Class and Statutory News
CCC 4 – 11 TO 15 SEPTEMBER 2017 Major outcomes of the 4th session of the IMO sub-committee on carriage of cargoes and containers (CCC 4) 11 to 15 September 2015
Sep. 26 2017
CCC 4 – 11 TO 15 SEPTEMBER 2017 Major outcomes of the 4th session of the IMO sub-committee on carriage of cargoes and containers (CCC 4) 11 to 15 September 2015
CCC 4 – 11 TO 15 SEPTEMBER 2017
insight of the major outcomes of the 4th session of the IMO sub-committee on carriage of cargoes and containers (CCC)
The Sub-Committee on Carriage of Cargoes and Containers (CCC), chaired by Mr. H. Xie (China), held its fourth session from 11 to 15 September 2017.
CCC 4 agreed on :
A list of technical discussion points for assessing the suitability of high manganese austenitic steel for cryogenic service, and to further develop information required to address these topics and draft acceptance criteria
Draft CCC.1 circular on safety awareness for the transport of ammonium nitrate based fertilizer (non-hazardous)
Draft test procedure for determining the TML for bauxite cargoes, with a view to inclusion in the draft amendments (05-19) in appendix 2 to the IMSBC Code.
Draft Individual schedule for Bauxite of Group A and of Group C.
Draft revised CCC.1 circular on Carriage of Bauxite which may liquefy to raise awareness on the potential risks posed by moisture in the carriage of bauxite.
Agenda item 3 - Amendments to the IGF code and development of guidelines for low-flashpoint fuels
3.1. Proposed amendments and corrections to part A-1 of the IGF code
CCC 4 agreed on draft amendments to IGF code for submission to MSC 99 with a view to approval and subsequent adoption.
3.1.1. Application provision of the amendments (2.2.)
The Working group (WG) on amendments to IGF code and development of guidelines for low-flashpoint fuels set up by the Plenary prepared a draft definition for the term "ship constructed on or after [date of entry into force]" for inclusion in part A of the Code in order to use such terminology when an application provision was to be developed in conjunction with a draft amendment.
3.1.2. Sub-factor fv, gas detectors in machinery spaces (5.3)
The definition was amended as follows :
"fv is calculated by use of the formulations for factor v contained in SOLAS regulation II-1/7-18.104.22.168 and reflects the probability that the damage is
not extending vertically above the lowermost boundary of the fuel tank. The formulations to be used are:"
3.1.3. Regulations on loading limit for liquefied gas fuel tanks (6.8)
CCC 4 instructed the WG to prepare the draft amendments to paragraph 6.8.2 of the IGF Code, including application provisions, with a view to submission to MSC 99 for approval and subsequent adoption.
Amendments to paragraph 6.8.2 are based on the idea that the intention of paragraph 6.8.2 is to allow for a higher loading limit than calculated by paragraph 6.8.1, but never above 95%, when the probability of heating the tank contents is very low and when the calculated loading limit using the formulae in paragraph 6.8.1 gives a lower value than 95%.
"6.8.2bis For ships constructed on or after [date of entry into force], in cases where the tank insulation and tank location make the probability very small for the tank contents to be heated up due to an external fire, special considerations may be made to allow a higher loading limit than calculated using the reference temperature, but never above 95%.
This also applies in cases where a second system for pressure maintenance is installed, (refer to 6.9). However, if the pressure can only be maintained / controlled by fuel consumers, the loading limit as calculated in 6.8.1 shall be used."
3.1.4. Protection of gas pipes and pipes for cryogenic liquefied gas - Regulations for fuel distribution outside of machinery space (9.5)
CCC 4 had for its consideration the proposal, regarding section 9.5 of the IGF Code, of amendments to clarifying the different protection requirements for gas pipes and pipes for cryogenic liquefied gas and also to clarifying the design features for cryogenic pipe protection.
"9.5.3 The requirements in 9.5.4 to 9.5.7 shall apply to ships constructed on or after [date of entry into force] in lieu of the requirements in 9.5.1 and 9.5.2.
9.5.4 Where gaseous fuel pipes pass through enclosed spaces in the ship, they shall be protected by a secondary enclosure. This enclosure can be a ventilated duct or a double wall piping system. The duct or double wall piping system shall be mechanically under pressure ventilated with 30 air changes per hour, and gas detection as required in 15.8 shall be provided. Other solutions providing an equivalent safety level may also be accepted by the Administration.
9.5.5 The requirement in 9.5.4 need not be applied for fully welded fuel gas vent pipes led through mechanically ventilated spaces.
9.5.6 Liquefied fuel pipes shall be protected by a secondary enclosure able to contain leakages. If the piping system is in a fuel preparation room or a tank connection space, the Administration may waive this requirement.
The secondary enclosure shall be able to withstand the maximum pressure that may build up in the enclosure in case of leakage from the fuel piping. For this purpose, the secondary enclosure may need to be arranged with a pressure relief system that prevents the enclosure from being subjected to pressures above their design pressures."
3.1.5. Explosion relief valves - Regulations for internal combustion engines of piston type (10.3)
CCC 4 agreed to draft amendments with a view to submission to MSC 99 for approval and subsequent adoption. These proposals were related to 10.3.1.1 of the IGF Code dealing with explosion relief valve capability in the exhaust system.
CCC 4 agreed that the draft amendment should apply to new ships only.
Hence, having recognized that the current requirements for explosion relief valve capability in the exhaust system located in 10.3.1.1 do not take into account the safety concept of different engines and the functional requirement in 10.2.2, CCC 4 agreed to include a new draft regulation 10.3.1.1bis, applicable to new ships only in order to address the above-mentioned gaps.
"10.3.1.1bis For ships constructed on or after [date of entry into force], the exhaust system shall be equipped with explosion relief
ventilation sufficiently dimensioned to prevent excessive explosion pressures in the event of ignition failure of one cylinder followed by ignition of the unburned gas in the system. systems unless designed to accommodate the worst case overpressure due to ignited gas leaks or justified by the safety concept of the engine. A detailed evaluation of the potential for unburnt gas in the exhaust system is to be undertaken covering the complete system from the cylinders up to the open end. This detailed evaluation shall be reflected in the safety concept of the engine."
3.1.6. Separation of fuel preparation rooms and type C tanks from high fire risk rooms - Regulations for fire protection (11.3)
CCC 4 had for its consideration proposal of amendments to paragraph 11.3.3 of the IGF Code based on the view that the requirements in paragraph 11.3.3 also apply to fuel preparation rooms and on the understanding that a cofferdam will be required when a type C tank is located directly above machinery spaces of category A and other rooms with high fire risk.
The Group agreed to amend the requirement in 11.3.3 in the view to:
align the fire arrangements for fuel preparation rooms located below deck with those for fuel containment systems;
delete the fire protection requirements for boundaries between fuel containment systems;
include additional fire protection requirements for boundaries of type C tanks located above machinery spaces of category A or other rooms with high fire risk.
"11.3.3 The space containing the fuel containment system shall be separated from the machinery spaces of category A or other rooms with high fire risks. The separation shall be done by a cofferdam of at least 900 mm with insulation of A-60 class. When determining the insulation of the space containing the fuel containment system from other spaces with lower fire risks, the fuel containment system shall be considered as a machinery space of category A, in accordance with SOLAS regulation II-2/9.
The boundary between spaces containing fuel containment systems shall be either a cofferdam of at least 900 mm or A-60 class division. For type C tanks, the fuel storage hold space may be considered as a cofferdam.
11.3.3bis Notwithstanding 11.3.3, for ships constructed on or after [date of entry into force], for type C tanks, the fuel storage hold space may be considered as a cofferdam provided the type C tank is not located directly above machinery spaces of category A or other rooms with high fire risk. When the fuel storage hold space is considered as a cofferdam, the minimum distance to the A-60 boundary from the outer shell of the type C tank or the boundary of the tank connection space, if any, shall be at least 900 mm."
3.2. Draft unified interpretations of the IGF code
CCC 4 endorsed the draft unified interpretations of provisions 6.8.2 and 11.3.3 of the IGF Code for inclusion as part of the draft MSC circular on unified interpretations of the IGF Code.
3.2.1. IGF Code part A-1, 6.8.2 – Storage tanks loading limits higher than calculated using the reference temperature
Having noted that the ability of a fuel tank to satisfy the holding time requirement in 22.214.171.124, which is evaluated under normal operating conditions has to be met irrespective of the application of 6.8.2 and should not be used as a factor when allowing a higher loading limit, CCC 4 endorsed the following UI :
The alternative loading limit option given under 6.8.2 is understood to be an alternative to 6.8.1 andshould only be applicable when the calculated loading limit using the formulae in 6.8.1 gives a lower value than 95%.
In such circumstances, higher loading limits than calculated by 6.8.1 may be permitted, but never above 95%, provided: - the tank is well insulated and capable of accumulating pressure, i.e. satisfy the holding time required by 126.96.36.199 with ship in idle condition without re-liquefaction or incineration of boil-off; and - the tank is located in a fuel storage hold space separated from potential fire loads by cofferdams or surrounded by ship spaces with no fire load.
3.2.2. IGF Code part A-1, 11.3.2 – Class division for space boundaries facing fuel tanks on open deck
The intent of the proposal of draft unified interpretation was to exempt the provision of A-60 class divisions for boundaries of service spaces, control stations, accommodation spaces, escape routes and machinery spaces facing fuel tanks on open deck when the fuel tank and its tank connections are completely enclosed in A-0 class divisions.
CCC 4 estimated that the waiver intended by the draft unified interpretation should be addressed by means of amendments to the IGF Code.
3.2.3. IGF Code part A-1, 11.3.3 – Other rooms with high fire risk
In considering how the phrase "other rooms with high fire risk" in 11.3.3 should be interpreted, CCC 4 aligned the spaces listed in the proposed draft unified interpretation with the categories listed in SOLAS regulation II-2/9.
3.3. Requirements for fuel cells - Draft new part E of the IGF Code relating to fuel cells
CCC 3 had agreed that the draft amendments to the IGF Code regarding fuel cells should be developed as a general part to the IGF Code. The provisions of the IGF Code for alternative design and arrangements would have to be used with regard to fuel storage and piping outside the fuel cell power systems, until specific provisions for these aspects are developed.
CCC 3 decided to re-establish the Correspondence Group on Development of Technical Provisions for the Safety of Ships using Low-flashpoint Fuels, and instructed it to finalize the draft amendments to the IGF Code regarding fuel cells.
CCC 4 set up a dedicated Working Group at this session on the development of draft amendments to the IGF Code regarding fuel cells and the identified unresolved issues which need further consideration, as for instance :
Definitions and terminology
Arrangement of fuel cell spaces
Applicable safety concept (ESD/Gas safe)
Piping arrangements for reformed fuels
The WG developed the following draft definitions to be included in part A of the Code :
"2.2.14bis Fuel cell is a source of electrical power in which the chemical energy of a fuel cell fuel is converted directly into electrical and thermal energy by electrochemical oxidation.
2.2.14ter Fuel reformer is the arrangement of all related fuel reforming equipment for processing gaseous or liquid primary fuels to reformed fuel for use in the fuel cells.
2.2.14quater Fuel cell power system is fuel cell(s), fuel reformers if fitted and associated piping systems."
"2.2.14quinquies Fuel cell power installation is the fuel cell power system and other components and systems required to supply electrical power to the ship. It may also include ancillary systems for the fuel cell operation.
2.2.14sexies Fuel cell space is a [structural] space [or enclosure] [or non-structural enclosure] containing elements of the fuel cell power system.
The structure of the part E should be as follows :
20 Fuel cell power installations
20.3 Functional requirements
20.5 Fuel cell specific ship arrangement and system design
3.4. Draft technical provisions for the safety of ships using methyl/ethyl alcohol as fuel
CCC 4 has recommended to MSC 99 to invite ISO to consider developing a standard for methyl/ethyl alcohol, a standard for methyl/ethyl alcohol fuel couplings.
At a broader level, CCC 4 was of the view that the toxic properties of methyl alcohol need to be further considered and noted the information provided by French delegates about a recent study on the use of methyl/ethyl alcohols as fuel in confined enclosed spaces, which indicates that the toxicity thresholds applicable to human health are very speedily attained. In this regard, the French delegates informed CCC 4 of its intention to submit the results of the aforementioned study to a future session.
Agenda item 4 - Suitability of high manganese austenitic steel for cryogenic service and development of any necessary amendments to the IGC code and IGF code
CCC 3 established a Correspondence Group (CG) on the Suitability of High Manganese Austenitic Steel for Cryogenic Service. Discussions of the CG were mainly focused on the development of test acceptance criteria.
CCC 4 in Plenary noted safety records from the operation of ships is indispensable for achieving a complete evaluation of the suitability of high manganese austenitic steel for cryogenic service and for ensuring an appropriate safety level. It is hard to evaluate the stress corrosion and fatigue fracture disposition of a material without trials and operation of actual ships for a certain period of time, since such aspects are largely dependent on the operational environment at sea (exposure to sea salt, random and complex forces, metocean environment).
CCC 4 considered that high manganese austenitic steel should not be incorporated into the IGC and IGF Codes until trial constructions and operation of ships with tanks made of the new material are carried out.
Therefore, instead of amendments to the IGC and IGF Codes, interim guidelines for the application of high manganese austenitic steel in cryogenic services would be preferable at a first stage.
CCC 4 established a WG on the Suitability of High Manganese Austenitic Steel for Cryogenic Service.
Following converging discussions in Plenary, CCC 4 endorsed the WG's proposal that consideration of the suitability of high manganese austenitic steel for cryogenic service should be limited to steel plates only.
WG noted that chapter 6 of the IGC Code was developed to address particular materials used for construction of cargo containment and piping systems at the time of the development of the IGC Code (1983) and, therefore, it would be not appropriate to use the test requirements set out in this chapter as a basis for assessing of the suitability of new materials.
WG prepared the following list of technical discussion points for assessing the suitability of high manganese austenitic steel for cryogenic service, and further developed information required to address these topics and draft acceptance criteria :
Identification of cargo constraints;
Base metal test
3. Weldability test, including heat affected zone (HAZ)
CCC 4 decided to re-establish the CG under the coordination of the Republic of Korea.
Agenda item 5 - Amendments to the IMSBC code
Bearing in mind BV’s report on MSC 98, it should be recalled that last meeting of the Committee has agreed on the following issues :
Resolution MSC.426(98) – amendments to the international maritime solid bulk cargoes (IMSBC), providing amendment which should be deemed to be accepted on 1 July 2018 and enter into force on 1 January 2019;
MSC.1/Circ.1395/Rev.3 - Lists of solid bulk cargoes for which a fixed gas fire-extinguishing system may be exempted or for which a fixed gas fire-extinguishing system is ineffective (consequential amendment to MSC.1/Circ.1395/Rev.2, in relation to the draft amendments to the IMSBC Code (MSC.426(98)).
5.2. Ammonium Nitrate Based Fertilizer (non-hazardous)
5.2.1. Reclassification from Group C to Group B
CCC 4 had for its consideration a proposal of amendments to the existing schedule for ammonium nitrate based fertilizer (non-hazardous), according which ammonium nitrate based fertilizers (non-hazardous) do not propagate combustion, are not flammable solids, are not self-heating and do not show self-sustaining decomposition behavior.
The proposed amendments were not supported and CCC 4, considering the reduction of hazard statements, carriage requirements and emergency procedures, are downgrading the way to handle such cargo. CCC 4 estimated that the reclassification from Group C to Group B was for the time being out of sight.
CCC 4 also noted the existing individual schedule for ammonium nitrate based fertilizer (non-hazardous) covers a wide range of different fertilizers. Dividing the existing individual schedule for ammonium nitrate based fertilizer (non-hazardous) into two schedules, i.e. for group B and group C, could be a way to consider.
5.2.2. Draft CCC.1 circular on safety awareness for the transport of ammonium nitrate based fertilizer (non-hazardous)
CCC 4 approved the draft CCC.1 circular on carriage of ammonium nitrate based fertilizer (non-hazardous)
The circular describes the safety principles for this cargo are as follows:
avoidance of storage of combustible substances near fertilizers;
avoidance of storage of incompatible substances near fertilizers;
avoidance of cross contamination with remains of previous cargoes;
avoidance of cross contamination of next cargo with fertilizer;
avoidance of sources of heat likely to affect the fertilizer;
avoidance of application of heat to any section which may have trapped/confined fertilizer.
5.3. Seed cake cargoes
5.3.1. Draft individual schedules
CCC 4 agreed, in principle with a view to inclusion in the draft amendments (05-19) to the IMSBC Code:
to the draft Individual schedule for MHB seed cake cargoes;
to the draft Individual schedule for Group C seed cake cargoes.
5.3.2. Draft amendments to the IMSBC code for the classification of seed cake cargoes
CCC 4 considered that a uniform classification approach is necessary for cargoes with similar properties and that in the long term, the criteria for classification of MHB(OH) cargoes should be developed. For instance, the absence of guidance for determining whether a cargo is cohesive or non-cohesive is open to broad interpretation and may result in catastrophic consequences, consequential amendments to appendix 3 to the Code may be required.
Hence, CCC 4 invited interested Member States and international organizations to submit more information to E&T 29.
However, WG on IMSBC estimated that the draft amendments to section 9 of the IMSBC Code should not be further developed at this stage.
5.3.3. Amendments to individual schedules for UN 1386 (b) and UN 2217
CCC 4 agreed, in principle, to the draft amendments to following individual schedules :
Seed cake UN 1386 (b), seed cake containing vegetable oil;
Seed cake UN 2217, seed cake with not more than 1.5% oil and not more than 11% moisture
CCC 4 considered reports from Global Bauxite Working Group (GBWG) and from the dedicated Correspondence Group (CG).
5.4.1. Hazard and criteria for Group A and Group C cargoes
CCC 4 agreed, in principle, with the criterion of Group A and Group C cargoes proposed by the GBWG and agreed by the CG.
5.4.2. New phenomenon – dynamic separation
Both liquefaction and dynamic separation are moisture-related mechanisms and there is a need to expand the existing definition of Group A to cover the new phenomenon of dynamic separation.
CCC 4 was on the view that the phenomenon of dynamic separation should be considered in the long term and decided to invite interested Member States and international organizations to submit proposals to the MSC, with a view to amending the IMSBC Code to address this moisture-related mechanism.
5.4.3. Draft new test procedure for determining the TML for bauxite cargoes
CCC 4 agreed to the draft test procedure for determining the TML for bauxite cargoes, with a view to inclusion in the draft amendments (05-19) in appendix 2 to the IMSBC Code.
5.4.4. Draft individual schedules for Group A and C cargoes
With a view to inclusion in the draft amendments (05-19) to the IMSBC Code, CCC 4 agreed to :
the draft Individual schedule for Bauxite of Group A;
the draft amendments to the individual schedule for Bauxite of Group C.
CCC 4 endorsed the WG's recommendation to instruct E&T 29 to make the necessary editorial modifications to the characteristics table of the draft new individual schedule for Bauxite of Group A, in order to harmonize the table with the amendments (05-19) to the IMSBC Code.
5.4.5. Consequential amendments to the IMSBC Code
Having noted that the consequential amendments to appendices 4 and 5 to the Code are needed, CCC 4 agreed to the consequential amendments to :
appendix 2 (Laboratory test procedures, associated apparatus and standards);
appendix 4 (Index);
appendix 5 (Bulk Cargo Shipping Names in three languages (English, Spanish and French)).
5.4.6. Revised CCC.1 circular on Carriage of Bauxite which may liquefy
CCC 4 approved the draft revised CCC.1 circular on Carriage of Bauxite which may liquefy to raise awareness on the potential risks posed by moisture in the carriage of bauxite.
The hereinbefore draft amendments are expected to be adopted by the MSC (MSC 101, in 2019) and the date of entry into force of these draft amendments to the IMBSC Code is expected to be 1 January 2021.
Hence, CCC 4 decided to invite the member governments to take the aforementioned draft test procedure and draft individual schedules for bauxite of group A and group C into consideration at the time of:
classification of Bauxite cargoes as Group A or Group C;
setting the preliminary suitable conditions for the carriage of this cargo in accordance with subsection 1.3 of the Code, when the cargo is classified as Group A.
5.4.6. New individual schedules
CCC 4 has referred to E&T 29 following proposals, for consideration and incorporation, as appropriate, into draft amendments05-19 to the IMSBC code :
Metal Sulphide Concentrates, Self-heating, UN 3190 as a Group A and B cargo;
Brucite as a Group C cargo.
Agenda item 6 - amendments to the IMDG code and supplements
6.1. Draft editorial corrections to amendment 38-16 to the IMDG Code
MSC.406(96) has amended (38-16) to the IMDG Code with an entry into force on 1 January 2018. CCC 4 agreed to some draft editorial corrections and referred them to E&T 28.
6.2. Draft amendment 39-18 to the IMDG Code
CCC 4 had for its consideration a proposal for a new special provision on the transportation of batteries (UN 2800) installed in cargo transport units. It agreed to forward it to UN Sub-Committee of Experts on the transport of Dangerous Goods (UNSCETDG) owing to the fact it is a multimodal issue.
Battery-vehicles are currently shipped under exemptions, in accordance with paragraph 188.8.131.52 of the IMDG Code. CCC 4 referred this topic and the related documents to E&T 28 for further consideration.
6.4. Emergency Response Procedures for Ships Carrying Dangerous Goods including the Emergency Schedules (EmS)
CCC 4 agreed to reinsert UN 3332 and UN 3333 in schedule S-S of the EmS Guide. It referred the proposed amendments to E&T 28. It asked the Secretariat to issue such editorial corrections before 1 January 2018, the date of entry into force of amendment 38-16.
Considering that a review of MSC.1/Circ.1216 could be beneficial, CCC 4 agreed, in principle, to draft a consolidated Revised EmS Guide and referred it to E&T 28 for finalization, with a view to approval at MSC 99 in 2018.
6.5. Amendment 39-18 to the IMDG code and supplements
CCC 4 agreed to amend the segregation codes and dangerous goods list, and to adapt the segregation requirements for uranium hexafluoride, in order to reflect the additional risk of class 6.1. It instructed E&T 28 to further develop the related draft amendments for inclusion, if appropriate, in the draft amendments (39-18) to the Code.
CCC 4 requested E&T 28 to finalize the draft amendments (39-18), with a view to submitting the draft amendments to MSC 99 for consideration and adoption.
Agenda item 7 – Unified interpretation of provisions of IMO safety, security and
7.1. Draft unified interpretations of the IGF code part A
Cf. paragraph 3.2 of this report
7.2. Other draft unified interpretations of the IGF code
7.2.1. Level indicator in the bilge well of tank connection spaces of independent liquefied gas storage tanks (paragraph 15.3.2)
The "level indicator" required by 15.3.2 of the IGF Code is understood to be required for the purposes of indicating an alarm status only. A level switch could fit.
7.2.2. Testing of high level alarms (paragraph 184.108.40.206)
The expression "each dry-docking" refers for cargo ships to the survey of the outside of the ship's bottom required for the renewal of the Cargo Ship Safety Construction Certificate and/or the Cargo Ship Safety Certificate, and for passenger ships, to the survey carried out according to paragraphs 5.10.1 and 5.10.2 of the Survey Guidelines under the Harmonized System of Survey and Certification,(HSSC), 2015.
7.3. Unified interpretation of paragraph 13.3.5 of the IGC code (as amended by resolution MSC.370(93))
The expression "each dry-docking" is considered to be the survey of the outside of the ship's bottom required for the renewal of the Cargo Ship Safety Construction Certificate and/or the
Cargo Ship Safety Certificate.