Regulatory Primer for Mates & MastersRegulatory Primer for Mates & Masters 16 3. General Cargoes and Offshore Que. What are the amendments to the regulations affecting container cargoes and when did they enter into force? Ans. Regulation 2 of SOLAS Chapter VI was amended to formalise the requirement for the shipper of packaged containers to verify and provide a container’s gross mass to the carrier and terminal representative prior to it being loaded onto the ship, the carrier in this case being the Master or his representative. This amendment was needed because incorrect declaration of the gross mass of packed containers has led to a number of safety-related incidents in port and at sea. The amendments entered into force on 1st July 2016. MGN 534 provides detailed guidance for UK shippers, terminals and carriers on implementing the SOLAS VI provisions. Specifically, it sets out two methods for obtaining an accurate gross mass and confirms that the responsibility for obtaining and documenting this rests with the shipper. A container should therefore not be loaded onto a ship unless the Master or his representative have been provided with, in advance of vessel loading, the verified actual gross mass of the container. Ref: MSC.1/Circ.1475 and MGN 534 Que. When carrying road freight units that require an electrical supply, who is responsible for the extension cable between the vessel and the road freight unit? Ans. The quality of the vessel’s electrical equipment is the liability of the shipowner and the quality of the electrical installations on the road freight unit is the liability of the unit’s owner and driver. The party responsible for providing the extension cable between the vessel and the road freight unit is responsible for its condition and performance. Regulatory Primer for Mates & MastersRegulatory Primer for Mates & Masters 17 Que. What is the IMDG Code and what is the most recent edition? Ans. The International Maritime Dangerous Goods (IMDG) Code is a uniform code for the international transport of dangerous goods by sea. The Code falls under SOLAS Chapter VII, which requires the carriage of dangerous goods to be in compliance with the relevant provisions of the Code. The Code covers topics such as packing, transportation, stowage and segregation of incompatible cargoes. Under the Code, dangerous goods are divided into a series of classes according to hazard, e.g. explosive, flammable or radioactive. The Code is split into two volumes (the 1st volume provides detailed guidance on hazardous goods classification, packing and consignment and the 2nd volume is the Dangerous Goods List) and a supplement (covering emergency response, medical first aid and reporting procedures). The latest edition of the IMDG Code is the 2018 edition, which was approved at MSC 99 in May 2018. This edition entered into force on 1st January 2020 (as per Resolution MSC.442(99)). The 2014 edition entered into force on 1st January 2016 and was itself amended by amendment 38-16 (see next question). Ref: IMDG Code Que. What are the most recent amendments to the IMDG Code? Ans. In May 2016, the IMO adopted amendment 38-16 to the IMDG Code. These amendments entered into force on 1st January 2018. The amendments have substantially revised the text of the Code and included are new UN numbers and a new Class 9 label for use when lithium metal and lithium ion cells are being shipped. Amendment 39-18 to the IMDG Code entered into force on 1st January 2020 (as per Resolution MSC.442(99)), incorporating revision of the classification categories. The Emergency Response Regulatory Primer for Mates & MastersRegulatory Primer for Mates & Masters 18 Procedures for Ships Carrying Dangerous Goods (EmS Guide) have also been completely revised by this amendment. For UK ships, MSN 1893 explains the amendment 39-18 and the changes to the IMDG Code. Que. What is the Document of Compliance in relation to dangerous goods? Ans. The Document of Compliance (DOC) for ships carrying dangerous goods is required under SOLAS Regulation II-2/19. This Regulation provides specific construction and equipment requirements for ships carrying dangerous goods, including separation requirements, additional water and fire-fighting requirements, bilge pumping and drainage arrangements, ventilation arrangements and RoRo specific requirements. The DOC is evidence of compliance with these requirements. In the UK, the MCA includes an annual survey for the arrangements of the DOC within the Safety Equipment Survey. Further information is contained in MGN 36. Que. When given a specific UN number, how should the IMDG Code be consulted? Ans. Volume 2 of the IMDG Code should be consulted first, specifically Part 3 as this contains the Dangerous Goods List. This lists the most commonly transported DGs and is organised by UN number. The list can be used to identify the UN number, proper shipping name and appropriate provisions for safe transportation (including Class, subsidiary hazards, packing group, special provisions, EmS details, stowage, handling and segregation). Reference should then be made to the IMDG Code Volume 1 and also the Supplement to obtain further, more detailed guidance on each aspect. Regulatory Primer for Mates & MastersRegulatory Primer for Mates & Masters 19 Que. Amendments to the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) were approved in 2010. What were these and on what ships is a Cargo Securing Manual required? Ans. The purpose of this Code is to ensure that persons engaged in carrying out container securing operations on deck have safe working conditions, safe access, appropriate securing equipment and safe places of work. The amendments were required because of the high number of accidents and injuries to stevedores, who have no control over the safety standards and lashing equipment encountered on board ships. The main areas of concern include inadequate working platforms, poor fall protection structures, poor access, insufficient working space, and difficult and awkward lashing equipment. Instances have occurred when a ship has not been permitted to load or discharge cargo due to the unacceptable conditions on board the vessel, leaving either the ship’s crew to complete the work or the vessel to work the cargo at another, more amenable port. Some sections of the Code apply to existing ships, not just new builds, and include maintenance, training and specialised container safety design. Reference is also made to the lashing of cargo units and vehicles in ships (Resolution (A.533(13)) and the maximum securing load of lashings on RoRo ships (Resolution (A.581(14)). In 2014, the IMO issued circular MSC.1/Circ.1353 which requires all types of ships engaged in the carriage of cargoes other than solid and liquid bulk cargoes to carry on board a Cargo Securing Manual that has been drawn up in accordance with the CSS Code and approved by the Administration. Regulatory Primer for Mates & MastersRegulatory Primer for Mates & Masters 20 The manual must cover all relevant aspects of cargo stowage and securing, including: • Cargo securing devices (both fixed and portable) • maximum securing load (MSL) of devices, such as lashings. MSL is used to define the allowable load capacity for a device used to secure cargo to a ship. Note that safe working load (SWL) may be substituted for MSL for securing purposes, provided this is equal to or exceeds the strength defined by MSL • inspection and maintenance • stowage, safety, handling and security information • the Cargo Safe Access Plan (CSAP). Que. What guidance has the MCA issued regarding cargo stowage and securing? Ans. MGN 552 – Safe Stowage and Securing of Specialised Vehicles was published by the MCA in April 2016. It highlights the potential hazards when carrying specialised vehicles and the importance of vessel suitability, experienced cargo handlers, an appropriate cargo securing manual, sufficient number and strength of lashings, and cargo distribution that maintains vessel stability. Que. What is OVID? Ans. OVID (Offshore Vessel Inspection Database) is a web-based inspection tool and database of inspection reports; it is underpinned with professional, trained and accredited inspectors. Released by OCIMF in early 2010, it is hoped that OVID will form a tool that is central to the selection and assurance of offshore vessels, complemented by an Offshore Vessel Management Self-Assessment (OVMSA) protocol, which will inform oil company assurance teams of the capabilities of the vessel/unit’s managing organisation. OVID covers the following types of offshore vessels: • Supply vessels • AHTS Regulatory Primer for Mates & MastersRegulatory Primer for Mates & Masters 21 • standby vessels • DSVs • drill ships • cable-laying vessels • semi-submersibles, etc. OVID does not include vessels such as shuttle tankers that are already covered in SIRE (Ship Inspection Report Programme). Note: OVID was designed to provide a number of positive benefits to OCIMF/OGP members and vessel managers. In using a database where inspection reports are available to OVID participating members, experience has demonstrated that inspection numbers will drop over time. Assurance checks as a part of the chartering process may be speeded up as the assurance personnel have access instantly to credible information on the vessel and its safety performance. OCIMF members have cooperated to develop a common inspection document and format that will eliminate the need for inspectors to conduct inspections using a core document and client-specific supplements. This should simplify the inspection process for both inspectors and ships’ staff and also provide assurance personnel in the oil companies with increased confidence in the inspection report content. The provision of a document detailing vessel/unit principal dimensions and equipment will give vessel operators the ability to ‘showcase’ its capabilities and provide a tool to project teams to pre-screen vessels that are capable of undertaking the required activities. Having this document controlled by the vessel/unit operator allows for rapid amendment to reflect vessel enhancements and allows project teams to quickly evaluate the vessel’s improved capabilities. Que. What is CMID? Ans. CMID is the Common Marine Inspection Document, which is an alternative to OVID. It is administered by the International Marine Contractors Association (IMCA). As the inspection system is voluntary, the use of either CMID or OVID is the decision of the company.