In any circumstances of doubt, cargo should be trimmed reasonably level to the boundaries of the cargo space. Furthermore, the second paragraph of the regulation VI/2 of SOLAS Convention requires the cargo information on the trimming procedure. Taking these issues into consideration. I propose to substitute the following sentences (c.f. 4th paragraph of regulation VI/7) for the sentences in the draft, i.e., "Trim reasonable level to the boundaries of the cargo space":
2.8 DISCHARGE
Re: General
(19) The precautions in view of only safety should be described in this item The information on the method of discharge irrelevant to safety should not be included in this item. "Normal grab discharge" should be substituted by "No special precautions".
3 Comments on individual entry
Re: AMMONIUM NITRATE FERTILIZERS (type A) - Heading
(20) The heading of this cargo should be read as follows:
AMMONIUM NITRATE FERTILIZERS (type A)
(A1) UN No.2067
(A2) UN No.2068
(A3) UN No.2069
(A4) UN No.2070
Reason: Editorial.
Re: AMMONIUM NITRATE UN No.1942,
AMMONIUM NITRATE FERTILIZERS (type A) and (type B) UN No.2071
- Emergency schedule B4
(21) The 3rd sentence for "Emergency Action in a Fire Situation" should be amended as follows:
Re: CEMENT and
CEMENT CLINKERS - HOLD CLEANLINES
(22) The following sentences should be deleted unless these precautions are related to safety:
"In the case of previous cargoes being carbohydrate or starchy - particular sugar - holds must be meticulously washed and dried. The smallest amount of sugar can render the whole cargo useless."
As I mentioned in the comment No.15, I am of the opinion that the precautions not related to safety should not be included in the BC Code. Therefore, I would like to request the Member proposing these sentences to clarify the reason why the contamination with "carbohydrate or starchy - particular sugar" should be prohibited, As long as there is no obvious explanation, these sentences should be deleted.
Re: CEMENT and
CEMENT CLINKERS - VENTILATION & CARRIAGE
(23) The following sentences should be deleted:
"The cargo should not be ventilated " in the item VENTILATION; and
"Hatches must be sealed. Shut all vent and access ways.", in the item CARRIAGE
In order to avoid moisture, the cargo holds are equipped with means of ventilation.
Re: COPRA - VENTILATION
(24) The description in the draft should be amended as follows:
"Adequate surface ventilation should be provided ...".
Reason: Editorial
Re: DOLOMITE - DESCRIPTION
(25) I propose the following editorial change:
"Dolomite is a light yellow/off-brown/brown coloured ..."
Re: FERROSILICON UN No.1408 and FERROSILICON BC No.022
(26) Ingress of water to the cargo holds for these cargoes should be prevented because these cargoes possess chemical hazards in case of contact with water. Therefore, the ventilation openings should be closed during rainy weather. In view of this, the description in the item "VENTILATION" should be read as follows (c.f, paragraph 2.3.1 in regulation II-2/53 of SOLAS Convention):
"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. "
