30 November 2022

Flexible intermediate bulk containers (FIBCs) and dry chemicals

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‘Jumbo Bags with Jumbo Claims’

We continue to see a high number of incidents and claims from bagged cargoes being stowed in the same compartments as break bulk and steel cargoes. We are also seeing claims brought about by different bagged chemicals being stowed together in the same hold on bulk carriers.

The claims include Flexible Intermediate Bulk Containers (FIBCs) commonly referred to as ‘bulk bags’, ‘jumbo bags’ or just ‘big bags’ that have been damaged such as ripped, torn or collapsed due to other factors including:

  • Not being stowed and secured in accordance with IMO Rules and guidance and good seamanship practice

  • Poor handling during the loading and discharging

  • Poorly constructed FIBCs

  • FIBCs failing for being utilised outside their intended design such as exceeding stowed tier height

What are FIBCs?

FIBCs have a body of a flexible woven material (typically polypropylene) and is intended to ship solid material in powder, flake or granular form. It is designed to be handled from the top by permanently attached lifting loops/slings which can be lifted by cranes, hoists or forklifts. They are frequently used to ship foodstuffs, agricultural product chemicals such as fertilisers, and pharmaceuticals.

FIBCs are manufactured to international standard such as EN ISO 21898 Packaging – Flexible Intermediate bulk containers for non-dangerous goods. The FIBC should have a label or printed on the material markings such as:

  • Safe Working Load (SWL)

  • Date of production

  • Number of certificates of construction and the date of issuance for the certificate

  • Type of FIBC, such as heavy duty or standard

FIBCs can be used to transport hazardous materials and/or dangerous goods if presented in an approved package for your particular products and it complies with the applicable regulatory code such as the International Maritime Dangerous Goods (IMDG) Code.

Statutory Regulations and Industry Practice

SOLAS (the International Convention for the Safety of Life at Sea)

SOLAS Chapter VI Regulation 5 (1) states that “Cargo, cargo units* and cargo transport units** carried on or under deck shall be so loaded, stowed and secured as to prevent as far as is practicable, throughout the voyage, damage or hazard to the ship and the persons onboard, and loss of cargo overboard.”

SOLAS Chapter VI Regulation VI/5 and VII/5 require that cargo units and cargo transport units, including containers, be loaded, stowed and secured throughout the voyage in accordance with a Cargo Securing Manual (CSM) approved by the Authority (usually the Classification Society on behalf of the Flag State Administration) and drawn up to a standard at least equivalent to the guidelines developed by the IMO.

  • The provision of a Cargo Securing Manual (CSM) onboard the vessel is mandatory.

  • When producing a ship-specific CSM, shipping companies need to incorporate the guidance and information provided in the CSS Code and any other Code.

  • Any deviation from the CSM would usually require approval from Class and an amendment to the CSM issued.

Code of Safe Practice for Cargo Stowage and Securing (CSS) Code

The CSS Code deals with the safe stowage and securing of cargoes and is best practice, but the relevant sections are usually included in the vessel’s approved CSM.

  • Annex 10 of CSS Code deals with FIBCs, advising that vessels with wide hatches with compartments that are regular in shape and free of obstructions are best suited for stowage.

  • FIBCs should be stowed as close as possible and any void space between FIBCs should be chocked off. Measures should be taken to prevent the FIBCs shifting to the open space in the wings and that chocking off is necessary in all cases to prevent shifting.

  • In the case of a tween deck or lower hold being used for stowage of FIBCs, sufficient gratings or plywood sheets should be placed against the FIBCs and the use of wire lashings to secure the cargo.

International Maritime Dangerous Goods (IMDG) Code

In instances when bagged cargoes are loaded into the holds of bulk carriers, these bagged cargoes are not subject to the International Maritime Solid Bulk Cargo (IMSBC) Code as this Code does not apply to bagged cargoes.

All dangerous goods in packaged form should be packed, loaded, stowed and transported in accordance with the IMDG Code. Chapter 4.1 deals with Use of Packaging, including Intermediate Bulk Containers (IBCs) which includes FIBCs.

Potential Incidents with FIBCs

Torn bags and spillages

When handling bagged cargoes, it is common for at least some of the bags to tear and incidental spillages to occur during loading or discharge. In the case of spillages of bagged chemicals onto the exterior packaging of other consignments in the same hold (which may or may not also be chemicals), this may result in delays, refusal by stevedores to handle externally contaminated packages and/ or rejection of such externally contaminated packages, even where there has not been direct contact or chemical reaction between incompatible chemicals.

Spillages involving environmentally hazardous substances (EHS) may result in fines or discharge being suspended.

Reactions of mixed chemicals in FIBCs within the same hold

We have seen an increase in the number of incidents related to bagged cargoes of different substances that are loaded into bulk carriers.

Potentially more serious incidents involve a reaction between some of these bagged chemicals which can occur due to spillages, tears in the bags, etc. In some cases, these reactions have resulted in fires onboard which destroyed large portions of the cargo within the hold. Following firefighting, the entire contents within the hold may not be salvageable, leading to large claims.

Because of the likelihood of spillages, there are risks associated with loading different FIBCs of chemicals. Extra caution should be taken to check for any potential incompatibilities between the cargoes to be loaded, and this may require an evaluation from a chemist. Checks should be undertaken to check the package integrity to minimise the likelihood of a spillage or tearing of the FIBCs. It is also important to ensure that the correct FIBC is used for the chemical.

Summary

All cargo is to be loaded, stowed and secured in accordance with IMO regulations, including SOLAS, the CSM, the CSS Code and the IMDG Code.

Irrespective of Charterers’ instructions to load cargo, the Master is obliged to ensure the safety of the vessel, crew and cargo. If the intended load may jeopardise the safety of the vessel, then under Chapter V, Regulation 34-1 of SOLAS, the Master has the authority to take any action deemed necessary to ensure the safety of the vessel.