 and the proposed amendments to the report of the Correspondence Group provided in the annex when considering actions requested by the CG in relation to bauxite (paragraph 9); and

.3 note the co-sponsors' support for the CG's proposals regarding bauxite and the proposals for the draft amendments (05-19) to the IMSBC Code (paragraph 13).

5/9 AMMONIUM NITRATE BASED FERTILIZER (non-hazardous)

European Chemical Industry Council (CEFIC)

CEFIC proposes to amend the schedule for AMMONIUM NITRATE BASED FERTILIZER (non-hazardous), following discussions at CCC 3, E&T 25 and E&T 26.

Proposed changes to the existing schedule are described in paragraphs 5 to 14 below and shown in the annex in the context of the existing schedule, with additions of new text and moved text shown by underlining and deletions of text shown with strikethrough font. Where appropriate, reasoning for the suggested changes is given. The clean version (without tracked changes) of the proposed revised schedule is presented in the annex to document CCC 4/INF.13.

The German Federal Institute for Materials Research and Testing (BundesanstaltfürMaterialforschung- und Prüfung – BAM)has carried out a test programme of UN Tests N1, N4, and S1 (UN Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, 2015) on a number of fertilizer products for CEFIC (and Fertilizers Europe). The main conclusion of these tests is that these ammonium nitrate based fertilizers (non-hazardous) do not propagate combustion, are not flammable solids, are not self-heating and do not show self-sustaining decomposition behaviour.

CEFIC proposes amendments to the existing schedule for AMMONIUM NITRATE BASED FERTILIZER (non-hazardous). Reasoning and for the amendments is provided in paragraphs 5 to 14, and are provided annotated on the existing schedule in the annex of the document.

The Sub-Committee is invited to consider the proposed amendments to the existing schedule for AMMONIUM NITRATE BASED FERTILIZER (non-hazardous).

CEFIC provides a clean version of the proposed revised schedule in the annex to document CCC 4/INF.13, and results of the tests are provided in the annex to document CCC 4/INF.14.

ICS recalls that, in documents CCC 2/5/24 and CCC 3/5/9, Germany proposed that AMMONIUM NITRATE BASED FERTILIZER (non-hazardous), a Group C cargo at present, be reclassified as MHB (OH) Group B cargo in accordance with paragraph 9.2.3.1.4 of the IMSBC Code. CEFIC (and Fertilizers Europe) does not support the reclassification of this cargo and submitted documents E&T 25/3/6 in 2015 and CCC 3/5/14 in 2016 to register its opposition with supporting reasons.

5/10 Editorial amendment to the IMSBC Code Philippines

The Philippines proposes an editorial amendment to address an inconsistency in the foreword of the IMSBC Code. In the IMSBC Code 2016 Edition publication, the last paragraph of the Foreword section states that:

"The IMSBC Code that was adopted by resolution MSC.268(85) was recommended to Governments for adoption or for use as the basis for national regulations in pursuance of their obligations under regulation of the SOLAS Convention, as amended."

It is proposed to revise the first line of the second to last paragraph of the Foreword section of the IMSBC Code (2016 Edition) to read:

"The IMSBC Code that was adopted by resolution MSC.268(85) was for adoption and implementation of Governments or for use as the basis for national regulations in pursuance of their obligations under the SOLAS Convention, as amended."

5/11 Test Methods to Determine Corrosivity for Solid Bulk Cargoes

Australia, Canada and International Iron Metallics Association (IIMA)

Australia et al. outline the research programmes being undertaken by a Global Industry Alliance to better understand the assessment of corrosion of steel by solid bulk cargoes and identify an appropriate test protocol for assessing the corrosivity of solid bulk cargoes.

5/INF.5 Supporting Documentation for New Individual Schedule for METAL SULPHIDE CONCENTRATES, SELF-HEATING UN 3190Including IMO Solid Bulk Cargo Information Reporting Questionnaire

Australia

Australiaprovides the IMO Solid Bulk Cargo Information Reporting Questionnaire and the Safety Data Sheet (SDS) for Copper Concentrate to support a new entry for Metal Sulphide Concentrates, Self-Heating UN 3190 Group A and B in the IMSBC Code.

Australia proposes to include a new individual schedule for this cargo in document CCC 4/5/2.

5/INF.6 Supporting Documentation for New Individual Schedule for METAL SULPHIDE CONCENTRATES, SELF-HEATING UN 3190

Australia

Australia provides the supporting test documentation and reports to confirm the information included in the IMO Solid Bulk Cargo Information Reporting Questionnaire and the Safety Data Sheet (SDS) set out in document CCC 4/INF.5 and to support the Australian proposal to include a new individual schedule for Metal Sulphide Concentrates, Self-Heating UN 3190 Group A and B in the IMSBC Code.

Australia proposes to include a new individual schedule for this cargo in document CCC 4/5/2.

5/INF.8 Information to support the new individual schedule for Brucite

China

China provides the cargo information to support the proposed new individual schedule for Brucite.

This document supplements the proposal by China for a new individual schedule for Brucite in document CCC 4/5/5.

5/INF.9 Progress on the development of the new individual schedule for direct reduced iron (D) (By-product fines)

International Iron Metallics Association (IIMA)

IIMA provides an update on progress made since E&T 26 towards a new individual schedule for direct reduced iron (D) (By-product fines).

5/INF.10&Corr.1

The Global Bauxite Working Group Final Report and Peer Review Letter

Australia, Brazil and Malaysia

Australia et al. provide the corrected GBWG final report (annex 1) and the associated peer review letter from Imperial College, London (annex 2).(Corr.1: In annex 1, page 86 and in annex 2, page 80, in the title of figure 118, delete the word "bauxite").

The Sub-Committee was invited to note the information provided in the annex to this document (CCC 4/INF.10) and the proposed amendments to the report of the Correspondence Group when considering actions requested by the CG in relation to bauxite.

5/INF.13 Draft revised schedule for AMMONIUM NITRATE BASED FERTILIZER (non-hazardous)

European Chemical Industry Council (CEFIC)

CEFIC provides a clean version of the revised individual schedule for AMMONIUM NITRATE BASED FERTILIZER (non-hazardous) proposed in document CCC 4/5/9. The clean version of the proposal is in the annex to the document.

This document supplements document CCC 4/5/9 and relates to documents CCC 3/5/9, CCC 3/5/14 and CCC 4/5.

5/INF.14 Additional information on AMMONIUM NITRATE BASED FERTILIZER

European Chemical Industry Council (CEFIC)

CEFIC provides additional information on AMMONIUM NITRATE BASED FERTILIZER (non-hazardous), specifically the report on the testing of five fertilizers according the UN Tests N.1, N.4 and S.1, as conducted by the German Federal Institute for Materials Research and Testing (BundesanstaltfürMaterialforschung- und Prüfung – BAM), as well the BAM "Opinion on Transport Classification".

This document supplements document CCC 4/5/9 and relates to documentCCC 4/INF.13.

ITEM 6: AMENDMENTS TO THE IMDG CODE AND SUPPLEMENTS

The Sub-Committee will finalise the draft amendments to the IMDG Code (amendment 39-18) and supplements, including harmonisation with the UN Recommendations on the transport of dangerous goods, based on the report of E&T 27 (CCC 4/6) and any other documents submitted to this session relevant to the item. The Sub-Committee will instruct E&T 28 to finalise the text of the draft amendments (39-18) to the IMDG Code, for consideration at MSC 99, with a view to adoption.

Papers:

6 Report of the 27th session of the Editorial and Technical Group

Secretariat

This document contains the discussions and decisions taken by E&T 27, which met under the chairmanship of Ms.Gudula Schwan (Germany),in the context of amendments to the International Maritime Dangerous Goods (IMDG) Code.

This document contains the following annexes:

Annex 1 - DRAFT EDITORIAL CORRECTIONS TO THE ENGLISH VERSION OF THE IMDG CODE AMENDMENT 38-16 ADOPTED BY RESOLUTION MSC.406(96)Annex 2 - DRAFT AMENDMENTS (39-18) TO THE IMDG CODE (PART 1)Annex 3 - DRAFT AMENDMENTS (39-18) TO THE IMDG CODE (PART 2)Annex 4 - DRAFT MSC CIRCUALR REVISED EMERGENCY RESPONSE PROCEDURES FOR SHIPS CARRYING DANGEROUS GOODS (EMS GUIDE)

The Sub-Committee will approve the report in general and, in particular, to:

.1 agree, in principle, to the draft editorial corrections to amendment 38-16 to the IMDG Code (paragraphs 2.1 to 2.7 and annex 1);

.2 note that the Group requested the Secretariat to draw IAEA's attention to the TI limits and CSI limits for the hold and the total vessel, with a view to harmonizing the IMDG Code and SSR-6 (paragraph 2.6);

.3 agree, in principle, to draft amendment 39-18 to the IMDG Code (part 1), taking into account that some amendments are held between square brackets to be finalized by CCC 4 or E&T 28, as appropriate (paragraphs 3.1 to 3.34 and annex 2);

.4 note that the Group requested the Secretariat to invite the UN TDG Sub-Committee to consider relevant amendments to the IMDG Code, as highlighted in annexes 1 and 2 (paragraph 3.34);

.5 agree, in principle, to draft amendment 39-18 to the IMDG Code (part 2), containing proposals submitted directly to E&T 27 (paragraphs 3.35 to 3.54 and annex 3); and

.6 agree, in principle, to the draft consolidated Revised Emergency Response Procedures for Ships Carrying Dangerous Goods (EmS) Guide (paragraph 4.3 and annex 4).

6/1 Clarification in SP 963 for UN 3496 Nickel-metal hydride batteries

Germany

Germany proposes to clarify the provisions for UN 3496 (NICKEL METAL HYDRIDE BATTERIES)which were implemented by amendment 35-10 of the IMDG Code – the agreement being that Nickel Metal Hydride (NiMH) button cells should be exempted from the provisions of the Code, while other NiMH batteries should be exempted only when packed withor, contained in, equipment.

The first sentence of SP 963 in the abovementioned amendment 35-10 of the IMDG Code as currently implemented isas follows:

"963 Nickel-metal hydride button cells or nickel-metal hydride cells or batteriespacked with or contained in equipment are not subject to the provisions ofthis Code […]”.

The sponsor suggests that the wording of this sentence may be understood in a way that NiMH button cells and NiMH batteries are both only exempted when packed in equipment. However, the intention was to exempt button cells in any case.

To clarify this issue and avoid any misunderstanding, the sponsor proposes to change the above sentence to:

"Nickel-metal hydride cells or batteries packed with or contained in equipment and nickel-metal hydride button cells are not subject to the provisions of this Code."

The proposals by Germany clarify the intent of SP 963 and it is the view of ICS that they should therefore be taken forward.

6/2 Meaning of segregation code SG1 Germany

Germany proposes to amend the description of Segregation Code 1 (SG1) which is currently assigned to UN 2956, class 4.1 (5-tert-BUTYL-2,4,6-TRINITROM-XYLENE (MUSK XYLENE)) to reflect the intention of SG1.

Specifically, the current text reads: "For packages carrying a subsidiary risk label of class 1, segregation as for class 1, division 1.3.", however the sponsor states that the current wording does not reflect the intention of SG1, which does not nullify the segregation applicable to class 4.1. It is stated that the segregation must take account of the main class as well as of the subsidiary risk. For the subsidiary risk of class 1, it is specified that the segregation should be as for division 1.3.

Therefore, the proposed replacement text for SG1 reads as follows: "For segregation purposes, a subsidiary risk of class 1 has the significance of division 1.3."

The Sub-Committee will consider the proposal to change the above sentence in order to provide clarity.

The proposals by Germany clarify the intent of SG 1 for UN 2956, class 4.1 and it is the view of ICS that they should therefore be taken forward.

6/3 Segregation provisions for uranium hexafluoride Germany

Germany proposes to adapt the segregation requirements for uranium hexafluoride, in order to reflect the additional risk of class 6.1 (toxic substance).

The fact that uranium hexafluoride has toxic properties was recently reflected in amendment 38-16 to the IMDG Code as follows: UN 2977 (RADIOACTIVE MATERIAL, URANIUM HEXAFLUORIDE, FISSILE) and UN 2978 (RADIOACTIVE MATERIAL, URANIUM HEXAFLUORIDE non fissile or fissile-excepted)are classified into class 7 with a subsidiary risk of classes 6.1 and 8; furthermore, UN 3507 (URANIUM HEXAFLUORIDE, RADIOACTIVE MATERIAL, EXCEPTED PACKAGE, less than 0.1 kg per package, non-fissile or fissile-excepted) is now classified into 6.1 with a subsidiary risk of classes 7 and 8.

The segregation table in chapter7.2.4 of the IMDG Code applies only to substances, materials and articles with not more than one subsidiary risk. In case of two or more subsidiary risks, the segregation provisions are given in column (16b) (see chapter 7.2.3.4 of the IMDG Code). However, column (16b) does not contain segregation provisions for the three UN numbers assigned to uranium hexafluoride (UN 2977, 2978 and UN 3507).

The sponsor notes that, for UN 2977 and 2978 which should be segregated as for class 7, no segregation code exists for the requirement “segregation as for class 7”; the sponsor also notes that UN 3507 should be segregated as for class 8, but there is no segregation code to indicate “segregation as for class 8”. Therefore,the sponsor proposes:

- In chapter 7.2.8 of the IMDG Code, two new segregation codes should be included as follows:

"SG76 Segregation as for class 7 SG77 Segregation as for class 8".

- In column (16b) of the dangerous goods list, the following segregation codes should be included:

.1 for UN 2977 and UN 2978: insert SG 17, SG 65, SG 76 in column (16b); and .2 for UN 3507: insert SG 77 in column (16b).

The Sub-Committee will consider the proposal to change the above sentence in order to provide clarity.

See also CCC 4/6/12.

6/4 Packing instruction P403 Germany

Germany notes that in packing instruction P403, special packing provision PP31 applies to many substances which are assigned to class 4.3, packing group I. This special packing provision requires packagings to be hermetically sealed, except for solid fused material. However, in packing instruction P410, which applies to class 4.3, packing group II, the same special provision PP31 requires packagings to be hermetically sealed without any exception.

Germany states that it is not logical for the requirements for a hermetically sealed packaging for packing group I material to be less stringent than those for packagings for packing group II material. Furthermore, it is noted that, according to the classification criteria of class 4.3, the criterion for the assignment of packing group I is the evolution of flammable gas at a rate greater than 1 litre per kilogram of the substance per hour. A material generating such a high amount of flammable gas in contact with water is either not fused at all or not effectively fused. Therefore, there is a contradiction between the characterization of a material as "solid fused" and the assignment of packing group I.Finally, it is stated that when a substance evolves in contact with water flammable gases at such high extent, there is, from a safety point of view, no justification to permit its transport in packagings which are not hermetically sealed.

Therefore, the sponsor proposes to eliminate the above-mentioned inconsistency and to deletethe words "except for solid fused material" in special packing provision PP31 as assigned in packing instruction P403, to enhance safety.

The Sub-Committee will consider the proposal to change the above sentence in order to provide clarity.

The proposals by Germany tighten the meaning of special packing provision PP 31 as assigned in packing instruction in P403.

6/5 FUMIGATED CARGO TRANSPORT UNIT (UN 3359) and MSC.1/Circ.1361

Germany

Germany proposes to delete the mandatory reference to MSC.1/Circ.1361 in the IMDG Code and to review the structure and content of the provisions onUN 3359 (FUMIGATED CARGO TRANSPORT UNIT). Amendments are proposed to create a simpler but clearer and safer regulation. Germany notes a number of issues and inconsistencies in the provisions as the currently exist, highlighting non-compliance issues, superfluous equipment requirements, and an absence of clarity as to the legal status of apparent requirements in them. Germany proposes three possible solutions to the identified problems for the Sub-Committee’s consideration as follows:

Proposal 1(reference to MSC.1/Circ.1361): Delete the reference to the MSC.1/Circ.1361 by deleting paragraph 5.5.2.5.1.

Proposal 2(amendments to the IMDG Code):.1 Delete

.1 the need for specific gas detecting devices by deleting paragraph 5.5.2.5.2;

.2 the first part of paragraph 5.5.2.5.4 referring to the periods between fumigation and loading, including the reference to a competent authority approval;.3 the second part of paragraph 5.5.2.5.4, as this is redundant to paragraphs 5.5.2.3.3 and 5.5.2.3.4;.4 paragraph 5.5.2.4.3 (in respect of tasking crews to dispose residues out of containers). It is noted that this paragraph is transferred from the UN Model Regulations, but any deletion has no impact on multimodal transport.

.2 Amend .1 entry UN 3359 in column (17) of the dangerous goods

list to read: "A ‘FUMIGATED CARGO TRANSPORT UNIT’ is a closed cargo transport unit containing goods or materials that either are or have been fumigated with toxic gases within the unit. The gases are usually evolved from solid or liquid preparations distributed within the unit. See also 5.5.2."

Proposal 3 (amendments to the IMDG Code with multimodal relevance)

.1 Amend paragraph 5.5.2.4 regarding documentation to read: "5.5.2.4.1 The consignor who offers a fumigated cargo unit for transport shall provide the carrier with the dangerous goods transport information in accordance with 5.4.1 except 5.4.1.5.1. The name of the fumigant shall be entered in brackets immediately following the proper shipping name.

5.5.2.4.2 A document is not required, when the fumigated cargo transport unit has been completely ventilated, so that a harmful concentration of fumigants will not occur during the entire transport, and when the date of ventilation has been marked on the warning sign."

.2 Consequently, paragraph 5.5.2.5.5 should be deleted.

.3 There might also be a need for amending the UN Model Regulations as these amendments have a multimodal impact. If supported by the Sub-Committee, a submission to the UN Sub-Committee should be considered.

The Sub-Committee will consider the proposals above and take action as appropriate.

ICS has, at previous sessions of DSC and CCC, proposed to clarify the fumigation rules under the IMDG Code, taking the view that they need to be simple and concise. There is no way ventilation make entry into the container safe without stringent testing, and even after such testing fumigant that has been absorbed in the cargo may re-emerge over time, presenting a safety hazard. Under the current rules a label is placed on the container door when fumigated and, if it is shipped as fumigated this will be included in the cargo manifest as hazardous. If, however, the container is ventilated then it is shipped as non-regulated and no documentation is required, though the date of ventilation must be marked on the label. This leads to the confusion highlighted by Germany. ICS takes the view that all containers that have been fumigated; whether ventilated or not; should be shipped as fumigated containers under UN3359 and documented accordingly. This would clarify and streamline the process and make it clear to all involved that the container has

been fumigated at some point and precautions must be undertaken when entering the container.

Germany highlights the confusion that currently exists in the supply chain with respect to the marking and handling of fumigated containers, and there is a clear and pressing need for the regulations to be simple and concise in order to increase safety. As such ICS believes the German proposals should be taken forward and either proposal 1 or 2 made by Germany would result in a clearer regulation.

6/6 Draft editorial corrections to the French version of amendment 38-16 to the IMDG Code (MSC.406(96))

France

France submits draft editorial corrections to the French version of amendment 38-16 to the IMDG Code.

6/7 Draft amendments (39-18) to the IMDG Code Amendments to special provision 363 of chapter 3.3

France

France proposes to amend the text of chapter 3.3, paragraph .7 sub-paragraph .4 of the IMDG Code in regard to placarding dimensions so as to harmonise the provisions regarding the marine pollutant marking dimensions for UN 3530 (ENGINE, INTERNAL COMBUSTION or MACHINERY, INTERNAL COMBUSTION) with the marking provisions for UN 3528 (ENGINE, INTERNAL COMBUSTION, FLAMMABLE LIQUID POWERED or ENGINE, FUEL CELL, FLAMMABLE LIQUID POWERED or MACHINERY, INTERNAL COMBUSTION, FLAMMABLE LIQUID POWERED or MACHINERY, FUEL CELL, FLAMMABLE LIQUID POWERED).

This proposed amendment is as follows:

“.4 for UN 3528 and UN 3530: – where the engine or machinery contains more than 60 L of liquid fuel and has a capacity of not more than 450 L, the labelling requirements of 5.2.2 shall apply; – where the engine or machinery contains more than 60 L of liquid fuel and has a capacity of more than 450 L but not more than 3,000 L, it shall be labelled on two opposing sides in accordance with 5.2.2; – where the engine or machinery contains more than 60 L of liquid fuel and has a capacity of more than 3,000 L, it shall be placarded on two opposing sides in accordance with 5.3.1.1.2; - for UN 3530, in addition the marking requirements of 5.2.1.6 apply;"

- for UN 3530:

(a) where the capacity of the engine or machinery does not exceed 3,000 L, in addition the marking requirements of 5.2.1.6 apply;

(b) where the engine or machinery contains more than 60 L of liquid fuel and has a capacity of more than 3,000 L, in addition the placarding requirements of 5.3.2.3.2 apply;"

The Sub-Committee will consider the aforementioned proposal with a view to commenting

and taking such further action as it deems appropriate.

6/8 Medical First Aid Guide (MFAG) Germany

Germany advises that a fully revised version of the IMO/WHO/ILO Medical First Aid Guide for Use in Accidents involving Dangerous Goods (MFAG) was adopted by the Maritime Safety Committee in 1998 (see MSC 69/22, paragraph 9.6). Following a review, which took into account current scientific medical knowledge, a set of proposed amendments to the MFAG are proposed concerning the use of paracetamol, medication advice under table 19, the use of furosemide and the text of appendix 2 of the MFAG.

6/9 Amendments to the EmS Guide Germany

Germany notices a seemingly unintentional editorial deletion in the draft revised EmS Guide (see CCC 4/6, annex 4) and therefore proposes to reinsert the special cases in schedule S-S.

6/10 Inclusion of Information on Segregation Groups in the Dangerous Goods List

Germany

Germany notes that whenever the segregation requirements of two or more different dangerous goods need to be determined, the segregation provisions can easily be retrieved from the dangerous goods table of the IMDG Code. However, the information on whether a particular substance is allocated to a segregation group requires detailed research in 653 entries of 18 segregation groups listed in chapter 3.1.4.4 of the IMDG Code.

It is advised that shippers and loaders in Germany easily overlook segregation allocations and that, forwarders and carriers had to stop container shipments because they contained mutually incompatible goods.

To avoid such confusion and for ease of reference, Germany proposes to provide the name or the number of the segregation code that a particular dangerous good is allocated to within the dangerous goods table.

It is therefore proposed to use specific codes, preceded by a unique reference such as SGG for segregation group, e.g. for UN 1908 CHLORITE SOLUTION, 8: "SGG 5", and to list these codes in column 16b, headlined "segregation". The detailed proposed changes and consequential amendments are set out in the document and the annex to this document (see CCC 4/6/10).

The Sub-Committee will consider the proposals above and take action as appropriate.

The proposal by Germany to provide the name or number of the segregation code for specific dangerous goods is welcome and ICS recommends that it should be supported.

6/11 Provisions for batteries installed in the cargo transport units

China

China makes a proposal on the transportation of UN 2800 (BATTERIES, WET, NON-SPILLABLE electric storage) installed in CTUsacting as the emergency power supply equipment of the container data centres secured in the same CTUs, which also consist of fixed fire suppression systems (UN 1044 – FIRE EXTINGUISHERS with compressed or liquefied gas) and air-conditioning systems (UN 2857 – REFRIGERATING MACHINES containing non-flammable, non-toxic gases or ammonia solutions).

It is noted that whilst such fire extinguishers and air-conditioning systems cannot be transported as normal cargo and the IMDG Code provisions apply to them, UN 2800 batteries are allowed to be carried as normal cargo exempted from the provisions of the IMDG Code so long as they meet the requirements of SP 238.

China further notesthat the draft amendments 39-18 to the IMDG Code introducedUN 3536 (LITHIUM BATTERIES INSTALLED IN CARGO TRANSPORT UNIT) assigned with a new special provision “389” that reads: “Dangerous goods necessary for the safe and proper operation of the cargo transport unit (e.g. fire extinguishing systems and air conditioning systems), shall be properly secured to or installed in the cargo transport unit and are not otherwise subject to this Code. Dangerous goods not necessary for the safe and proper operation of the cargo transport unit shall not be transported within the cargo transport unit.”

Consequently, it is observed that the batteries, as the power supply equipment of the IT machines secured in the same CTUs, can be transported as normal cargo when they meet the requirement of SP 238 for UN 2800. Furthermore, dangerous goods necessary for the safe and proper operation of the CTU, e.g. fire-extinguishing systems and air-conditioning systems, shall be properly secured to or installed in the cargo transport unit and are not otherwise subject to the provisions of the IMDG Code.

Therefore, the sponsor proposes a new SP "9XX" to be assigned to column (6) of UN 2800, chapter 3.2 of the Dangerous Goods List, and to be added to chapter 3.3 of the Special provisions applicable to certain substances, materials or articles. The Sub-Committee will consider the proposal and take action as appropriate.

6/12 Segregation provisions for uranium hexafluoride World Nuclear Transport Institute(WNTI)

WNTI provides further information to CCC 4/6/3 submitted by Germany, regarding the segregation requirements for uranium hexafluoride, in order to reflect the additional risk of class 6.1 that was assigned to it in the latest version of the IMDG Code.

Following an analysis of the current version of the IMDG Code, WNTI concludes that the requirements for segregation shall be a combination of those in table 7.2.4 for class 6.1, 7 and 8 for UN 2978 (RADIOACTIVE MATERIAL, URANIUM HEXAFLUORIDE non fissile or fissile-excepted) and UN 2978, and for class 6.1 and 8 for UN 3507 (URANIUM HEXAFLUORIDE, RADIOACTIVE MATERIAL, EXCEPTED PACKAGE, less than 0.1 kg per package, non-fissile or fissile-excepted). Taking into account that segregation rules for

class 8 cover those for class 6.1, it is stated the segregation rules should be as for class 7 and 8 for UN 2977 and UN 2978, and as for class 8 for UN 3507. Segregation codes SG17 and SG65 do not reflect exactly the segregation requirements needed for UN 2977 and UN 2978 due to their toxic and corrosive hazards. WNTI proposes a number of amendments to the Code to account for the findings of its analysis.

See also CCC 4/6/3

6/13 Battery-vehicles European Chemical Industry Council (CEFIC)

CEFIC states that the use of battery-vehicles for compressed gases is not included in the IMDG Code and they are currently shipped under exemptions by competent authorities as set out in chapter 7.9.1.2 of the IMDG Code; this paragraph also explains that consequently, when such exemptions are made by competent authorities, the Code needs to be amended to include provisions covered by the exemption.

CEFIC informsthe Sub-Committee of the intention to develop such requirements, in order to comply with paragraph 7.9.1.2.1 to have a permanent solution for the sea transport of battery-vehicles for compressed gases, and the relevantamendments to the IMDG Code are set out in the annex to the current document(CCC 4/6/13).

6/14 Proposed amendment to the shipping provisions for FISHMEAL (FISHSCRAP), STABILIZED (UN 2216)

Peru

Peru proposes to modify the draft amendments 39-18 for the shipping provisions in the IMDG Code for the transport of fishmeal, specifically the draft amendments to SP 308 and SP 945 relating to UN 2216 (FISHMEAL (FISHSCRAP), STABILIZED). Associated self-heating test results have been submitted as document CCC 4/INF.12 (see below).

It is noted that E&T 27 agreed the new provisions for stabilisation of Fishmeal to prevent spontaneous combustion by effectively applyingtocopherol but, restricted the application to non-bulk packages, i.e. to packages not exceeding 3 m³ capacity, as well as the lower residual ethoxyquin levels once again only for packages < 3,000 kg. The sponsor claims that the technical basis for this threshold is unclear, and it could be argued that as the volume of the packed fishmeal increases so the surface area exposure to the air (per unit volume) theoretically decreases, effectively reducing the risk of oxidation, not increasing it.

Following a detailed discussion, the sponsor’s proposal is to amend SP 308 and SP 945 as per below:

.1 delete the restriction of 3,000 kg in SP 308 "For packages containing not more than 3,000 kg,.."; and

.2 delete SP 945.

The Sub-Committee will consider the comments and proposals provided in this document

and take action as appropriate.

See also CCC 4/INF.12

6/15 Fire Incidents at a Container Terminal in an Iranian Port and comments in relation to the Emergency response procedures for ships carrying dangerous goods (EmS Guide)

Islamic Republic of Iran

The Republic of Iran advises that is has reviewed the draft revised EmS Guide prepared by E&T 27, and provides comments based on two fire incidents in respect of containers loaded with dangerous goods such as UN 3377 (SODIUM PERBORATE MONOHYDRATE) and UN 3378 (SODIUM CARBONATE PEROXYHYDRATE ) (usually added as disinfectant to detergents), occurring in port terminals during hot seasons with temperatures in excess of 50o C leading to chemical reaction and segregation of Hydrogen Proxy from the containers. It was noted that oxygen was produced as a result of an isometric reaction, which can create excessive heat and cause fire on the dunnage inside the container. Situated in a tropical area, Iranian ports have frequently seen more than the two incidents referred to in this paper.

In both incidents, fire followed the leakage of water and emission of gaseous vapour. In the first incident regarding UN 3378, water was used to extinguish the fire (in accordance with the EMS Guide and the dangerous goods list of the IMDG Code, EmS codes F-A, S-Q), but this was inefficient. In the second incident regarding UN 3377, water was used to extinguish the fire (in accordance with the EMS Guide and the dangerous goods list of the IMDG Code), but in addition to this being inefficient, the fire was also extended. Therefore,in both incidents water was unsuitable for extinguishing fire caused by these substances.

The sponsor proposes that water shall not be used for putting out fires resulting from the leakage of water and the emission of gaseous vapour from a container, particularly if the container is on board a ship or stowed in a container terminal, because of its potential to spread the fire. Therefore, it is suggested that the EmS Guide (F-A, S-Q) regarding UN 3377 and UN 3378 should be amended to an appropriate fire schedule and that column 15 of the IMDG Code dangerous goods list should also be amended.

See also CCC 4/6/16

6/16 Comments on document CCC 4/6/15 ICHCA International Ltd

Building upon Iran’s submission (see CCC 4/6/15 above), ICHCA recalls a major incident in Tianjin Port, China which led to catastrophic consequences including major loss of life.

The sponsornotes that containers with dangerous goods are often not segregated from others nor temporarily stored in satisfactory conditions and, that the IMDG Code itself is focused on the maritime side of such transport and even though IMO has made it mandatory for all shore-based personnel to be trained regarding the handling of dangerous goods, little guidance exists. Additionally the IMO Revised recommendations on the safe transport of dangerous cargoes and related activities in port areas

(MSC.1/Circ.1216) (latest edition being the 2007 Edition) are really aimed at port States and competent authorities to help them develop their own legislation and guidance.

Therefore, to cover the gap regarding any port State guidance or document comparable to the IMDG Code on handling and storing dangerous goods on the port side of the transport chain, and also noting that ports are ill-prepared for fires or other incidents involving dangerous goods, ICHCA and its industry partners are considering developing a guide based on the IMDG Code and other IMO instruments as there is high need at ports and terminals.

The sponsor also observes that IMO might consider that a review of MSC.1/Circ.1216 is overdue and could be augmented by more detailed recommendations on handling and storage of dangerous goods and emergency response in port.

See also CCC 4/6/15

6/17 Comments on document CCC 4/6 ICHCA International Ltd.

ICHCA provides some comments and observations of editorial nature, regarding the draft editorial corrections to amendment 38-16 and draft amendment 39-18 to the IMDG Code prepared by E&T 27.

The Sub-Committee will consider the comments and observations as set out in the annex, with a view to forwarding them to the twenty-eighth session of the Editorial and Technical Group for detailed consideration and possible incorporation into the editorial corrections to the amendment 38-16 or draft amendment 39-18 to the IMDG Code, as appropriate.

6/INF.12

Additional information regarding UN 2216 FISHMEAL (FISHSCRAP)

Peru

This document contains additional self-heating test data as support for the removal of the 3,000 kg restriction on the new draft fishmeal shipping provisions decided at E&T 27 in the draft amendments 39-18 to the IMDG Code (part 1), specifically the draft amendments to SP 308 and SP 945.

The Sub-Committee will note the information provided.

ITEM 7: UNIFIED INTERPRETATION OF PROVISIONS OF IMO SAFETY, SECURITY AND ENVIRONMENT-RELATED CONVENTIONS

The Sub-Committee will consider the unified interpretations, proposals and comments submitted to the session by Member States and international organizations, with a view to developing relevant IMO interpretations, as appropriate.

Papers:

7 Draft IACS Unified Interpretations to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels

International Association of Classification Societies

IACSprovides unified interpretations of paragraphs 6.8.2, 11.3.2 and 11.3.3 of Part A of the IGF code as follows:

1. With reference to paragraph 6.8.2 regarding the loading limit for liquefied gas fuel tanks, the concept of a “second system for pressure maintenance” is unclear as any pressure control by fuel consumers are excluded from this provision (including incineration of boil-off). The provision, to increase the loading limit beyond the calculated value using the reference temperature where these systems are installed, should therefore be removed. i.e. higher loading limits than calculated by 6.8.1 may be permitted, but never above 95%, provided:

the tank is well insulated and capable of accumulating pressure, i.e. satisfy the holding time required by 6.9.1.1 with ship in idle condition without re-liquefaction or incineration of boil-off; and

the tank is located in a fuel storage hold space separated from potential fire loads by cofferdams or surrounded by ship spaces with no fire load.

2. With reference to paragraph 11.3.2 regarding fire protection, boundaries of accommodation spaces, service spaces, control stations, escape routes and machinery spaces facing a fuel tank need not be shielded by A-60 class division, provided that the fuel tank and its tank connections are completely enclosed in A-0 class divisions. Vacuum insulated Type C tanks with integrated tank connection spaces are considered to be enclosed in A-0 class divisions.

3. With reference to paragraph 11.3.3 regarding fire protection, the following examples of "other rooms with high fire risk" should be considered as a minimum:

Cargo spaces except cargo tanks for liquids with FP above 60 degrees C and except cargo spaces complying with SOLAS II-2/10.7.1.4;

Vehicle, Ro-Ro and special category spaces; Service spaces (high risk): Galleys, pantries containing cooking

appliances, saunas, paint lockers and store-rooms having areas

of 4 m2 or more, spaces for the storage of flammable liquids and workshops other than those forming part of the machinery space; and

Accommodation spaces of greater fire risk for ships carrying more than 36 passengers: saunas, sale shops, barber shops and beauty parlours and public spaces containing furniture and furnishing of other than restricted fire risk and having deck area of 50 m2 or more.

ICS thanks IACS for the submission containing unified interpretations of provisions of the IGF code.

Comments for point 1: Refer to CCC 4/3/6/Rev.1

Comments for point 2: ICS has concerns that the suggested interpretation of paragraph 11.3.2 which removes the requirement for A-60 class division constitutes a reduction of the existing safety standards and thus cannot recommend support for the proposal.

7/1 Draft unified interpretation on the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels

International Association of Classification Societies

IACS proposes unified interpretation of paragraph 15.3.2 (Part A-1) of the IGF Code.

IACS identifies that the required "level indicator" specified in the paragraph is not used for measurement purposes, but for detection purposes to give a "high level" alarm for the bilge well. To clarify this understanding IACS proposes the interpretation that the 'level indicator' required by 15.3.2 of the IGF Code is understood to be required for the purposes of indicating an alarm status only and that a level switch (float switch) is an instrument example considered to meet this requirement.

Paragraph 15.3.2 contains provisions for the indication of high level and low temperature for bilge wells in each tank connection space of an independent liquefied gas storage tank.

ICS finds the interpretation provided in this submission to be practical and helpful. We would therefore recommend support for this proposal.

7/2 Draft unified interpretations on the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels

Belgium

Belgium proposes an interpretation to the IGF code requirement that Premixed engines using fuel gas mixed with air before the turbocharger should be located in ESD-protected machinery spaces. It is proposed that this requirement is exempted for premixed engines that are equipped with a

ventilation hood covering the entire engine, single walled gas pipe parts included provided that the ventilation capacity, fan motors and ventilation outlet complies with the requirements in IGF Code Part A-1, Section 9.6.1.2. Additionally, a gas detection system shall be installed in the hood that automatically cuts off the gaseous fuel supply when gas is detected.

ICS thanks Belgium for the submission. The proposal to exempt premixed engines form the requirement for ESD protection is not amply justified. The alternate provisions suggested could be accepted as equivalent to the ESD standard by the Administration at its own discretion. In order to maintain the goal based nature of the ESD philosophy, ICS cannot recommend support for this proposal.

7/3 Development of a unified interpretation for the use of electrical equipment in hazardous areas on gas-fuelled ships

Belgium

Belgium proposes to develop a unified interpretation of the IGF Code to clarify which electrical equipment can be used in hazardous areas. It is proposed to develop this unified interpretation in such a way that there is a common and equal base and approach in the implementation of the IGC Code and the IGF Code, taking into account existing standards such as IEC 60079-10-1:2015.

7/4 Definitions of the terms "each dry-docking", "high-level alarms" and "first occasion of full loading"

International Association of Classification Societies

IACS provides a copy of the latest version of IACS Unified Interpretation GC18 relating to paragraph 13.3.5 of the International Code for the Construction and Equipment of Ships Carrying Liquid Gases in Bulk (IGC Code), as amended by resolution MSC.370(93). In particular, this document contains interpretations of the terms "each dry-docking", "high-level alarms" and "first occasion of full loading" with respect to testing of overflow control of liquid cargo tanks.

IACS provides the following related interpretations:1. The expression "each dry-docking" refers to the survey of the outside

of the ship's bottom required for the renewal of the Cargo Ship Safety Construction Certificate and or the Cargo Ship Safety Certificate.

2. The expression "high-level alarms" refers to the high liquid level alarm(s) specified in paragraph 13.3.1 that give audible and visual warning when activated but does not include the additional independent sensor which activates the emergency shutdown system (ESD) and additional sensor(s) specified in paragraph 13.3.2 of the IGC Code.

3. The "first occasion of full loading" after "dry-docking" is considered to be the first loading where conditions allow for testing provided that the position of sensors for all high-level alarms(s), additional sensor(s) specified in paragraph 13.3.2 of the IGC Code, and sensor(s) which

activates the ESD were tested by simulation at the dry-docking. The testing of the high-level alarms with liquid cargo is to be recorded in the ship's logbook or cargo log by the Master and verified by the Administration or recognized organisation at the first annual survey after "each dry-docking".

ICS is aware of a potential lack of consensus within the industry regarding the UI, in particular the extent to which overfill shut-off and ESD should be included in the liquid test. The difference in views involves IACS and INTERTANKO on the one hand, and SIGTTO on the other.  

The standard practice on gas carriers is to conduct tests of all elements of the overfill control system using liquid cargo in accordance with the requirements of regulation 13.5.5 of the IGC Code. The draft UI limits the test in 13.5.5 to the high-level alarms and excludes overfill shut-off or ESD. Both approaches come with their own particular risks, however a full function test of the overfill control system is the only way to ensure that the systems work correctly and will protect the ship from the consequences of overfill.

Regardless of the relative merits of the proposed interpretation, In the absence of unified agreement within the industry on the interpretation of the testing requirements of the IGC Code, it would be unwise to recommend support for the UI. Similarly, alignment with the IGF Code is not a justification for supporting the UI.  

The intervention below is drafted on the assumption that differences of opinion within the industry are not resolved prior to the session. The intervention would be made following SIGTTO.   

ICS thanks IACS for the UI of the overfill prevention testing requirements of the IGC Code.  ICS considers that the UI may go beyond interpreting a requirement and may in fact amend and reduce the overfill control testing requirement in the IGC Code.

Furthermore, IACS and SIGTTO, both of whom contributed substantial expertise to the development of the Code do not agree on the UI. This should be cause for concern.   

Consequently, ICS is not able to recommend support for the UI and considers that its future consideration should be predicated on consensus amongst the experts. Moreover, in our view, ensuring alignment between the UI for the IGC Code and the UI for the IGF Code in CCC 4/7/5 should not be considered as sufficient justification for approving either UI.  

7/5 Definitions of the terms "each dry-docking", "high-level alarms" and "first occasion of full loading" in the IGF Code

International Association of Classification Societies

IACS provides a copy of the latest version of Unified Interpretation GF1 relating to paragraph 15.4.2 of the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), as adopted by resolution MSC.391(95). In particular, the document discusses the interpretation of the terms "each dry-docking", "high-level alarms" and "first occasion of full loading", with respect to the testing of high-level alarms in liquefied gas fuel tanks during maintenance surveys.

IACS provides the following related interpretations:1. The expression "each dry-docking" refers to the survey of the outside

of the ship's bottom required for the renewal of the Cargo Ship Safety Construction Certificate and or the Cargo Ship Safety Certificate for cargo ships and the survey of the outside of the ship’s bottom to be carried out every 60 months for passenger ships.

2. The expression "high-level alarms" is considered to be high liquid level alarm(s) specified in paragraph 15.4.2.1 that give audible and visual warning when activated but does not include the independent sensor(s) which activates the automatic shutdown of liquefied gas fuel tank filling and additional sensor(s) specified in 15.4.2.2 of the IGF Code.

3. "First occasion of full loading" after "dry-docking" refers to the first loading of the liquefied gas fuel where conditions allow for testing provided that the position of sensors for all high-level alarm(s) additional sensor(s) specified in 15.4.2.2 of the IGF Code and independent sensor(s) which activates the automatic shutdown of liquefied gas fuel tank filling were tested by simulation at the dry-docking. The testing of the high-level alarms with liquefied gas fuel is to be recorded in the ship's logbook by the Master and verified by the Administration or recognized organisation at the first annual survey of a cargo ship, or the first renewal survey of a passenger ship, after "each dry-docking".

IACS provides interpretation of the overfill prevention testing requirements of the IGF code similar to those provided in CCC 4/7/4 for the IGC code. See ICS comments and intervention under CCC 4/7/4. The concerns raised remain valid for the IGF code as well.

ITEM 8: CONSIDERATION OF REPORTS OF INCIDENTS INVOLVING DANGEROUS GOODS OR MARINE POLLUTANTS IN PACKAGED FORM ON BOARD SHIPS OR IN PORT AREAS

The Sub-Committee will consider reports on inspections of cargo transport units carrying dangerous goods in accordance with MSC.1/Circ.1442 (as amended by MSC.1/Circ.1521) and take action, as appropriate.

Papers:

8 Results of inspections on packaged dangerous goods Germany

Germany provides a report on the results of inspections carried out in Germany in 2016 on CTUs with packaged dangerous goods, in accordance with MSC.1/Circ.1442 as amended by MSC.1/Circ.1521 which urges Governments to implement such inspection programmes and report findings to IMO.

Out of a total of 9,907 CTUs inspected, 3,609 CTUs (39%) were found with deficiencies (for further details, see annexto the current document - CCC 4/8).

The Sub-Committee will note the information provided and take action as appropriate.

8/1 Results of inspections on containers with packaged dangerous goods

Sweden

Sweden provides a report on the results of inspections carried out in Sweden in 2016 on CTUs with packaged dangerous goods, in accordance with MSC.1/Circ.1442 as amended by MSC.1/Circ.1521 which urges Governments to implement such inspection programmes and report findings to IMO.

In Swedish legislation, inspections of packaged dangerous goods in port areas and inspections for CSC approval on board ships are conducted by different national authorities. The data provided in this paper only covers inspections in port areas of CTUs carrying packaged dangerous goods performed by the Swedish Coast Guard.

Out of 561 CTUs inspected, 122 CTUs (21.74%) were found with deficiencies (for further details, see annex to the current document - CCC 4/8/1).

The Sub-Committee will note the information provided and take action as appropriate.

8/2 Results of inspections on containers with packaged dangerous goods

Chile

Chile provides a report on the results of inspections carried out in Chile in 2016on CTUs transporting dangerous goods, in accordance with MSC.1/Circ.1202 of 2006, updated by MSC.1/Circ.1442 of 2014 which urges Governments to implement such inspection programmes and report findings to IMO.

Out of a total of 2,932 CTUs inspected, 206 CTUs (7.02%) were found with deficiencies (for further details, see annex to the current document - CCC 4/8/2).

The Sub-Committee will note the information provided.

8/3 Results of inspections on packaged dangerous goods United States

The United States provides a report on the results of inspections carried out in the USA in 2016 on CTUs carrying packaged dangerous goods, in accordance with MSC.1/Circ.1442 as amended by MSC.1/Circ.1521 which urges Governments to implement such inspection programmes and report findings to IMO.

Out of 23,809 CTUS inspected by the USCG, 1,923 (8.07%) were found with deficiencies.

Additionally, out of 30,481 CTUs inspected by the National Cargo Bureau (NCB), 2,729 8.95%) were found with deficiencies (for further details, see annex to the current document - CCC 4/8/3).

The Sub-Committee will note the information provided and take action as appropriate.

8/4 Comments on documents CCC 4/8, CCC 4/8/1, CCC 4/8/2 and CCC 4/8/3, including ananalysis of inspection results and wider issues of awareness of the CTU Code

ICHCA International Ltd

ICHCA draws attention to the very low percentage of IMO Member states reporting on container inspections (traditionally less than 10% - but about 2.5% at this session) and also the low number of inspections performed which has never exceeded 4 per 100,000 packed containers moved.

The sponsor also draws attention to the alarming deficiencies regularly reported, i.e. “Placarding and Marking” and “Stowage and Securing”.

In addition, the sponsor reports that during a recent seminar on dangerous goods, one shipping line revealed that many shippers disregard dangerous goods regulations by using alternative terms for dangerous goods in order to avoid surcharges and additional measures, including any ship or port restrictions, as well as the regulations themselves.

The sponsor anticipatesthat 1.16 million units with declared dangerous goods in 2015 could have had deficiencies and this does not take into account many units that are shipped with undeclared dangerous goods or non-regulated cargoes.

To help ameliorate the situation, ICHA and its partners (TT Club, GSF and WSC) have an awareness campaign on the importance of the CTU Code, which is not mandatory albeit referenced in the IMDG Code and SOLAS. The sponsor also urges member states to adopt the principles of MSC.1/Circ. 1442 as amended by MSC.1/Circ.1521, and step up their activity with regard to inspections and reporting.

It is additionallysuggested that the inspection programme needs to be reconsidered, and the following recommendations are made:

.1 while the substance of MSC.1/Circ.1442 applies to all cargo types packed in

CTUs, the title appears to restrict application to cargo declared to be dangerous. It is recommended that the title be amended;

.2 governments should be asked to identify what issues prevent them from inspecting CTUs and reporting the findings to IMO in a consistent and statistically viable fashion;

.3 inspections compliant with MSC.1/Circ.1442 are also carried out by entities that are not Competent Authorities. Such activity should be encouraged and facility made for it to be reported to IMO; and

.4 consideration should be given to advances in scanning technologies that may permit improved and risk-based inspections to be carried out more effectively.

It is advocated that training in CTU Code precepts could be considered in the same way as training in appropriate aspects of the IMDG Code is mandated for all that are involved in consigning dangerous goods.

ICHCA and its partners urge IMO Member States and industry bodies to work together to raise awareness of these issues, encourage reporting of non-compliance, and help to raise safety standards throughout the CTU supply chain.

The Sub-Committee will consider the above comments, especially the recommendations .1 to .4, the little data that is available and the potential scale of the issue, and consider what might be done to raise awareness and compliance in both governments and industry.alike.

Changing the title of MSC.1/Circ.1442 has previously been considered and rejected: see CCC 3/15 para 6.18 noting the decision of E&T 24 as outlined in CCC 3/6 para2 4.2 and 4.3:

“4.2 As instructed by CCC 2, the group discussed the possibility of finding a better way to express the circular's title, so that MSC.1/Circ.1442 is applicable to all cargoes carried in cargo transport units.

4.3 In this context, the majority of the group was of the view that the title of the circular correctly expresses the purpose of the inspections. The group was of the opinion that the title does not limit the scope to inspections of cargo transport units, which are declared to contain dangerous goods. It was noted that the title refers in general to inspections of cargo transport units with regard to the relevant provisions for the transport of dangerous good, and that other CTUs may be inspected in order to detect undeclared dangerous goods.”

ICSsupports the proposals of ICHCA. The low number of States reporting the outcome of Container inspections programmes is a significant concern, particularly taking into account the estimated numbers of containers carrying mis-declared dangerous goods cargoes. The CTU Code is an invaluable resource for the promotion of best practices in container handling and ICS endorses that States and stakeholders alike should make common use of it and, that it should be as widely promulgated as possible.

8/5 Results of inspections on packaged dangerous goods Republic of Korea

The Republic of Korea provides a report on the results of inspections carried out on a daily basis in six Korean ports (Busan, Yeosu, Incheon, Ulsan, Pohang and Pyeongtaek) by the competent authorities of the Regional Offices of Oceans and Fisheriesin 2016 on CTUs carrying packaged dangerous goods, in accordance with MSC.1/Circ.1442which urges Governments to implement such inspection programmes and report findings to IMO.

Out of a total of 6,310 CTUs inspected, 391 CTUs (6.19%) were found with deficiencies (for further details, see annex to the current document -CCC 4/8/5).

The Sub-Committee will note the information provided and take action as appropriate.

8/INF.4& Rev.1

Consolidated results of container inspection programmes

Secretariat

The Secretariat provides a consolidated report of container inspections based on the reports by Germany, Sweden, Chile, the United States and the Republic of Korea (see above).

Out of a total 73,400 CTUs inspected, a total of 8,324 (11.34%) were found with deficiencies, and the overall number of deficiencies was 11,327 (for further details, see annex to the current documents – CCC 4/INF.4 + CCC 4/INF.4/Rev.1)

ITEM 9: Biennial status report and provisional agenda for CCC 5

The Sub-Committee will review and update its biennial status report, as approved by MEPC 70 and MSC 97, taking into account the progress made at the session. The Sub-Committee will also prepare the draft biennial agenda for the 2018-2019 biennium together with the draft provisional agenda for CCC 5, in accordance with the Organization and method of work of the Maritime Safety Committee and the Marine Environment Protection Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5), for approval by MEPC 72 and MSC 99.

Papers:

No papers submitted.

ITEM 10: ELECTION OF CHAIR AND VICE-CHAIR FOR 2018

In accordance with the Rules of Procedure of the MSC and the MEPC, the Sub-Committee will elect its Chair and Vice-Chair for 2018.

ITEM 11: ANY OTHER BUSINESS

The Sub-Committee will consider any matters submitted under this agenda item by Member States or international organizations or referred to it by the committees or other sub-committees.

Papers:

11 Report of the Informal Industry Correspondence Group on Preventing the use of counterfeit refrigerants

IICL

IICL presents the “Industry best practices for preventing the use of counterfeit refrigerants” as developed through the Informal Industry Correspondence Group administered bythe IICL.

These best practices were developed to prevent incidents involving the use of counterfeit refrigerants, as encouraged by the DSC Sub-Committee in DSC 18/13, para 5.6. The best practices are set out in the current document and annex (CCC 4/11).

The Sub-Committee will note the information provided and take action as appropriate.

11/1 Development of measures to prevent loss of containersRevision of ISO 1161 and ISO 3874

ISO

ISO reports on the progress of the revision of its work to provide more detailed specifications and testing regimes for lashing gear through revisions to ISO standards 1161 (Series 1 freight containers – Corner fittings – Specifications) and 3874(Series 1 freight containers – Handling and securing), following the request of DSC 18 to ISO to revise ISO 3874 in regard to the equipment used on board ships to secure containers, taking into account the report of the Lashing@sea project.

A liaison has been established with Sub-Committee 4 (Outfitting and deck machinery) of ISO/TC 8 in respect of DIS 17905 (Ships and Marine Technology – Installation, Inspection and Maintenance of Container Securing Devices for Ships), which is a complementary standard to ISO 3874. The tables and required strength values for lashing gear are the same in both standards. The aforementioned action was a necessary step in establishing the mandate for reviewing the strength of lashing gear and securing devices as, otherwise, there was a danger of conflicting data between ISO 3874 and ISO 668. The review of the strength requirements of lashing gear and securing devices is also taking account of the latest generation of container vessels with design capacity in excess of 18,000 TEU.

Additionally, the new issue of ISO 3874, which is expected in autumn 2017, will include design and strength characteristics for automatic twistlocks which are already widely used, based on anecdotal evidence that automatic twistlocks may have had a part to play in recent losses of containers from vessels at sea.

With regard to ISO 1161 which was last revised and published in July 2016, the sponsor informs that the Chinese delegation that participates in the ISO Technical Committee has expressed its wish to bring modifications to this new standard, and therefore reopen the

dedicated work on this standard. The sponsor is currently expecting the Chinese proposal to be communicated to the ISO TC secretariat.

11/2 Report on activities related to the Global ACEP Database

BIC

The BIC provides a third report which is a regular update on activities related to the Global Approved Continuous Examination Programs (ACEP) Database. In total, 10 countries now use the database to publish their ACEPs, 7 of which have also updated the database since registering. 80 ACEPs have aggregately been entered in the database so far.

The sponsor highlights the importance of having a single publication location, for safety improvement reasons, and informs on how states can utilise the database.

The Sub-Committee will consider the information provided and to take action as appropriate.

11/3 Implementation in Chile of resolution MSC.380(94)of 21November 2014

Chile

Chile presents its experience following implementation ofresolution MSC.380(94) through national legislation,establishing the obligation to verify the gross mass of containers carrying cargo prior to stowage aboard ship to avoid accidents during navigation.

It is reported that one year after entry into force of the amendment, activities relating to such verification are conducted in a fully efficient and normal manner, there is full compliance with the obligations imposed by the new regulations, and there have been no difficulties of interpretation that might cause the measures to be inadequately incorporated in their legal system.The Sub-Committee is advised that the Maritime Authority will continue to observe and monitor this subject with a view to evaluating and proposing changes or updates to the current Maritime Circular, as necessary.

The Sub-Committee will take note of the information provided.

11/4 Update on the Deployment of the BoxTech Technical Characteristics Database

International Bureau of Containers (BIC)

BIC advises that its container Technical Characteristics Database (BoxTech) is eleven months into its launch,loaded with approximately 5 million containers, i.e. roughly 20% of the global fleet, and continues to grow. The sponsor informs that there are to be enhancements to the system in co-operation with industry partners, regarding safety, security and efficiency, such as container flagging and recovery alerts to help identify missing containers, special status and security alerts, and updates related to change of ownership to help ensure that containers are properly neutralised, remarked and inspected before re-entering the supply chain. More information on the database is available on https://www.bic-boxtech.org/faqs/ .

11/5 Estimate of containers lost at sea World Shipping Council (WSC)

In 2011, 2014 and again in 2017, the World Shipping Council (WSC) undertook a survey of its member companies to obtain a more accurate estimate of the number of containers lost at sea on an annual basis. For the combined nine-year period from 2008 to 2016, on average, the sponsor estimates that there were 568 containers lost at sea each year, not counting catastrophic events, and 1,582 containers lost at sea each year including catastrophic events. On average, 64% of containers lost during this period were attributed to a catastrophic event.

11/INF.16

The introduction of safety management system for packaged dangerous goods

Republic of Korea

The Republic of Korea advises of its developmentand test-operating of a safety management system for packaged dangerous goods transported by road in connection to maritime transport. The basic function of the system is to enable accident prevention and response agencies to make use of transport information on packaged dangerous goods in containers.

The safety management system collects real-time transport information on dangerous goods by utilizing beacons attached to containers with DG. If an emergency occurs, the system detects irregular indications and offers safety management and response information as well as an alarm, which can urge the agencies to take actions to the emergency effectively. This way the system provides an effective management method for transported dangerous goods. The sponsor claims that the system can eliminate blind spots in transport of dangerous goods and reduce the possibility of disaster with proper responses to accidents. More information is included in the annex provided with the document.

A diagram and more information are available in the annex to the current document (CCC 4/INF.16)

11/INF.18

Study on Quantitative Risk Assessment of a Medium-Sized Floating Regasification Unit

Republic of Korea

The Republic of Korea provides a report on the results of a research projectdesigned to investigate, through a case study, the risk of new compact LNG regasification systems, to be fitted on a medium-sized Floating Regasification Unit (FRU), by means of a Hazard and Operability (HAZOP) study during the design of the FRU.

ITEM 12: REPORT TO THE MARITIME SAFETY COMMITTEE AND THE MARINE ENVIRONMENT PROTECTION COMMITTEE

The Sub-Committee will consider its draft report on the session, for submission to the MSC and the MEPC for approval.