Gard has once again alerted its Members and clients to the significant risks associated with bulk cargo liquefaction. The recent tragic loss of crew members on a bulk carrier in the Bay of Bengal has renewed concerns about the safety of certain iron ore fines shipments, particularly from ports on the east coast of India.

While the cause of the capsize and sinking has not yet been established, authorities have reported that the vessel was carrying iron ore fines from Paradip. Gard is also aware of further cases involving iron ore fines loaded in the region in which liquefaction is suspected, and separately, of a recent case involving the liquefaction of iron ore fines loaded in Brazil, underlining that the risk is not confined to Indian ports.

Group A cargoes: a perennial liquefaction risk

Under the International Maritime Solid Bulk Cargoes (IMSBC) Code, cargoes such as iron ore fines are classified as Group A, meaning they may liquefy if shipped with moisture content exceeding their Transportable Moisture Limit. Liquefaction occurs when cyclic forces from a vessel's motion cause cargo to behave like a liquid rather than a solid, and it can lead to cargo shift and loss of vessel stability. This has been a recurring cause of bulk carrier casualties for decades. As highlighted in Intercargo's Bulk Carrier Casualty Report 2015-2024, the consequences can be catastrophic, resulting in loss of life, loss of vessels, and significant environmental and commercial impacts. Despite extensive international regulation and industry guidance, Gard continues to encounter cases where cargo is loaded in a dangerously wet condition, often linked to inadequate moisture management practices and to concerns about the reliability of the cargo sampling and testing arrangements on which shipper declarations are based.

Overview of Group A shipments from India

Gard's correspondent, James MacKintosh & Co., has prepared an overview of the major Group A cargoes exported from India, including key loading regions and seasonal weather patterns. Seasonal weather is particularly relevant here: India's east coast is exposed to the southwest and northeast monsoons, which bring heavy rainfall during parts of the year and increase the likelihood that uncovered cargo will absorb moisture.

In many ports, stockpiles are stored in open yards, sometimes with only limited protection from tarpaulins, and may remain exposed to the elements during transportation by road, rail, or barge. These conditions can raise moisture content beyond the Transportable Moisture Limit (TML). The correspondent has also raised concerns that, where cargo is delivered to ships by barges, samples taken from shore stockpiles may not always be representative of the cargo ultimately loaded on board.

Regulatory requirements and local precautions

Gard's understanding is that NT/ENG Circular No. 2 of 2017 remains in force and should be read together with other notices (M.S. Notice No. 9 of 2010, M.S. Notice No. 31 of 2009, and M.S. Notice No. 34 of 2009). In addition, the Mercantile Marine Department (MMD) Kolkata has reportedly introduced further precautions for the carriage of Group A cargoes, although these have yet to be formally published through a circular. Members should watch for formal publication of these measures, as they may add to the documentation and testing requirements already applicable at Indian loading ports. Members are encouraged to contact their local agents for the latest requirements and guidance applicable to specific loading ports. Guidance can also be obtained from the local correspondent. In consultation with the Club, Members should consider appointing their own surveyor to assist the master.

Gard's geofencing

Gard's geofencing alerts are limited to owned vessels entered with Gard and do not detect vessels for charterer Members. It is therefore important for charterers to notify Gard every time they fix their vessels to load such cargo. The main purpose of the geofencing alert is not to monitor Members' activity, but to provide support by highlighting the risks involved when carrying cargoes that can liquefy and the precautions that can be taken to mitigate those risks.

Key recommendations

Members with vessels scheduled to load iron ore fines or other Group A cargoes in India should exercise heightened caution and ensure that shippers fully comply with their obligations under the IMSBC Code. Particular attention should be paid to cargo declarations and certificates for moisture content and the transportable moisture limit, and to evidence that approved moisture management, sampling, and testing procedures are being followed and are code compliant.

The IMSBC Code states that bilges should be sounded and that the appearance of the cargo surface shall be checked regularly during the voyage. Risk indicators include cargo shift or movement of the stow with the vessel, a flattening of the cargo profile, softening at the periphery, or surface water and slurry. If there are concerns that liquefaction may be occurring, the master should seek third-party expert support and take action to reduce the energy input into the cargo, for example by avoiding beam seas. Early intervention can be critical in preventing a deterioration of the vessel's stability condition.

Source: Gard,