4 FERROSILICON may create flammable and toxic gases when in contact with water. Ingress of water into the cargo hold carrying FERROSILICON should, therefore, be prevented. For this purpose, ventilation openings of a ship carrying this cargo should be equipped with mean of closure and the ventilation duct should be closed in rough weather. On the other hand, based on the experience of carriage of this cargo by Japanese shipping companies, it can be said that discontinuity of ventilation is not liable to lead to immediate danger. For these reasons, Japan is of the opinion that the column for VENTILATION in the entries of FERROSILICON (UN No.1408 and BC No.022) should read as follows:
"The cargo spaces should be provided with an effective power ventilation system. Ventilation fans should normally be run continuously whenever cargoes are on board. Where this is impracticable, they should be operated as weather permits and in any case for a reasonable period prior to discharge."
By the same reasons, paragraph 4 in "GENERAL REQUIREMENTS FOR CARRIAGE OF FERROSILICON" in the appendix of the entry for FERROSILICON UN No.1408 should be deleted.
Fire-extinguishing systems for SEED CAKE (UN No.1386 and 2217)
5 As described in paragraph 18 in the report of the Correspondence Group, extension of CO2 discharge pipes for the carriage of SEED CAKE (UN No.1386 and 2217) was discussed in the Correspondence Group. In cases where provision for extension of CO2 discharge pipes to the bottom of the cargo holds for these cargoes is provided in the BC Code, these cargoes should not be carried by bulk carriers not fitted with the special CO2 discharge pipes, in accordance with the Code.
6 Provision for the extension of CO2 discharge pipes in cargo hold can be regarded as an interpretation of the requirements for fixed fire-extinguishing systems in chapter II-2 of the SOLAS Convention. Japan, therefore, considers that inclusion of such provision precaution in the BC Code should be discussed not only by the Sub-Committee but also by the FP Sub-Committee. The provision should not be included in the BC Code until considered by the FP Sub-Committee.
Action requested of the Sub-Committee
7 The Sub-Committee is invited to consider the above comments and take action as it deems appropriate.
