|
付録2 第7回DSC小委員会への日本提案等
付録2（1）
SUB-COMMITTEE ON DANGEROUS
GOODS,SOLID CARGOES AND
CONTAINERS |
DSC7/4/3
29 July 2002
Original: ENGLISH |
| 7th session |
|
| Agenda item 4 |
|
REVIEW OF THE BC CODE, INCLUDING EVALUATION OF PROPERTIES OF SOLID BULK CARGOES
Comments on the schedules of the draft revised BC Code
Submitted by Japan
SUMMARY
| Executive summary |
: |
This document provides comments to the proposal by the Netherlands
regarding the schedules for solid bulk cargoes in the draft revised BC Code |
| Action to be taken |
: |
Paragraph 15 |
| Related documents |
: |
DSC 7/4/2, DSC 6/5/1, DSC 7/2/Add.1, DSC 4/5/3, DSC 4/14, IMDG
Code |
|
|
General
| 1 |
This document is submitted in accordance with paragraph 46.5
of the Guidelines on the organization and method of work (MSC/Circ.931) and provides
comments to the proposal by the Netherlands regarding the schedules for solid
bulk cargoes in the draft revised BC Code as contained in the document DSC 7/4/2. |
| 2 |
Japan appreciates the effort of the Netherlands on the revision
of the draft BC Code and is in favour of the opinion of the Netherlands that standard
sentences should be used in the BC Code. Taking into account the request by MSC
on human element-related matters (DSC 7/2/Add.1), the opinion of the Netherlands
is rational and important. |
| 3 |
Japan further is in favour of the opinion of the Netherlands
that MSC/Circ.671 should be up-dated to adjust the names of cargoes used in the
revised BC Code. To facilitate the work of amendments to MSC/Circ.671, the working
group at the last session of the Sub-Committee developed the draft revised MSC/Circ.671
as provided in the annex 1 of the document DSC 7/4 (DSC 6/WP.4). |
BROWN COAL BRIQUETTES
| 4 |
In the draft revised MSC/Circ.671 (DSC 7/4, annex 1), "BROWN
COAL BRIQUETTES" is listed in Table 1. The Netherlands pointed out the inconsistency
between the draft MSC/Circ.671 and the individual schedule of this cargo (DSC
7/4/2, annex 2, page 6). Regarding this cargo, Japan would like to invite the
Sub-Committee to recall several issues. |
| 5 |
The inclusion of this cargo into the BC Code was proposed by
Australia in document DSC 4/5/3, based on the sufficient experience of safe carriage
and the amendment to the BC Code was agreed by the Sub-Committee (DSC 4/14, paragraphs
5.28 and 5.40 and annex 2). In the proposal by Australia, it was pointed out that
BROWN COAL BRIQUETTES were shipped according to the precautions and requirements
for coal (c.f. DSC 4/5/3, paragraph 3). At this time, there was no discussion
on MSC/Circ.671 and scope of application of the requirements in chapter II-2 of
SOLAS Convention. Thus, the correspondence group on the revision of the BC Code
invited the Sub-Committee to consider the inclusion of this cargo and "PEAT MOSS"
in MSC/Circ.671 (c.f. DSC 6/5/1 paragraph 24 and 31.10). |
| 6 |
The first sentence in regulation 10.7.1.4 of revised chapter
II-2 of the Convention is as follows: |
"The Administration may exempt from the requirements of paragraphs 7.1.3 and 7.2, cargo spaces of any cargo ship if constructed, and solely intended for, the carriage of ore, coal, grain, unseasoned timber, non-combustible cargoes or cargoes which, in the opinion of the Administration, constitute a low fire risk."
This sentence does not mean that coal is a cargo, which constitute a low fire risk. Coal is a cargo for which a fixed gas fire-extinguishing system may be exempted similar to cargoes, which constitute a low fire risk.
| 7 |
Taking above-mentioned issues into consideration, Japan considers
that MSC/Circ.671 can be amended as follows: |
"LISTS OF SOLID BULK CARGOES WHICH ARE NON-COMBUSTIBLE
OR CONSTITUTE A LOW FIRE RISK FOR WHICH A FIXED GAS FIRE-EXTINGUISHING
SYSTEM MAY BE EXEMPTED OR FOR WHICH A FIXED GAS FIRE-EXTINGUISHING SYSTEM
IS INEFFECTIVE
| 2 |
The Committee also agreed the annexed table 1 which provides
a list of solid bulk cargoes which are non-combustible or constitute a low fire
risk, for which a fixed gas fire-extinguishing system may be exempted
and recommended Member Governments to take into account the information contained
in that table when granting exemptions under the provisions of regulation II-2/53.1.
II-2/10.7.1.4 |
Table 1
List of solid bulk cargoes which are non-combustible
or constitute a low fire risk for which a fixed gas fire-extinguishing
system may be exempted
Cargoes listed in regulation II-2/53 II-2/10.7.1.4
Ore
Coal (COAL BC No: 010 and BROWN COAL BRIQUETTES BC No:002)
Grain
Unseasoned timber
Cargoes listed in the Code of Safe Practice for Solid Bulk Cargoes (BC Code) which are non-combustible or constitute a low fire risk"
This draft can dissolve the inconsistency regarding BROWN COAL BRIQUETTES between MSC/Circ.671 and the BC Code.
SULPHUR
| 8 |
The Netherlands pointed out the lack of sentences for precautions
on dust explosion in the schedule for SULPHUR (DSC 7/4/2, annex 2, Page 25). In
relation to this, Japan would like to invite the Sub-Committee to further consider
the applicability of this schedule. |
| 9 |
In the IMDG Code, special provision 242 (SP 242) is applied
to Sulphur UN 1350. SP 242 is as follows: |
"Sulphur is not subject to the provisions when it has been formed to a specific shape (such as prills, granules, pellets, pastilles or flakes).
Note AMENDMENT 31-02 on SP 242: Delete "when it is transported in quantities of less than 400 kg per package, or"
| 10 |
In the BC Code, there is a schedule for SULPHUR (lumps and
coarse-grained powder) and carriage of fine-grained sulphur in bulk is prohibited
but there is no schedule for SULPHUR formed to a specific shape. Japan would like
to invite the Sub-Committee to consider SULPHUR formed to a specific shape. |
| 11 |
To keep the consistency between the IMDG Code and the BC Code,
SULPHUR formed to a specific shape should not be classified as dangerous goods.
However, Japan considers that SULPHUR formed to a specific shape can be classified
into MHB, because dust may be generated resulted from handling of this cargo in
bulk. The precautions for the carriage of SULPHUR formed to a specific shape are
supposed to be the same as those for the carriage of SULPHUR (lumps and coarse-grained
powder). |
| 12 |
The possible draft schedule including SULPHUR formed to a specific
shape is as follows (schedule for SULPHUR (lumps and coarse-grained powder) in
DSC 6/5/1): |
SULPHUR (lump and coarse grained) UN No. 1350
and BC No.???
DESCRIPTION
Fine grained sulphur (flowers of sulphur) should
NOT be transported in bulk. Lump or coarse-grained sulphur is classified into
dangerous goods of class 4.1 and UN number is 1350. Sulphur formed to a specific
shape (such as prills, granules, pellets, pastilles or flakes) is classified as
MHB and BC number is???. Ignites readily. When involved in a fire, toxic,
very irritating and suffocating gas is evolved. Forms explosive and sensitive
mixtures with most oxidizing material. Bulk Sulphur has a liability to dust explosion
which may occur especially after discharge and during cleaning. Fine grained
sulphur (flowers of sulphur) should NOT be transported in bulk.
CHARACTERISTICS
| ANGLE OF REPOSE |
BULK DENSITY (KG/M3) |
STOWAGE FACTOR (M3/T) |
| Not applicable |
[1053-1176] |
[0.85-0.95] |
| SIZE |
CLASS |
GROUP |
[Slate to 10 mm granules & prills to 5 mm] |
4.1 or MHB |
B |
|
| 13 |
The precautions for dust explosion after discharge and during
cleaning are provided in the draft schedule for SULPHUR (DSC/6/5/1, annex 2).
The hazard of dust explosion during loading and unloading is also pointed out
in column "HAZARD". Taking these issues into account, the concrete precautions
for dust explosion should further be provided in the columns for "LOADING" and
"DISCHARGE", in particular, prevention of spark. |
| 14 |
In the existing BC Code, it is pointed out in column for "Observation"
in the schedule for SULPHUR that residues are highly corrosive to steel, in particular
in the presence of moisture. In the draft schedule for SULPHUR in column for "HOLD
CLEANLINESS", lime washing is required. However, corrosivity of sulphur is not
pointed out in general. The hazard due to corrosion should clearly be pointed
out in column for "HAZARDS". |
Action requested of the Sub-Committee
| 15 |
The Sub-Committee is invited to consider above proposals and
comments, and take action, as it deems appropriate, in particular, on the schedule
for SULPHUR. |
|
