4.4.2. Sampling shall be conducted only by persons who have been suitably trained in sampling procedures and who are under the supervision of someone who is fully aware of the properties of the consignment and also the applicable principles and practices of sampling.


4.4.3. For a concentrate or other cargo which may liquefy, the shipper shall facilitate access to stockpiles for the purpose of inspection, sampling and subsequent testing by the ship’s nominated representative


CARGOES THAT MAY LIQUEFY 7.1.2. A ship’s motion may cause a cargo to shift sufficiently to capsize the vessel. Cargo shift can be divided into two types, namely, sliding failure or liquefaction consequence. Trimming the cargoes in accordance with the Code can prevent sliding failure.


7.2.3. A cargo shift caused by liquefaction may occur when the moisture content exceeds the TML. Some cargoes are susceptible to moisture migration and may develop a dangerous wet base even if the average moisture content is less than the TML. Although the cargo surface may appear dry, undetected liquefaction may take place, resulting in shifting of the cargo.


7.3.1.1. Concentrates or other cargoes which may liquefy shall only be accepted for loading when the actual moisture content of the cargo is less than its TML.


What are the shippers’ obligations? Shippers are obliged to:


1. Provide Owners/Master with: (i) accurate information of the cargo before loading


(ii) signed certificate of the TML of the cargo


(iii) signed certificated or declaration of the moisture content of the cargo


2. Facilitate access to stockpiles for sampling


3. Arrange samples to be properly tested


Photo from www.skuld.com The reality


Although the Code sets out shippers’ obligations very clearly, in reality they were rarely complied with. For instance:


1. Shippers certificates: Very often the shippers’ certificates are forged. The MC or TML declared by shippers are often inaccurate and the error can be as much as 10%.


2. Sampling during loading: Local shippers/mines are very


Loading at anchorage by barges


influential organisations and they are often armed. When a Master or local surveyors keep rejecting bad cargo, local surveyors might receive death threats from shippers. Moreover, dry cargoes can be placed onto wet cargo as disguise. From our experience, even for samples collected at dry season, they still failed the lab test.


3. Stockpiles: The stockpiles are also owned by the powerful shippers/mines. The stockpiles are normally located in remote locations and access is often rejected. The stockpiles are seldom covered hence are exposed to the prevailing weather.


4. Location of loading areas: As mentioned above, the stockpiles and loading areas are usually located in very remote areas with restricted access. The loading areas are often ill-equipped and loading often takes place at anchorage owing to the absence of any proper loading port.


5. Loading from barges: Owing to the lack of proper loading facilities, loading often takes place at anchorage using barges. Like the stockpiles, the barges are seldom covered and are also exposed to the weather. Moreover, where there is more than one vessel loading in one area, a barge being rejected by one vessel will be presented to another. In the absence of a good surveyor onboard, one may end up having to load cargo that has been rejected by other vessels, without any treatment or sun drying.


The Report • September 2018 • Issue 85 | 57


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