Regulation CR. 19.2.1.3 involves the requirement for the drainage and pumping arrangements or checking stability taking the water for fire-extinguishing into account. However, this paragraph is for the cargo holds carrying packaged cargoes and not applicable to cargo holds for bulk cargoes. For carriage of bulk cargo, there is no requirement on stability taking supplied water into account.
Note: Regulation CR. 19 is almost the same as existing regulation 54.
Comments on the draft sections 1 to 12
Re: General
(1) The word "material" is better to be substituted by "cargo", except in the words such as "properties of the material".
Re: Foreword
(2) 8th paragraph - Editorial
"... including May 2001."
(3) 9th paragraph - Editorial
(4) 10th paragraph - Clarification
The following sentence should be deleted and, if necessary, incorporated into relevant entries for individual cargoes.
"[In circumstances where, consultation with the competent authority is required prior to bulk shipment of materials, it is equally important to consult authorities at the ports of loading and discharge concerning requirements which may be in force.]"
Re: Introduction
(5) Paragraph 7 - Editorial
"Details of test procedures, together with advice on methods of sampling to obtain representative samples for test purposes, are given in sections 4, 7 and 8 and appendix 1."
Reason: Paragraph 4.3, 4.5 and 4..6 are the precautions for sampling.
Re: Section 1
(6) Paragraph 1.10
"Incompatible cargoes" - Editorial
"... entries for individual cargoes classified in Group B." - Clarification
(7) Paragraph 1.18
I am of the opinion that the trimming of the general word irrespective of the means of the leveling cargo. Concrete means of trimming should be described, as necessary, in the section 5 of the BC Code. Therefore, I propose to amend the definition of "trimming", i,e., the definition in existing BC Code, as follows:
Re: Section 2
No comment.
Re: Section 3
(8) Paragraph 3.5.2.4
The following guidelines can be good references for the protection of working areas from gases, Therefore, I propose to add a asterisk and a footnote as follows:
"3.5.2 Recommendations on ventilation
.4 Ventilation should be such that any escaping hazardous gases, vapours or dust cannot reach living quarters. Escaping hazardous gases, vapours or dust should not be able to reach work areas' unless adequate precautions are taken (refer to Appendix 3).]
Footnote: Refer to "Tanker Safety Guide (LIQUEFIED GAS)" and "INTERNATIONAL SAFETY GUIDE FOR OIL TANKERS & TERMINAL (ISGOTT)", by The International Chamber of Shipping (ICS)"
Re: Section 4
(9) Paragraph 4.2.3 - Editorial
Re: Section 5
(10) Paragraph 5.1
I propose new paragraph 5.1 as follows:
"5.1.1 All relevant information, including characteristics of cargo regarding possibility of cargo shift, if available, and preventive measures against cargo shift, should be supplied in writing to the master by the shipper prior to loading.
