Environmentally Hazardous Bulk Cargoes and the IMSBC Code

The BIMCO Marine Department has received some enquiries regarding mineral concentrates and metal sulphide concentrates in the International Maritime Solid Bulk Cargoes (IMSBC) Code. The enquiries centered on whether these cargoes are considered environmentally hazardous substances (EHS) and thus should be IMO-classed 9

(i.e. miscellaneous hazardous substances that are not classifed elswhere in the IMDG Code) and having UN 3077 listing.
Members should take note that environmentally hazardous substances are currently not covered in the IMSBC Code for bulk materials and this has been brought to the attention to the relevant committees in the International Maritime Organzation. It was agreed thereat that this matter needed further investigation.
Members should also note that notwithstanding the above, there may be stricter requirements at the port of loading/discharg regarding the declaration of mineral concentrates and metal sulphide concentrates in terms of them being EHS. For instance, please see the marine notice issued by the Australian Maritime Safety Authority imposing additional requirements to be implemented for these cargoes in respect of their properties that may meet the criteria as EHS under UN 3077.
Therefore, it would be prudent for members to always check beforehand, the requirements at the port of loading/discharge when shipping the above-mentioned cargoes so as to ensure that the additional requirements, if any imposed by these port authorities are adhered to apart from the normal compliance required by the IMSBC Code.