I:\DSC\7\4-3.

doc

For reasons of economy, this document is printed in a limited number. Delegates are
kindly asked to bring their copies to meetings and not to request additional copies.

INTERNATIONAL MARITIME ORGANIZATION


IMO

E


SUB-COMMITTEE ON DANGEROUS
GOODS, SOLID CARGOES AND
CONTAINERS
7th session
Agenda item 4
DSC 7/4/3
29 July 2002
Original: ENGLISH

REVIEW OF THE BC CODE, INCLUDING EVALUATION OF PROPERTIES
OF SOLID BULK CARGOES

Comments on the schedules of the draft revised BC Code

Submitted by Japan



SUMMARY

Executive summary:

This document provides comments to the proposal by the Netherlands
regarding the schedules for solid bulk cargoes in the draft revised
BC Code

Action to be taken:

Paragraph 15

Related documents:

DSC 7/4/2, DSC 6/5/1, DSC 7/2/Add.1, DSC 4/5/3, DSC 4/14,
IMDG Code


General

1 This document is submitted in accordance with paragraph 46.5 of the Guidelines on the
organization and method of work (MSC/Circ.931) and provides comments to the proposal by the
Netherlands regarding the schedules for solid bulk cargoes in the draft revised BC Code as
contained in the document DSC 7/4/2.

2 Japan appreciates the effort of the Netherlands on the revision of the draft BC Code and is
in favour of the opinion of the Netherlands that standard sentences should be used in the
BC Code. Taking into account the request by MSC on human element-related matters
(DSC 7/2/Add.1), the opinion of the Netherlands is rational and important.

3 Japan further is in favour of the opinion of the Netherlands that MSC/Circ.671 should be
up-dated to adjust the names of cargoes used in the revised BC Code. To facilitate the work of
amendments to MSC/Circ.671, the working group at the last session of the Sub-Committee
developed the draft revised MSC/Circ.671 as provided in the annex 1 of the document DSC 7/4
(DSC 6/WP.4).

DSC 7/4/3 - 2 -


I:\DSC\7\4-3.doc
BROWN COAL BRIQUETTES

4 In the draft revised MSC/Circ.671 (DSC 7/4, annex 1), "BROWN COAL BRIQUETTES"
is listed in Table 1. The Netherlands pointed out the inconsistency between the draft
MSC/Circ.671 and the individual schedule of this cargo (DSC 7/4/2, annex 2, page 6).
Regarding this cargo, Japan would like to invite the Sub-Committee to recall several issues.

5 The inclusion of this cargo into the BC Code was proposed by Australia in document
DSC 4/5/3, based on the sufficient experience of safe carriage and the amendment to the
BC Code was agreed by the Sub-Committee (DSC 4/14, paragraphs 5.28 and 5.40 and annex 2).
In the proposal by Australia, it was pointed out that BROWN COAL BRIQUETTES were
shipped according to the precautions and requirements for coal (c.f. DSC 4/5/3, paragraph 3). At
this time, there was no discussion on MSC/Circ.671 and scope of application of the requirements
in chapter II-2 of SOLAS Convention. Thus, the correspondence group on the revision of the
BC Code invited the Sub-Committee to consider the inclusion of this cargo and "PEAT MOSS"
in MSC/Circ.671 (c.f. DSC 6/5/1 paragraph 24 and 31.10).

6 The first sentence in regulation 10.7.1.4 of revised chapter II-2 of the Convention is as
follows:

"The Administration may exempt from the requirements of paragraphs 7.1.3 and 7.2,
cargo spaces of any cargo ship if constructed, and solely intended for, the carriage of ore,
coal, grain, unseasoned timber, non-combustible cargoes or cargoes which, in the opinion
of the Administration, constitute a low fire risk."

This sentence does not mean that coal is a cargo, which constitute a low fire risk. Coal is a cargo
for which a fixed gas fire-extinguishing system may be exempted similar to cargoes, which
constitute a low fire risk.

7 Taking above-mentioned issues into consideration, Japan considers that MSC/Circ.671
can be amended as follows:

"LISTS OF SOLID BULK CARGOES WHICH ARE NON-COMBUSTIBLE OR
CONSTITUTE A LOW FIRE RISK FOR WHICH A FIXED GAS
FIRE-EXTINGUISHING SYSTEM MAY BE EXEMPTED OR FOR
WHICH A FIXED GAS FIRE-EXTINGUISHING SYSTEM
IS INEFFECTIVE

2 The Committee also agreed the annexed table 1 which provides a list of solid bulk
cargoes which are non-combustible or constitute a low fire risk, for which a fixed gas
fire-extinguishing system may be exempted and recommended Member Governments to
take into account the information contained in that table when granting exemptions under
the provisions of regulation II-2/53.1. II-2/10.7.1.4

Table 1

List of solid bulk cargoes which are non-combustible or constitute a low fire risk for which
a fixed gas fire-extinguishing system may be exempted

Cargoes listed in regulation II-2/53 II-2/10.7.1.4

Ore
Coal (COAL BC No: 010 and BROWN COAL BRIQUETTES BC No:002)
Grain
Unseasoned timber

- 3 - DSC 7/4/3


I:\DSC\7\4-3.DOC
Cargoes listed in the Code of Safe Practice for Solid Bulk Cargoes (BC Code) which are
non-combustible or constitute a low fire risk"

This draft can dissolve the inconsistency regarding BROWN COAL BRIQUETTES between
MSC/Circ.671 and the BC Code.

SULPHUR

8 The Netherlands pointed out the lack of sentences for precautions on dust explosion in the
schedule for SULPHUR (DSC 7/4/2, annex 2, Page 25). In relation to this, Japan would like to
invite the Sub-Committee to further consider the applicability of this schedule.

9 In the IMDG Code, special provision 242 (SP 242) is applied to Sulphur UN 1350.
SP 242 is as follows:

"Sulphur is not subject to the provisions when it has been formed to a specific shape
(such as prills, granules, pellets, pastilles or flakes).

Note AMENDMENT 31-02 on SP 242: Delete "when it is transported in quantities of
less than 400 kg per package, or"

10 In the BC Code, there is a schedule for SULPHUR (lumps and coarse-grained powder)
and carriage of fine-grained sulphur in bulk is prohibited but there is no schedule for SULPHUR
formed to a specific shape. Japan would like to invite the Sub-Committee to consider SULPHUR
formed to a specific shape.

11 To keep the consistency between the IMDG Code and the BC Code, SULPHUR formed
to a specific shape should not be classified as dangerous goods. However, Japan considers that
SULPHUR formed to a specific shape can be classified into MHB, because dust may be
generated resulted from handling of this cargo in bulk. The precautions for the carriage of
SULPHUR formed to a specific shape are supposed to be the same as those for the carriage of
SULPHUR (lumps and coarse-grained powder).

12 The possible draft schedule including SULPHUR formed to a specific shape is as follows
(schedule for SULPHUR (lumps and coarse-grained powder) in DSC 6/5/1):

SULPHUR (lump and coarse grained) UN No. 1350 and BC No.???

DESCRIPTION

Fine grained sulphur (flowers of sulphur) should NOT be transported in bulk. Lump or
coarse-grained sulphur is classified into dangerous goods of class 4.1 and UN number
is 1350. Sulphur formed to a specific shape (such as prills, granules, pellets, pastilles or
flakes) is classified as MHB and BC number is???. Ignites readily. When involved in a
fire, toxic, very irritating and suffocating gas is evolved. Forms explosive and sensitive
mixtures with most oxidizing material. Bulk Sulphur has a liability to dust explosion
which may occur especially after discharge and during cleaning. Fine grained sulphur
(flowers of sulphur) should NOT be transported in bulk.
DSC 7/4/3 - 4 -


I:\DSC\7\4-3.doc

CHARACTERISTICS

ANGLE OF REPOSE BULK DENSITY (KG/M
3
) STOWAGE FACTOR
(M
3
/T)
Not applicable [1053 1176] [0.85 0.95]
SIZE CLASS GROUP
[Slate to 10 mm granules &
prills to 5 mm]
4.1 or MHB B

13 The precautions for dust explosion after discharge and during cleaning are provided in the
draft schedule for SULPHUR (DSC/6/5/1, annex 2). The hazard of dust explosion during
loading and unloading is also pointed out in column "HAZARD". Taking these issues into
account, the concrete precautions for dust explosion should further be provided in the columns
for "LOADING" and "DISCHARGE", in particular, prevention of spark.

14 In the existing BC Code, it is pointed out in column for "Observation" in the schedule for
SULPHUR that residues are highly corrosive to steel, in particular in the presence of moisture.
In the draft schedule for SULPHUR in column for "HOLD CLEANLINESS", lime washing is
required. However, corrosivity of sulphur is not pointed out in general. The hazard due to
corrosion should clearly be pointed out in column for "HAZARDS".

Action requested of the Sub-Committee

15 The Sub-Committee is invited to consider above proposals and comments, and take
action, as it deems appropriate, in particular, on the schedule for SULPHUR.


___________