IMO: Exemptions & challenges for bulk cargo fire systems

The International Maritime Organization has issued the revised 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.

Circular MSC.1/Circ.1395/Rev.6 was issued on 26 June 2023 and supersedes MSC.1/Circ.1395/Rev.5.

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

1. The Maritime Safety Committee, at its sixty-fourth session (5 to 9 December 1994), agreed that there was a need to provide Administrations with guidelines regarding the provisions of SOLAS regulation II-2/10 concerning exemptions from the requirements for fire-extinguishing systems.

2. Consequently, the Committee approved MSC/Circ.671 whereby it agreed to:

a list of solid bulk cargoes, for which a fixed gas fire-extinguishing system may be exempted (table 1) and recommended Member States to take into account the information contained in table 1 when granting exemptions under the provisions of SOLAS regulation II-2/10.7.1.4; and
a list of solid bulk cargoes for which a fixed gas fire-extinguishing system is ineffective (table 2), and recommended that cargo spaces in a ship engaged in the carriage of cargoes listed in table 2 be provided with a fire-extinguishing system which provides equivalent protection. The Committee also agreed that Administrations should take account of the provisions of SOLAS regulation II-2/19.3.1 when determining suitable requirements for an equivalent fire-extinguishing system.

3. The Maritime Safety Committee, at its seventy-ninth session (1 to 10 December 2004), reviewed the above-mentioned tables and approved MSC/Circ.1146. The Committee decided that the annexed tables should be periodically reviewed and invited Member States to provide the Organization, when granting exemptions to ships for the carriage of cargoes not included in table 1, with data on the non-combustibility or fire risk properties of such cargoes. Member States were also requested to provide the Organization, when equivalent fire-extinguishing systems are required for the agreed carriage of cargoes not included in table 2, with data on the inefficiency of fixed gas fire-extinguishing systems for such cargoes.

4. The Maritime Safety Committee, at its eighty-ninth session (11 to 20 May 2011), noting the mandatory status of the IMSBC Code, reviewed the aforementioned lists of solid bulk cargoes to align certain names in the lists with those in the recent version of the IMDG Code and approved MSC.1/Circ.1395 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, superseding MSC/Circ.1146. The Maritime Safety Committee, at its ninety-second session (12 to 21 June 2013), approved a revision of MSC.1/Circ.1395 (MSC.1/Circ.1395/Rev.1).

5. The Maritime Safety Committee, at its ninety-fifth session (3 to 12 June 2015), considering a proposal by the Sub-Committee on Carriage of Cargoes and Containers, at its first session, approved a revision of tables 1 and 2 of MSC.1/Circ.1395/Rev.1 (MSC.1/Circ.1395/Rev.2).

6. The Maritime Safety Committee, at its ninety-eighth session (7 to 16 June 2017), considering a proposal by the Sub-Committee on Carriage of Cargoes and Containers, at its third session, approved a revision of tables 1 and 2 of MSC.1/Circ.1395/Rev.2 (MSC.1/Circ.1395/Rev.3).

7. The Maritime Safety Committee, at its 101st session (5 to 14 June 2019), considering a proposal by the Sub-Committee on Carriage of Cargoes and Containers, at its third session, approved a revision of tables 1 and 2 of MSC.1/Circ.1395/Rev.3 (MSC.1/Circ.1395/Rev.4).

8. The Maritime Safety Committee, at its 105th session (20 to 29 April 2022), considering the proposal by the Sub-Committee on Carriage of Cargoes and Containers, at its seventh session, approved a revision of tables 1 and 2 of MSC.1/Circ.1395/Rev.4.

9. The Maritime Safety Committee, at its 107th session (31 May to 9 June 2023), considering the proposal by the Sub-Committee on Carriage of Cargoes and Containers, at its eighth session, approved a revision of MSC.1/Circ.1395/Rev.5, as set out in the annex.

10. The purpose of this circular is to provide guidance to Administrations. However, Administrations are not prevented from granting exemptions for cargoes not included in table 1 or imposing any conditions when granting such exemptions under the provisions of SOLAS regulation II-2/10.7.1.4.

11. This circular supersedes MSC.1/Circ.1395/Rev.5.

ANNEX

TABLE 1 List of Solid Bulk Cargoes for Which a Fixed Gas Fire-Extinguishing System May Be Exempted

1. Cargoes including, but not limited to, those listed in SOLAS regulation II-2/10:
Ore
Coal (COAL and BROWN COAL BRIQUETTES)
Grain
Unseasoned timber

2. Cargoes listed in the International Maritime Solid Bulk Cargoes (IMSBC) Code, which are not combustible or constitute a low fire risk, as follows:
.1 all cargoes not categorized into group B in the IMSBC Code;
.2 the following cargoes categorized into group B in the IMSBC Code:

ALUMINA HYDRATE
ALUMINIUM SMELTING BY-PRODUCTS UN 3170
(Both the names ALUMINIUM SMELTING BY-PRODUCTS or ALUMINIUM REMELTING BY-PRODUCTS are in use as proper shipping name)
ALUMINIUM FERROSILICON POWDER UN 1395
ALUMINIUM SILICON POWDER, UNCOATED UN 1398
AMORPHOUS SODIUM SILICATE LUMPS
BORIC ACID
CLINKER ASH
COAL TAR PITCH
DIRECT REDUCED IRON (A) Briquettes, hot-moulded
ELECTRIC ARC FURNACE DUST, PELLETIZED
FERROPHOSPHORUS (including briquettes)
FERROSILICON UN 1408, with 30% or more but less than 90% silicon (including briquettes)
FERROSILICON, with at least 25% but less than 30% silicon, or 90% or more silicon
FLUE DUST, CONTAINING LEAD AND ZINC
FLUORSPAR
GRANULATED NICKEL MATTE (less than 2% moisture content)
LEACH RESIDUE CONTAINING LEAD
LIME (UNSLAKED)
LOGS
MAGNESIA (UNSLAKED)
MATTE CONTAINING COPPER AND LEAD
MONOCALCIUMPHOSPHATE (MCP)
MONOAMMONIUM PHOSPHATE (M.A.P.), MINERAL ENRICHED COATING
PEAT MOSS
PETROLEUM COKE (calcined or uncalcined)*

* When loaded and transported under the provisions of the IMSBC Code.

PITCH PRILL
PULP WOOD
PYRITES, CALCINED (calcined pyrites)
RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-I), non-fissile or fissile-excepted UN 2912
RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECTS (SCO-I), non-fissile or fissile-excepted UN 2913
ROUNDWOOD
SAND, MINERAL CONCENTRATE, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-I) UN 2912
SAW LOGS
SILICOMANGANESE (low carbon)
SULPHUR, UN 1350 (crushed lump and coarse grained)
SUPERPHOSPHATE (triple, granular)
TIMBER
VANADIUM ORE
WOODCHIPS, with moisture content of 15% or more
WOOD PELLETS NOT CONTAINING ANY ADDITIVES AND/OR BINDERS
ZINC ASHES UN 1435
ZINC OXIDE ENRICHED FLUE DUST

3. Cargoes assigned to the following generic group B shipping schedules when they do not exhibit any self-heating, flammability or water-reactive flammability hazards in accordance with the MHB tests and classification criteria contained in the Code:

METAL SULPHIDE CONCENTRATES
METAL SULPHIDE CONCENTRATES, CORROSIVE UN 1759

3. Solid bulk cargoes which are not listed in the IMSBC Code, provided that:
.1 they are assessed in accordance with section 1.3 of the Code;
.2 they do not present hazards of group B as defined in the Code; and
.3 a certificate has been provided by the competent authority of the port of loading to the master in accordance with 1.3.2 of the Code.

TABLE 2 List of Solid Bulk Cargoes for Which a Fixed Gas Fire-extinguishing System is Ineffective and for Which a Fire-extinguishing System Giving Equivalent Protection Shall Be Available

The following cargoes are categorized into group B of the IMSBC Code:

ALUMINIUM NITRATE UN 1438
AMMONIUM NITRATE UN 1942, with not more than 0.2% total combustible material,
including any organic substance, calculated as carbon to the exclusion of any other
added substance
AMMONIUM NITRATE BASED FERTILIZER MHB
AMMONIUM NITRATE BASED FERTILIZER UN 2067
AMMONIUM NITRATE BASED FERTILIZER UN 2071
BARIUM NITRATE UN 1446
CALCIUM NITRATE UN 1454
LEAD NITRATE UN 1469
MAGNESIUM NITRATE UN 1474
POTASSIUM NITRATE UN 1486
SODIUM NITRATE UN 1498
SODIUM NITRATE AND POTASSIUM NITRATE, MIXTURE UN 1499

For more information, please see the document below (available only to subscribers):