We have been working with industry on issues identified with the repeatability and reliability of the modified C.1 test prescribed by section 184.108.40.206.3 of the International Maritime Solid Bulk Cargoes Code (IMSBC code).
It was noted that actual behaviour of solid bulk materials did not reflect the outcome of the test which found a number of benign materials to be a corrosive solid. AMSA, the Minerals Council of Australia (MCA) and Australian industry have been working with Curtin University to assess the scope the issues. This resulted in papers being taken to the third session of the IMO Carriage of Cargoes and Containers (CCC) sub-committee (see note) and an exemption being issued for iron ore and iron ore fines to allow the use of an alternative test pending the conclusion of further research. This issue is now the subject of an international research effort and an IMO Correspondence Group. The work is progressing well, but it will take some time to complete.
Relevant papers submitted by Australia were:
- CCC 3/5/17
- CCC 3/INF.7
- CCC 3/INF.17
- CCC 3/INF.18
- CCC 3/INF.19.
Support was provided by the IIMA in CCC 3/5/20 and the outcome detailed in the report of CCC3 in CCC 3/15 in sections 5.60 to 5.62.
In the interim AMSA, the Minerals Council of Australia (MCA), and Australian industry have continued to work with Curtin University on this issue. As a result, we have extended alternative test arrangements to cover iron ore, iron ore fines, bauxite, coal, mineral concentrates and metal sulphide concentrates. We are acting in line with our obligations under the IMSBC code, and in consultation with IMO, to facilitate the shipment of these cargoes until the issue can be resolved. The alternative was to rely in a tripartite assessment under section 1.3 of the IMSBC code for many shipments of these cargos. This was considered untenable. Once the IMO agree on a solution to this issue we will move to implement it.
We have issued two exemptions in respect of this issue:
- Exemption 5450 to section 334 of the Navigation Act 2012 allows shippers of iron ore, iron ore fines, bauxite and coal to use an alternative method for evaluation of the MHB corrosive properties of iron ore and iron ore fines. The alternative method is by use of the standard DIN 50929-3 corrosion of metals; probability of corrosion of metallic materials when subject to corrosion from the outside; buried and underwater pipelines and structural components as detailed in the exemption. The previous exemption EX5389 has been withdrawn.
- Exemption 5451 to section 334 of the Navigation Act 2012 allows shippers of mineral concentrates and metal sulphide concentrates to use a modified C.1 test better suited to the properties of these materials. The test ensures greater repeatability and better reflects the evidence for transfer and carriage of this cargo.