The Master’s Dilemma
Masters face an impossible situation. They arrive at an Indian port to load iron ore fines. The shipper provides certificates from a laboratory approved by the Directorate General of Shipping showing that the cargo’s moisture content is below the Transportable Moisture Limit. The certificates appear to comply with IMSBC Code requirements. The master has limited time, limited local knowledge, and immense commercial pressure to load and sail.
How is the master to know that the samples were not drawn properly? How is he to know that the laboratory, while accredited, received samples of unknown origins? How is he to verify that the stockpile from which his cargo will be loaded is the same stockpile that was sampled? How is he to assess whether a stockpile that has sat for twelve years through multiple monsoons is safe to load, when no approved sampling procedure exists for stockpiles over three metres high?
Yes, he has the Can-test to turn to – which at best remains a rudimentary method to determine the fitness of the cargo, and it cannot replace laboratory testing.
The master’s authority to refuse unsafe cargo is clear under SOLAS and the IMSBC Code. But exercising that authority requires either clear evidence of danger or strong support from the shipowner and P&I Club. When certificates appear to be in order and commercial pressure is intense, masters often have no practical choice but to load.
This places the master in an untenable position. If the cargo liquefies at sea, the master and crew pay the price. If the master refuses cargo based on reasonable concerns but cannot prove it is unsafe, the shipowner faces claims for delay and breach of charter. The system should protect masters who exercise proper caution. Instead, it often penalizes them.
The Role of P&I Clubs and the IIMS
Protection and Indemnity Clubs have a vital role in preventing casualties. They provide insurance, but more importantly, they provide loss prevention guidance and support to masters facing difficult cargo decisions. Clubs maintain correspondent networks in ports worldwide to provide local expertise and oversight.
However, the effectiveness of this system depends entirely on the quality of correspondents and surveyors appointed. When correspondents prioritize cost over competence, or when they have financial interests in the survey firms they appoint, the system fails. When clubs accept the lowest-cost survey rather than insisting on the best-qualified surveyor, they undermine their own loss prevention objectives.
The International Institute of Marine Surveying (IIMS) has a critical role to play in addressing this problem. As the professional body representing marine surveyors worldwide, the IIMS can establish and maintain lists of qualified experts for critical cargo operations, including iron ore fines sampling and testing. These lists should be made available to the International Group of P&I Clubs, allowing claims handlers to identify and appoint competent surveyors regardless of local commercial pressures.
The IIMS has raised this issue at every forum, conference, and annual general meeting. The organization’s leadership, including the current President, has highlighted the dangerous state of affairs in Indian iron ore exports. But awareness alone is insufficient. The IIMS must work with the International Group to create a formal framework ensuring that the best surveyor is appointed for safety-critical operations, not merely the most convenient or least expensive.
THE REPORT | MAR 2026 | ISSUE 115 | 97
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