(3) Re: DSC 3/3 ANNEX 9
As I explained in the comment No.1 on the matters in principle, dated on May 30, DSC 3/3 Annex 9 should be reflected in the entries for individual cargoes. DSC 3/3 Annex 9 includes the BCSN for mineral concentrates. The BCSN for mineral concentrates missed in the draft entries were listed in my comment No.9 on the entries for individual cargoes. The names other than BCSN, such as ore or mineral names, should be included in the list in appendix 4, in accordance with DSC 3/3 Annex 9 - Table A.2,1(2). In view of this, the draft appendix 4 is excellent, In other words, to keep the consistency between the list and the entries for individual cargoes, the individual entries should be amended as I proposed in comment No.9 on the entries for individual cargoes.
I have two editorial comments on the draft appendices.
Re: Appendix 4 paragraph 1.4
(4) Editorial amendment.
(5) In the list of non-cohesive cargoes, "MONOAMMONIUM PHOSPHATE" is missed.
Comments on the Amendment to the BC Code
Re: SEED CAKE (a) - UK Comment No.29
Re: SEED CAKE (b) - UK Comment No.30
Re: SEED CAKE (c) - UK Comment No.31
Background
・ Regarding the entries for "SEED CAKE (a)", the UK proposed the following new sentences for the column "PRECAUTIONS":
"CO2 fixed fire fighting system, if fitted, should have the injection pipes extended down the hold to discharge the medium at the tank top or near the bottom of the cargo. Regular temperature readings should be taken at varying depths in the cargo spaces and recorded. If the temperature of the material exceeds 55 degfC and continues to increase, ventilation to the cargo should be restricted. If self-heating continues, then carbon dioxide or inert gas should be introduced. <UK 17 May (29)>"
・ For the other "SEED CAKE", it is proposed to add the first sentence.
・ I invited the UK to explain about the reason for the amendment (My comments No.117).
・ The UK answered as follows:
"The proposals made by the UK are as a result of many years experience, primarily in shipments between the Pacific basin and Europe, by UK shippers and include their findings as to the best way to monitor and deal with the carriage of such cargoes. Introducing CO2 or inert gas into the bottom of the hold, by adding extension pipes to the hold CO2 discharge lines, allows the gas to pass through the cargo and up through the seat of a fire."
My comment
The amendments to the BC Code proposed by the UK may leads to the prohibition of the carriage of these cargoes with ordinary bulk carriers having a fixed gas fire-extinguishing systems, because the amendments correspond to the new interpretation of the requirement in chapter II-2 of SOLAS Convention, In view of this, I am of the opinion that such amendment should be addressed to the Sub-committee or the Committee first. For the discussion at the Sub-committee or the Committee, the danger of the carriage under existing BC Code should be pointed out and the effect of new requirement should be clarified.
I would like to invite the members of the C.G. to comments on this issue, subject to the decision by the coordinator.
