The Present Danger
This season, iron ore fines exports from Goa are set to resume, with some mining activity being allowed in the state; an estimated 15 to 25 million tonnes will be shipped. This is welcome news for the economy, but it presents a significant safety concern for critical reasons: the cargo intended for shipment has been stockpiled and exposed to the elements for many years. Freshly mined cargo, if any at all, will be blended with these “dumps” as they are commonly called. But how does one sample a stationary stockpile-especially ones which have existed forever and even have green vegetation growing on their surfaces? This is not a theoretical concern. Representative sampling of large static stockpiles is extraordinarily difficult even under ideal conditions. The IMSBC Code Chapter 4 provides guidance, but proper execution requires a trained team, a detailed sampling plan, heavy machinery such as bulldozers to dig into the cargo, and multiple rounds of sampling as the stockpile is progressively broken down during its transportation. Very few organizations in India currently possess this capability.
The Commercial Pressure
The resumption of exports has created intense commercial pressure. Shippers who have held non- performing assets for over a decade are eager to monetize their cargo. Shipowners and charterers, facing tight freight markets, are reluctant to refuse cargo or delay sailing for additional testing. Surveyors and sampling companies, having survived years of minimal business, face pressure to provide “cargo pass” certificates at the lowest possible cost.
The writer has witnessed this pressure firsthand. Samples are delivered to accredited laboratories and fail testing. Shortly afterward, another sample arrives, purportedly from the same stockpile for the same vessel, and passes. How these samples are drawn, where they are drawn from, and how they are mixed remains unclear. While the laboratory may note that samples were not drawn under their supervision, this disclaimer means little to a master who sees a certificate from a competent authority- approved laboratory and accepts the cargo.
Shippers are appointing surveyors with no experience or competency in iron ore sampling, selecting them purely on cost. Some requests are explicit: provide a certificate that allows the cargo to be loaded, regardless of actual conditions. Surveyors who maintain proper standards risk losing business to competitors willing to provide the desired result.
The Institutional Memory Gap
The officers currently serving in the Competent Authority, in P&I Clubs, and in correspondent organizations have largely changed since 2009. The new generation has studied cargo liquefaction in training courses. Few have seen it occur. Fewer still experienced the landscape as it existed before the 2009 casualties—the commercial pressures, the inadequate testing, the near-misses, and the ultimate tragedies.
This gap in institutional memory is dangerous. Those who witnessed the Black Rose and Asian Forest casualties understood viscerally why proper sampling and testing procedures are non-negotiable. They saw the consequences of cutting corners. They knew that behind every certificate and every test result stood the lives of seafarers who would sail with that cargo.
Today’s decision-makers may lack that direct experience. Commercial considerations have begun to influence survey appointments by clubs and their correspondents. Correspondents, who serve as the clubs’ eyes and ears in port, appear to have forgotten that the best surveyor should be appointed, not the most convenient or least expensive one. Some correspondents have abandoned professional ethics entirely and invested in their own private survey firms, creating direct conflicts of interest. The loss of export volume has meant a loss of commission income, and the temptation to recover that income through cost-cutting or self-dealing has proven difficult to resist.
96 | ISSUE 115 | MAR 2026 | THE REPORT
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