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UN 3077 EHS Solid Bulk Cargoes – how to comply with carriage requirements under the IMSBC Code

The carriage requirements of UN 3077 environmentally hazardous solid bulk cargoes under the IMSBC Code. This article has been updated. Please see ” UN 3077 Environmentally hazardous Solid Bulk Cargoes Update” issued on 3 June 2021

BIMCO is still receiving enquiries in relation to the carriage of solid bulk cargoes, in particular, mineral concentrates and metal sulphide concentrates carried under class 9 (miscellaneous dangerous substances and articles), “Environmentally Hazardous Substances (EHS), Solid, N.O.S, UN 3077” of the International Maritime Dangerous Goods (IMDG) Code.

Members should note that EHS solid bulk cargoes, UN 3077, ie cargoes that are hazardous to the aquatic environment or having a marine pollutant subsidiary risk, are not covered in the International Maritime Solid Bulk Cargoes (IMSBC) Code. As such, strictly speaking, as these are cargoes not listed in the Code, they will have to be carried under a tripartite agreement agreed upon by the competent authorities of the ports of loading/discharge and the ship’s flag state administration in accordance with section 1.3 of the IMSBC Code.

Mineral concentrates are classified only as Group A in the IMSBC Code, and if the concentrate in question contains sulphur and is liable to oxidise and self-heat, it will also be classified as a metal sulphide concentrate, making a mineral concentrate’s classification under the Code as a Group ‘ A and B’ cargo and classified as a material hazardous only in bulk (MHB). They are not considered dangerous cargoes as mineral concentrates and metal Sulphide concentrates are not UN 3077 cargoes as explained above.

Every mineral ore cargo is different when it is mined and processed like concentrates and the shipper is responsible for identifying, testing and declaring his cargo’s properties every time it is loaded. If the shipper has declared his mineral concentrate or metal sulphide concentrate cargo as UN 3077 possessing EHS properties, it means that it is a substance that is hazardous to the marine environment, meeting the EHS criteria laid out in section 2.9.3 of the IMDG Code. The basic EHS elements are the criteria meeting acute or chronic aquatic toxicity, potential for or actual bioaccumulation; and degradation for organic chemicals.

When a solid bulk cargo has been classified as UN 3077, it will be considered a dangerous cargo by virtue of it being Class 9 and carrying UN no. 3077.

However, there are certain countries where it is nationally legislated that such goods are classified as UN 3077 and hence you would have to comply with the requirements of the loading port/discharging port accordingly, which are over and above what is required in the normal compliance required by the IMSBC Code. Hence, whether this cargo should fall under the provisions of section 1.3 of the IMSBC Code would depend on the legislation of the exporting and discharging countries for these cargoes. If they are not covered as UN 3077 goods under national legislation or allowing these cargoes to comply with the requirements of the normal “mineral concentrates” and “metal sulphide concentrates” schedules in the IMSBC Code, then in our view, section 1.3 would apply and a tripartite agreement will be required to carry the cargo.

Therefore, BIMCO cannot emphasise enough that it would always be a prudent measure to check beforehand, the requirements at the port of loading/discharge when shipping the above-mentioned cargoes so as to ensure that the additional requirements, if any, imposed by these port authorities are adhered to apart from the normal compliance required by the IMSBC Code.

Please see our online cargo database for the carriage requirements of mineral concentrates and metal sulphide concentrate.
Source: BIMCO

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