(97) Re: CLEAN UP: The sentence should be read as follows:
"Pure urea does not corrode steel but in water solution strip some kinds (e,g., rubber chloride) of paintwork. Impure urea with ammonium may corrode steel structure and in water solution strip some kinds of paintwork. Sweep, hose out and dry holds."
Reason: In general, urea carried in bulk contains impurities and the corrosions of structure and paint have been reported.
Re: ZINC ASHES UN No: 1435
(172) My comment No.126 is not accurately reflected in this draft entry.
Re: ZINC ASHES UN NO. 1435
ZINC DROSS
ZINC RESIDUE
ZINC SKIMMINGS
(126) Re: PRECAUTIONS
I propose to add the following sentences in this column:
"Wet cargo should not be accepted for shipment, although the cargo is not visibly wet in appearance. The cargo should be handled and carried under dry condition."
Re: ZINC ASHES UN No: 1435 - VENTIILATION
(173) I prefer the privies text, i.e., "Keep well ventilated to prevent hydrogen buildup".
Re: FIRE PROTECTION
Re: DIRECT REDUCED IRON Briquettes, hot-moulded BC No: 016
(174) This cargo is listed in Table 1 of MSC/Circ.671 and be able to be carried in hatches without a fixed gas fire-extinguishing system. Therefore, to keep the consistency with MSC/Circ.671 Table 1, the following text should be amended:
Re: FIRE PROTECTION of MHBs for which the requirement for a fixed gas fire-extinguishing system can not be exempted
(175) On ships not less than 2,000 GRT, MHBs not listed in MSC/Circ.671 Table 1 should be stowed in cargo holds protected with a fixed gas fire-extinguishing system as required by regulation II-2/53.1.1 in SOLAS Convention. On the other hand, on ships less than 2,000 GRT, these cargoes can be stowed in cargo holds without a fixed gas fire-extinguishing system, (c.f. Reg. II-2/53.1) In view of this, my comments No.110 and 111 were not accurate. Therefore, to keep the consistency between the requirements for a fixed gas fire-extinguishing system in SOLAS and the BC Code, I propose following text for the columns for FIRE PROTECTION in the entries in the following cargoes:
CHARCOAL BC No: 005
DIRECT REDUCED IIRON, DRI BC No: 015
SAWDUST BC No: 055
TANKAGE BC No: 065
WOODCHIPS BC No.075
WOOD PULP PELLETS BC No: 080
"This cargo with a moisture content of 15 % or more has a low fire risk and may be carried in hatches without a fixed gas fire-extinguishing system. This cargo with a moisture content less than 15 % may be carried in hatches without a fixed gas fire-extinguishing system on ships less than 2,000 GRT. Refer to the emergency procedures for action in a fire."
Comments on the letter by the UK dated on Nov. 9.
The UK pointed out that there are some conflicts in the text in HAZARD and in FIRE PROTECTION IN CARGO SPACE for some cargoes. In view of this, my comment is as follows:
Re: FIRE PROTECTION IN CARGO SPACE
(176) To avoid confusion, consistency between MSC/Circ.671 Table 1 and the text in the BC Code should be kept. When there is a doubt on the fire risk of a cargo, the text, "this cargo constitute a low fire risk ...", can be removed from the column. In such case, the text, "this cargo may be carried in hatches without a fixed gas fire-extinguishing system.", may be enough for the column.
Comments on the draft appendices
Re: Appendix 4
(1) As I pointed out in the comments on section 1 to 12 of the BC code (c.f. Comment No.29), the information included in the first pages of the appendices A, B and C of the existing BC Code should be kept in the new BC Code. Furthermore, the meaning of the expressions in the column "Group" should be explained. I consider that the appropriate position of the information included is on the top page of the new appendix 4, e.g., as follows:
"List of materials and hazard identifications
