untrimmed”. It refers to “a specially suitable compartment which is not filled to the maximum extent possible in way of the hatch opening but is filled to a level equal with or above the bottom edge of the hatch end beams and has not been trimmed outside the periphery of the hatch opening by the provisions of A 10.4”. In this scenario, the compartment is filled to or above the bottom edge of the hatch end beams, but not to the maximum possible level, and the ends outside the hatch coaming are left untrimmed. The grain outside the hatch opening may rest at its natural angle of repose, and only the free grain surface in way of the hatch opening must be level.
One of the advantages of this method is that it eliminates the need for trimming the ends, which was previously required, thereby significantly reducing cargo handling time. Allowing trimming operations to be omitted beneath a cross deck significantly reduces the operational burden while maintaining compliance with safety requirements, this is presumed to be the rationale behind the amendment. When trimming is deemed unnecessary, the fundamental premise is that the risk of lateral movement does not arise. Nevertheless, safety considerations remain critical, including recalculating the inclination moment, shifting moment, and cargo volume curve under the new configuration, and ensuring that stability calculations (including residual stability) are accurately reflected. Failure to meet these requirements may result in the condition being judged unsafe, creating a risk of warnings during cargo handling authorisation or inspection.
The amendments apply to new buildings with keel laid on or after 1 January 2026, and to existing ships wishing to use the new loading condition for improved flexibility and compliance. For existing ships, the amended Grain Code can also be applied to improve loading flexibility and demonstrate compliance with the new requirements.
Actions required by vessels and owners
While the changes offer the advantage of reducing cargo handling time, if existing vessels are to load in this way it will be necessary to address the heeling moments for the new loading configuration and update the Grain Loading Manual accordingly. The following actions should be taken by shipowners/operators:
Revision of the Grain Loading Manual: Incorporate into the existing manual the new heeling moment curves, filling levels and volume curves, and assumptions regarding the angle of repose.
Update of the Grain Loading Computer: Integrate the new loading configuration into the loading computer and obtain certification.
Class and Authority Approval: Submit the revised Grain Loading Manual (for the relevant vessel) to the flag administration or a recognised organisation for approval. For vessels intending to use the new condition, the definition of “specially suitable compartment” must be correctly included in the manual.
Coordination with Charterers and Loading Ports:
Discuss in advance with charterers, grain shippers, and stevedores the potential use of the “new loading condition,” and confirm that the loading port understands the new condition and agrees to omit trimming during cargo operations.
How this matters for P&I claims
As we have seen, the upcoming revision of the Grain Code allows untrimmed ends below the Cross Deck with only the exposed surface near the hatch level. If the revised inclination/shifting moments and residual stability are not correctly
calculated and approved, any resulting list or cargo shift may be argued as foreseeable and preventable, which potentially weakens a carrier’s defence under Hague or Hague-Visby Rules by assisting the cargo interests to argue about the vessel’s unseaworthiness or want of due diligence for seaworthiness at the commencement of the voyage. Conversely, evidence of correct calculations/approvals and records of proper monitoring on each voyage (e.g. verified stowage plans, hold-by-hold trim photos and records of on-voyage monitoring etc.) can strengthen the carrier’s defences in cargo damage claims resulting from the vessel’s list or cargo shift.
In addition, where the cargo loading under the new condition can affect the fumigation efficacy and ventilation plans, potential claims (including recoveries) for insect damage, taint or crew exposure may hinge on whether the revised preparation/monitoring steps were followed, and on the chain of responsibility within the charterparty chain (and possibly with the fumigator).
Potential legal implications
One issue that we see being raised is whether Owners or Charterers should pay for the costs associated with the operational steps above. The cost of revising a vessel’s manual documentation, updating computer software and dealing with Flag administration could be significant, so if the Charterers want this to be done, should the costs be for their account? Unfortunately, the answer is not easy and will depend on the particular terms of the charterparty in question, but as there is no obligation on the owners of existing vessels to make any of these changes, the starting position is likely to be that Charterers must persuade Owners to take these steps and revise their manuals – rather than being able to force it on the Owners.
THE REPORT | MAR 2026 | ISSUE 115 | 73
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