AMENDMENTS TO THE IMSBC CODE AND SUPPLEMENTS. Revision of existing individual schedules for SEED CAKE and GRAIN SCREENING PELLETS

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1 E SUB-COMMITTEE ON CARRIAGE OF CARGOES AND CONTAINERS 3rd session Agenda item 5 CCC 3/5/11 7 June 2016 Original: ENGLISH AMENDMENTS TO THE IMSBC CODE AND SUPPLEMENTS Revision of existing individual schedules for SEED CAKE and GRAIN SCREENING PELLETS Submitted by Australia, Canada, China, Italy, Spain, the United States and BIMCO Executive summary: Strategic direction: 5.2 High-level action: Output: Action to be taken: Paragraph 19 SUMMARY This document proposes to revise the existing individual schedule for SEED CAKE (non-hazardous) in the IMSBC Code, to introduce individual schedules for Group B (MHB) and Group C (non-hazardous) Related documents: DSC 18/6/23, CCC 1/5/3, CCC 1/5/4, E&T 25/3, E&T 25/3/1, E&T 25/3/7 and CCC 3/5 Introduction 1 The IMSBC Code contains five entries that may be used for materials that are described as seed cake, residues of oily vegetables or pellets. The nature of the hazard categorisation and additional information associated with the Bulk Cargo Shipping Name (BCSN) limit the applications of these schedules. 2 The individual schedules in question are:.1 SEED CAKE, containing vegetable oil UN 1386 (a) mechanically expelled seeds, containing more than 10% of oil or more than 20% of oil and moisture combined;.2 SEED CAKE, containing vegetable oil UN 1386 (b) solvent extractions and expelled seeds, containing not more than 10% of oil and when the amount of moisture is higher than 10%, not more than 20% of oil and moisture combined;

2 Page 2.3 SEED CAKE UN 2217 with not more than 1.5% oil and not more than 11% moisture;.4 SEED CAKE (non-hazardous) In so far as it only applies to the following, which have been specifically excluded from the SEED CAKE (b) schedule:.1 solvent extracted rape seed meal, soya bean meal, cotton seed meal and sunflower seed meal, containing not more than 4% oil and 15% oil and moisture combined, and being substantially free from flammable solvents;.2 mechanically expelled citrus pulp pellets containing not more than 2.5% oil and 14% oil and moisture combined;.3 mechanically expelled corn gluten meal containing not more than 11.0% oil and 23.6% oil and moisture combined;.4 mechanically expelled corn gluten feed pellets containing not more than 5.2% oil and 17.8% oil and moisture combined; and.5 mechanically expelled beet pulp pellets containing not more than 2.8% oil and 15.0% oil and moisture combined..5 GRAIN SCREENING PELLETS 3 The nature of these individual schedules, the inconsistencies with the UN Model Regulations and their limitations were discussed at E&T 25 with regard to documents E&T 25/3 and E&T 25/3/1 (Germany and Italy) and document E&T 25/3/7 (China). An informal group was convened to further discuss the issues raised in the documents and the schedules in general, and the outcome of the discussions of this informal group, together with those of the E&T group, are reflected in the report of E&T 25 (CCC 3/5, paragraphs 3.56 to 3.73). Discussion 4 In considering documents E&T 25/3, E&T 25/3/1 and E&T 25/3/7, it was noted the following issues:.1 the description of what may be captured in SEED CAKE classified as dangerous goods is relatively consistent in that it relates to residues of grains, other seeds and oily vegetables after oil has been extracted using solvent or mechanical processes. These materials may be shipped in the form of pulp, meals, cake, pellets and expellers. The description in the schedules then lists the seeds, vegetable material and grain residues to which the schedule may apply. While the description is advisory it acts as a barrier to the use of these schedules for other processed grain and seed pellets (commonly used as stock feeds), which share the same properties and should be shipped under one of these BCSNs. Document E&T 25/3/7 proposed amendments to make the descriptions consistent; however, it was noted that the proposal further restricts the range of materials and any new schedule should have a broader description;

3 Page 3.2 the BCSN for SEED CAKE described as UN 2217, UN 1386(a) and UN 1386(b) rely on the IMDG Code. The UN 1386 and UN 2217 entries in the IMDG Code are also different to the entries in the UN Model Regulations. In the UN Model Regulations, UN 1386 is separated from UN 2217 where the latter exceeds 1.5% oil and 11% moisture. The UN Model Regulations do not rely on solvent, mechanical extraction or the range of oil and moisture content, as is the case with the IMDG Code and the IMSBC Code;.3 the BCSN for SEED CAKE UN 1386(a) and UN 1386 (b) are differentiated by an oil content set at 10% oil or 20% oil and moisture combined. The lower limit of the range for SEED CAKE (b) is not specified, meaning this schedule also captures the oil and moisture content of the individual schedule for SEED CAKE UN The difference being that the individual schedule for SEED CAKE UN 2217 is specifically related to solvent extraction for those bulk cargoes that contain not more than 1.5% oil and not more than 11% moisture. Furthermore, the differentiation between the SEED CAKE individual schedules for UN 1386(b) and UN 2217 and the IMDG Code is also identified, as the IMDG Code permits a wider range of materials to be captured in UN 2217 by the virtue of special provision 929;.4 five groups of oily vegetables excluded from SEED CAKE (b) (see paragraph 2.4) are captured in the individual schedule for SEED CAKE (non-hazardous). As indicated, this schedule only applies to these five groups of materials. Other 'non-hazardous' seed cake like materials or any future oily vegetable materials cannot rely on this schedule. Furthermore, as it was noted that this schedule essentially only applies to the materials specifically listed under the BCSN, it was questioned as to whether this should be a seed cake entry at all. It does not include whole seeds (soya beans, sunflower seeds, etc.), materials not related to seeds (citrus pulp) or extracted seed that have not been shaped into "cakes" (bakery materials, meal, oily vegetables, etc.);.5 there is a potential need for a Class 4.2 UN 3088 SEED CAKE (processed oily vegetables) schedule in the IMSBC Code; however, it was concluded that this should be considered where the properties of these products indicate that such a schedule is required;.6 the true oil content of some seed cake, particularly pellets, is difficult to determine where part the oil content is locked in the structure of cereals and grains as fats. In such cases it may be difficult to determine if oil levels exceed 1.5%;.7 there is no MHB entry for seed cake, oily vegetables and their residues or pellets. However, experience has shown that some materials shipped, which do not meet the criteria for classification as Class 4.2, present significant self-heating risk when shipped in bulk. Any resulting fire can be deep seated and difficult to extinguish. Such cargoes should be shipped under an MHB Schedule. Section 9 of the IMSBC Code details how such MHB properties are to be identified for new schedules; and.8 the individual schedule for GRAIN SCREENING PELLETS describes materials that could also be considered under the SEED CAKE entries; however, this is a Group C schedule related to a very specific material. It was desirable to consider this schedule in the process to minimize duplication and

4 Page 4 avoid unnecessary additional schedules. However, it was also noted that the risks associated with these pellets includes the fact they have grain like qualities and amalgamation with the SEED CAKE (non-hazardous) resulted in a very complex schedule. The view was expressed that GRAIN SCREENING PELLETS should not be captured as a seed cake and should be subject to the Grain Code. 5 While noting the benefit of harmonizing the classification of dangerous goods in solid bulk form with the UN Model Regulations, it is recognized that harmonization between the IMDG Code entries with the UN Model Regulations is the first step given the linkage between the IMSBC Code and IMDG Code in SOLAS chapter VII. Proposals to align the IMSBC and IMDG Code and UN Model Regulations will be subject to separate proposals. 6 It was noted in document E&T 25/3 that the issue of SEED CAKE had been taken to the UN Committee of Experts on the Transport of Dangerous Goods (UNTDG), but they had not agreed to the proposal to amend the existing entries for SEED CAKE, therefore, the proper shipping name covers further organic materials with self-heating properties. This decision is based on the fact that N.O.S entries apply to the transport of packaged organic material of Class 4.2; however, the N.O.S entries do not cover seed cake (see document ST/SG/AC.10/C.3/2015/7, paragraphs 30 and 31 of document ST/SG/AC.10/C.3/94). It is unlikely that changes could be progressed though UN TDG for inclusion in the IMDG Code before the amendment On this basis, no changes to the schedules for SEED CAKE classified as UN 1386 and UN 2217 can be considered at this time. As it is not in the remit of the UNTDG to consider MHB classification and there is no barrier to consideration of an individual schedule for Group B (self-heating). Cargo properties, inclusion of whole seeds and relationship with the International Grain Code 7 As indicated in the existing individual schedules, the main risk associated with seed cake, processed oily vegetables and pellets is self-heating. Oxidation of whole seeds and whole vegetables is prevented by their external protective skins, shells or husks. However, crushed, extracted or otherwise processed vegetable materials and seeds are more liable to oxidize (and self-heating as a consequence) due to the following mechanism where processing exposes internal tissues:.1 such tissues are more prone to atmospheric oxygen oxidation or decomposition as exposed internal tissues are more easily attacked by microorganisms; and.2 hydrolysis and decomposition caused by vegetable enzymes. These enzymes in living plants are usually segregated into cellular organelles, in order to prevent them from attacking and decomposing the plant's own tissues. When plant tissues are processed the enzyme containing organelles are broken and the enzymes are freely released into the tissues and begin to decompose them. 8 As oxidation of whole seeds and whole vegetables is prevented by their external protective skins, shells or husks, such seeds and vegetables can be safely carried under the Grain Code, however, the co-sponsors noted such materials are sometimes combined with processed material and the seed cake, residue or pellet may present a self-heating hazard as a result.

5 Page 5 9 The co-sponsors also noted that, in case of amalgamation of the schedule for GRAIN SCREENING PELLETS with SEED CAKE schedules, some cargoes, particularly pellets, may be non-cohesive and have an angle of repose of less than 30 degrees. Such cargoes should be carried in accordance with the precautions in the Grain Code. However, where these cargoes possess hazards in accordance with section 9 of the IMSBC Code, the hazards also need to be addressed in accordance with the IMSBC Code. 10 This issue highlights the difficulty in the relationship between the Grain Code and the IMSBC Code. There are non-cohesive cargoes which flow like grain and present similar risks insofar as stowage and carriage, but:.1 where the cargo does not consist of whole seeds these materials may not be subject to the Grain Code, even though the same loading precautions and stability calculations should be applied to their carriage by virtue of appendix 3 and section 5 of the IMSBC Code; or.2 where the cargo contains whole seeds but also presents a chemical hazard due to these seeds being combined with other materials (as is commonly the case with animal feed pellets), these materials need to be subject to carriage requirements that address the chemical hazard, as well as the loading precautions and stability calculations prescribed under the Grain Code by virtue of appendix 3 and section 5 of the IMSBC Code. 11 In the course of discussions related to grain-like behavior of bulk cargoes, the co-sponsors noted the following:.1 while SOLAS regulation VI/1-2 requires the carriage of solid bulk cargoes, other than grain to be in compliance with the IMSBC Code, it does not limit the applications of the IMSBC Code to grain cargoes nor does it specify that the IMSBC Code is applicable to non-grain bulk cargoes only;.2 that SOLAS regulation VI/9.1 requires grain to be carried in compliance with the International Grain Code "in addition to any other applicable requirements of the present regulations". SOLAS regulation VI/1-1 defines the IMSBC Code and the term "Solid bulk cargo" which includes grain. This indicates that the IMSBC Code is applicable to grain;.3 however, the definition of grain in SOLAS regulation VI/8.2 and in the Grain Code refers to the processed forms of grain "whose behavior is similar to that of grain in its natural state";.4 the Grain Code provides no guidance as to how to assess if the behavior of a processed grain is "similar to that of grain in its natural state". On this basis, Section 5 of the IMSBC Code is the only mechanism that applies the Grain Code to "processed forms of grain";.5 while cohesion is the fundamental criterion for assessing the flowing properties of materials, section 5 of the IMSBC Code does not provide any specific procedure for determining cohesiveness of cargoes; and.6 the assessment of cohesive properties is open to subjective interpretation and misinterpretation by shippers as the angle of repose alone is not an indicator of cargo stability. The absence of a procedure means there is no uniform method to determine whether or not certain bulk materials "flow freely like grain".

6 Page 6 12 The co-sponsors concluded that the problem of determination of cohesive properties of cargoes is not properly addressed in the IMSBC Code and that the problem of application of both the Grain Code and the IMSBC Code to non-cohesive bulk cargoes (including grain) could only be solved if the IMSBC Code provides a standard uniform method to assess cohesion of materials.the co-sponsors agreed that this was a complex issue and needs to be examined separately as it has broader ramifications. 13 The complexity of the situation was also such that the co-sponsors concluded it might need to be addressed separately and more widely in the context of possible amendments to the individual schedule for GRAIN SCREENING PELLETS. To avoid unnecessary complexity and ambiguity, the co-sponsors recommend that GRAIN SCREENING PELLETS should not belong to the new proposed schedules for the residues of processed oily vegetables and that these schedules should be kept separate. 14 Finally, it was noted that the process of classifying self-heating SEED CAKE relies on the presence of solvent residues in solvent extracted SEED CAKE. The co-sponsors considered that a diagram would provide additional clarity in this process. Outcomes 15 The individual schedules for SEED CAKE UN 1386 (a) and (b) and SEED CAKE UN 2217 cannot be revised, but the co-sponsors consider that new Group C and MHB Group B SEED CAKE schedules are required. It is recommended that the existing individual schedule for SEED CAKE (non-hazardous) be substituted with two new schedules, resulting in a Group B (MHB - self-heating) and a Group C (non-hazardous) schedule. This would involve broadening the description in the resultant schedules to capture seed cake and processed oily vegetables. 16 The co-sponsors also recommend that the BCSN used in these schedules needs to be modified to ensure the link between all schedules is obvious. The five resultant schedules would be:.1 SEED CAKE UN 1386(a);.2 SEED CAKE UN 1386(b);.3 SEED CAKE UN 2217;.4 SEED CAKE AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES - Group B, MHB schedule; and.5 SEED CAKE AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES (non-hazardous) Group C schedule. 17 In this regard, the co-sponsors propose that the existing individual schedule for SEED CAKE (non-hazardous) be replaced with new individual schedules for SEED CAKE AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES and SEED CAKE AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES (non-hazardous). Proposed draft schedules are set out in annex 1 and annex 2 respectively. 18 In addition, the co-sponsors propose that a new paragraph bis and the associated classification diagram be included in section of the IMSBC Code. The proposed draft amendments are set out in annex 3.

7 Page 7 Action requested of the Sub-Committee 19 The Sub-Committee is invited to consider the above information and take action as appropriate. ***

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9 Annex 1, page 1 ANNEX 1 PROPOSED DRAFT INDIVIDUAL SCHEDULE FOR SEED CAKE AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES This schedule applies to materials which have been tested according to N.4 of the UN Manual of Tests and Criteria and certified by a person recognized, by the competent authority of the country of shipment, not to meet the criteria for Class 4.2. Description Any pulp, meal, cake, pellets, expellers or residues produced from oil-bearing seeds, grains, cereals, fruit or vegetables, after oil has been solvent extracted, vapour extracted or extracted by other chemical or mechanical processes, that possesses hazards only when carried in bulk Characteristics Angle of repose Bulk density (kg/m³) Stowage factor (m³/t) Various* 478 to to 2.09 Size Class Group Various MHB (SH [OH]) B * When shipped in the form of pellets, materials covered by this schedule could be non-cohesive and where the angle of repose is 30 or less, may flow freely like grain Hazard Some materials have a tendency to self-heat.1 if contaminated by oily residue and/or.2 where shipped above 11% moisture and at high temperature Liable to oxidize, causing subsequent reduction of oxygen in the cargo space. Non-cohesive pellet cargoes may flow freely like grain. See section of this Code. Loading of pellets may evolve explosive dusts. Carbon dioxide may also be evolved. Stowage and Segregation Segregation as required for class 4.2 materials unless determined otherwise by the competent authority. Hold cleanliness Clean and dry as relevant to the hazards of the cargo. Weather precautions This cargo shall be kept as dry as practicable. This cargo shall not be handled during precipitation. During handling of this cargo all non-working hatches of the cargo spaces into which this cargo is loaded or to be loaded shall be closed. Loading A certificate from a person recognized by the competent authority of the country of shipment specifying the oil content and moisture content is to be issued prior to loading commencing. This cargo shall only be accepted for loading when the temperature of the cargo is not higher than the ambient temperature plus 10 C, or 55 C, whichever is lower. Loading of dry pellets using cargo blowers may result in the generation of static electricity and present a risk of dust explosion. Blower equipment shall be earthed. Piping shall be electrically continuous or earthed.

10 Annex 1, page 2 Solvent extracted cargo shall only be accepted for loading when certification that the cargo will not give off dangerous gases that would result in a risk of explosion during carriage. Such certification is to be provided by a person recognized by the competent authority of the country of shipment. Trim in accordance with the relevant provisions required under sections 4 and 5 of the Code. Non-cohesive pelletized materials shall be loaded in accordance with the applicable requirements of subsection 5.4 of the Code. Precautions The temperature of this cargo shall be measured regularly at a number of depths in the cargo spaces and recorded during the voyage. If the temperature of the cargo reaches 55 C and continues to increase, ventilation to the cargo shall be stopped. If self-heating continues, then carbon dioxide or inert gas shall be introduced to the cargo space. The use of carbon dioxide, if fitted, shall be withheld until fire is apparent. Entry of personnel into cargo spaces for this cargo shall not be permitted until tests have been carried out and it has been established that the oxygen content has been restored to a normal level. Electrical circuits for equipment in cargo spaces which is unsuitable for use in an explosive atmosphere, shall be isolated by removal of links in the system other than fuses. Spark-arresting screens shall be fitted to ventilators to the cargo spaces containing of this cargo. Persons who may be exposed to the dust of the cargo shall wear a dust filter mask, protective eyewear, and protective clothing as necessary. Ventilation Surface ventilation, either natural or mechanical, shall be conducted as necessary, for removing any residual solvent vapour. To prevent self-heating of the cargo caution is required when using mechanical ventilation. Carriage Hatches of the cargo spaces carrying this cargo shall be weathertight to prevent the ingress of water. Discharge No special requirements. Clean-up No special requirements. Emergency procedures Special emergency equipment to be carried Self-contained breathing apparatus. Emergency procedures Wear self-contained breathing apparatus. Emergency action in the event of fire Batten down; use ship's fixed CO 2 fire-fighting installation, if fitted. Medical first aid Refer to the Medical First Aid Guide (MFAG), as amended.

11 Annex 1, page 3 Remarks The use of CO 2 or inert gas is limited to controlling the fire, and further amounts may need to be injected from time to time during passage to reduce the oxygen content in the hold. On arrival in port, the cargo will need to be removed in stages to reach the seat of the fire. ***

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13 Annex 2, page 1 ANNEX 2 PROPOSED DRAFT INDIVIDUAL SCHEDULE FOR SEED CAKE AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES (non-hazardous) SEED CAKE AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES (non-hazardous) The provisions of this schedule apply to:.1 Solvent extracted or mechanically expelled pulp pellets and meal exempted from SEED CAKE UN 1386(b) or SEED CAKE UN Any other pulp, meal, cake, pellets, expellers or residues produced from oil-bearing seeds, grains, cereals, fruit or vegetables, after oil has been solvent extracted, vapour extracted or extracted by other chemical or mechanical processes, that will not present a hazard during carriage Description Residue remaining after oil has been extracted, by solvent or mechanical processes, from oil-bearing seeds, grains, cereals, fruit or vegetables. The above may be shipped in the form of pulp, meals, cake, pellets, expellers. Characteristics Angle of repose Bulk density (kg/m³) Stowage factor (m³/t) Various* 478 to to 2.09 Size Class Group Various Not applicable C * When shipped in the form of pellets, materials covered by this schedule could be non-cohesive and where the angle of repose is 30 or less the cargoes may flow freely like grain. Hazard Liable to oxidize, causing subsequent reduction of oxygen in the cargo space. Non-cohesive pellet cargoes may flow freely like grain. See section of this Code. This cargo is non-combustible or has a low fire-risk. Stowage and Segregation No special requirements. Hold cleanliness Clean and dry as relevant to the hazards of the cargo. Weather precautions This cargo shall be kept as dry as practicable. This cargo shall not be handled during precipitation. During handling of this cargo all non-working hatches of the cargo spaces into which this cargo is loaded or to be loaded shall be closed. Persons who may be exposed to the dust of the cargo shall wear a dust filter mask, protective eyewear, and protective clothing as necessary.

14 Annex 2, page 2 Loading Trim in accordance with the relevant provisions required under sections 4 and 5 of the Code. Where the material has been exempted from the schedules for schedule for seed cake UN 1386 (b) or UN 2217 a certificate from a person recognized by the competent authority of the country of shipment shall be provided by the shipper, prior to loading, stating that the requirements for exemption as set out either in the schedule for seed cake UN 1386 (b) or UN 2217, whichever is applicable, are met. Non-cohesive pelletized materials shall be loaded in accordance with the applicable requirements of subsection 5.4 of the Code. Precautions Entry of personnel into cargo spaces for this cargo shall not be permitted until tests have been carried out and it has been established that the oxygen content has been restored to a normal level. Ventilation No special requirements. Carriage Hatches of the cargo spaces carrying this cargo shall be weathertight to prevent the ingress of water. Discharge No special requirements. Clean-up No special requirements. ***

15 Annex 3, page 1 ANNEX 3 PROPOSED DRAFT AMENDMENTS TO THE INTERNATIONAL MARITIME SOLID BULK CARGOES (IMSBC) CODE Section 9 Materials possessing chemical hazards Materials hazardous only in bulk Self-heating solids Add the new paragraph bis as follows: " bis The classification of SEED CAKE cargoes is also dependent on the presence of flammable solvents in solvent-extracted materials. The chart below illustrates the classification procedure and is to be read in conjunction with and "