In response to a number of queries in respect of the Shipment of "Metal Sulphide Concentrates UN 3077" ("MSC"), the Association is pleased to provide the following information to Members, which hopefully will be of assistance. The queries typically relate to shipments involving Australia where a cargo that is a MSC will be considered environmentally hazardous in relation to MARPOL Annex V (effective 1 January 2013).
Substances which are classified in this manner are those which are not necessarily otherwise classified as a dangerous cargo, yet they have a possible environmental hazard property, specifically a possible toxic threat to marine life.
In order to determine whether a particular cargo is UN 3077 (following a United Nations categorization, and the implementation of the IMDG 2008) it needs to be tested to see if, when introduced into a marine ecology system, the cargo presents a toxic danger to the marine environment. Such information should be declared by Shippers in the cargo declaration prior to loading.
One of the challenges in shipping such cargo is that while the IMSBC speaks of cargoes with a potential chemical hazard (Category B), the cargoes with a possible environmental hazards may not be so specifically categorized. Hence default rules for shipment under the IMSBC may apply.
Thus approval for carriage may need to obtained from authorities in ports of loading as well as ports of discharge, and indeed both flag and / or class may also have comments or conditions before approving the carriage of a particular cargo, as the Association was made aware of in a recent case for Members.
Obtaining such approvals can be time consuming and be the cause of delays, unless appropriate arrangements are made in advance of the proposed lift.
Cargoes which may fall into this category can include:
- zinc sulphide concentrate
- copper sluphide concentrate
- lead sulphide concentrate
- nickel sulphie concentrate
Some of these cargoes may also fall under Category A or B of the IMSBC, and reference is made to the applicable part of that Code for issues in relation to risks of liquefaction and / or chemical hazards.
Where and how is such cargo produced
Australia is famous, amongst many reasons, for its extensive mining industry, found across the continent. The term "Metal Sulphide Concentrates" ("MSC") is a general description casting an umbrella over a number of concentrates such as iron, lead, lithium, zinc, copper, aluminium, nickel, magnesium, etc. Please see the link that provides maps over different mine locations. In particular see map 18.26.
Metal concentrates are generally produced from the sulphide ores from metal mines. The most common ones are copper, lead, and zinc. The raw ore is ground finely in various operations to remove waste in order to concentrate the metal component.
Export volumes / import destinations
Statistics for export volumes and destinations are available for different types of metal concentrates. Please refer to the Quarterly from the Bureau of Resources and Energy Economics, in particular to page 133 for export volumes and import destinations.
For statistics on national production of minerals on a world scale please see the following table at Geoscience Australia's website.
The varied nature of the possible Environmental Hazard
The question of environmental hazard in this context is focused on the issue of possible toxic threat to the marine environment, should the cargo be introduced into the sea (for whatever reason).
As stated above, this is a question of having a particular cargo subjected to testing to determine if it would present a toxic risk should it enter the marine environment. Shippers should ensure that such necessary testing is carried out in advance, and in accordance with applicable government regulations / authority approval (in Australia these matters are regulated with the involvement of AMSA).
In case of doubt or concern which is not adequately addressed by the shippers in advance of loading, Members should feel free to contact the Association for further assistance at any time.
Other Potential Environmental Hazards
There are other potential issues, however, which the Association would like to address with Members as part of the overall advisory.
Risk of Dust Contamination
Very dry cargo can give off dust when moved, and if this is caught by strong winds, it may spread a significant distance. Thereafter claims can follow from nearby residential areas. Given that many cargo producing, storage and loading areas are in dry and arid regions in Australia, cargo can come on board in very dry conditions.
While in Australia it appears that the facilities available at load ports have mitigated these risks, in other countries where such cargoes may be discharged there may be a lower level of preparedness to deal with such circumstances.
The Association has dealt with claims for cleaning of cars and houses, alleged damage to personal property as well as alleged health claims, where during cargo operations dust was carried from the vessel to nearby areas.
Residual Health Concern Issues
Lead as a material and as a cargo has known health implications which may make ports, authorities and stevedores very reluctant to deal with such material unless it is a designated and expected cargo.
The Association is aware of a vessel discharging limestone cargo, when reaching the final tonnes of cargo to be discharged, a dark powder was found by stevedores who called for a halt in operations. When it was established that the previous cargo was lead concentrate, all further work was halted and the vessel eventually had to sail without being able to fully discharge as the local port would not accept the discharge of this lead concentrate residue.
Loss Prevention Advice
The advice is that whenever concentrates were loaded previously it will always be necessary to wash hold very thoroughly, especially when loading a cargo of wheat next, say in Australia, where very strict inspection routines are in place.
Furthermore, great care has to be taken to ensure that residues are disposed of appropriately, in accordance with local laws and regulations as well as MARPOL.
Practical advice on shipment
The advices given by AMSA in respect of shipping of metal sulphide concentrates are as provided in M-notice 19/2010 (with reference to subsequent notices).
Furthermore the amended IMSBC Code Appendix 1 provides that ships transporting MSC must be equipped with modern fire extinguishing systems, there may be exceptions for certain specific cargoes which are deemed a low fire risk, but this should be checked specifically prior to entering into a fixture for carriage of MSC.
It will, however, be necessary to ascertain the precise nature of the cargo to be laden, in each and every case, and to ensure the shipper provides a complete and accurate cargo declaration - on the basis of which the proper risk analysis in relation to the cargo can be carried out.
Where Members are not sure as to what cargo is being proposed for carriage, it would be prudent to seek in advance information on the exact nature of the cargo prior to concluding the fixture so that the shipment can be assessed and prepared for appropriately.
If at any stage Members or the master become concerned, they should feel free to contact the Association at any time, and in case of emergencies, the club's correspondents are available to assist around the clock.
For further reading, Members are referred to the following, reproduced with this article:
- AMSA Marine Notice 19/2010 (and Members may further wish to look at Notices 17/2012 and 19/2012)
- Australian Submission to the IMO in respect of Environmental Hazard Classification 9 July 2010
- Australian Government Resources and Energy Quarterly September Quarter 2013
The Association is grateful to Correspondents Aus Ship P&I / James Neill Solicitors for contributing to this article.