What Must Happen Now
The situation is urgent but not yet irreversible. Exports are resuming, but large-scale shipments have not yet commenced. There is a narrow window of opportunity to prevent the next casualty. The following actions must be taken immediately:
For P&I Clubs and the International Group
Establish minimum standards for surveyor appointment on iron ore fines shipments, particularly from Indian ports. Cost must not be the determining factor. Competence, experience, and independence must be verified before appointment.
Prohibit correspondents from appointing their own affiliated survey firms for safety-critical operations. The conflict of interest is obvious and unacceptable.
Require independent pre-loading surveys by qualified surveyors for all iron ore fines shipments from stockpiles that have been inactive for more than one year. The survey must include visual inspection of stockpiles, witnessing of sampling, and independent verification of cargo condition.
Establish standard rates across clubs for specific regions and cargo types to prevent a “race to the bottom” where surveyors compete solely on price. Professional services should be compensated at levels that allow proper execution.
Work with the IIMS to maintain and publish lists of qualified surveyors for iron ore fines operations, making these lists available to all claims handlers and correspondents.
Issue clear guidance to members that masters have full authority to refuse cargo if they have reasonable concerns about safety, and that clubs will support masters who exercise proper professional judgment even if this results in commercial disputes.
For Shipowners and Masters
Do not rely solely on shipper-provided certificates. Appoint independent surveyors to witness sampling and verify cargo condition before loading commences.
Exercise the authority provided under SOLAS and the IMSBC Code to refuse cargo that presents a reasonable safety concern, even if certificates appear to be in order. Document concerns clearly and seek support from the P&I Club.
Conduct can tests on cargo from each barge or stockpile before accepting it aboard. If the can test shows free moisture or cargo instability, stop loading immediately and require additional laboratory testing.
Obtain moisture analysis when approximately 75% of cargo is loaded to verify that conditions have not changed during loading operations.
Avoid loading iron ore fines during or immediately after the monsoon season unless absolutely confident that cargo has been properly protected and tested.
Maintain detailed records of all cargo documentation, sampling procedures, test results, and any concerns raised during loading. These records are essential if a dispute or casualty occurs.
For Shippers
Accept that proper sampling and testing are non- negotiable requirements, not obstacles to trade. The cost is minimal and the alternative is unacceptable.
Engage qualified sampling companies with trained personnel and proper equipment to conduct sampling under approved procedures. Do not select samplers based solely on cost.
Protect stockpiles from weather exposure using effective covering systems. Cargo that has been exposed to multiple monsoon seasons cannot be assumed safe for loading without extensive testing.
Provide complete and accurate information about stockpile history, including age, source, previous handling, and exposure to weather.
Cooperate fully with masters and surveyors who raise legitimate concerns about cargo condition. Commercial considerations must not override safety.
Recognize that providing false or misleading cargo certificates is not merely a commercial matter—it is a criminal act that endangers lives.
98 | ISSUE 115 | MAR 2026 | THE REPORT
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