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IMO Guidelines: International Maritime Organisation MARPOL Annex V and IMSBC Code Developments

Adopted in 2012, the new IMO guidelines cover the development of more systematic hazard assessments for solid bulk cargoes. The two relevant regulations that suppliers/shippers of solid bulk materials need to comply with are, firstly, MARPOL Annex V, designed to prevent pollution of the marine environment, and secondly, the International Maritime Solid Bulk Cargoes Code (IMSBC), set up to ensure the safe transport of solid bulk cargoes. 

The consequences of this work are that, firstly, residues of cargoes meeting certain criteria can no longer be discharged into the sea from 1st January 2013*. Dry residues and/or wash water have to be discharged at “adequate port reception facilities”. Secondly, if no such ballast water management facilities are available, the shipmaster can refuse to ship the cargo. 

Shippers have to declare whether or not their cargoes are “Harmful to the Marine Environment (HME). Such declarations have to be included in the shipping documents and the competent authority, of both the port state of loading and unloading, have to be notified.

In December 2012, ECI completed a Phase I project to help the global copper industry (producers, traders and customers) meet these obligations. Specifically, the project [click for details] assessed how to appropriately classify bulk cargoes, such as copper concentrates and copper granules, and how to then identify which need to be classified as “HME” under MARPOL Annex V from 1st January 2013 onwards.

A 2-page IMO guidance note on provisional classifications is available

*On May 16th 2013, the IMO’s Marine Environment Protection Committee agreed that, until 31st December 2015, cargo hold wash water, from holds previously containing solid bulk cargoes classified as HME, may be discharged outside special areas, providing:

  • the master determines that there are no adequate reception facilities either at the receiving terminal or at the next port of call;
  • the ship is en route and as far as practicable from the nearest land, but not less than 12 nautical miles;
  • before washing, solid bulk cargo residue is removed (and bagged for discharge ashore) as far as practicable and holds are swept;
  • filters are used in the bilge wells to collect any remaining solid particles and minimize solid residue discharge; and
  • the discharge is recorded in the Garbage Record Book and the flag State is notified utilizing the Revised Consolidated Format for Reporting Alleged Inadequacies of Port Reception Facilities (MEPC.1/Circ.469/Rev.2). 


Click here for the 2-page IMO communiqué on this compliance extension.


ECI is now managing a Phase II project to support the industry in meeting its obligations under the IMSBC requirements regarding Materials Hazardous in Bulk (MHB). These impose additional requirements on the reporting, by shippers, of physico-chemical hazards and the human health hazards for workers during the loading, shipping and unloading of materials classified as MHB. Such a classification will increase the required level of risk management measures to ensure maritime safety.  

How to Join the Global Copper Industry 'Business Venture' for IMO-GHS

Information on how non-members of the Copper Alliance can participate in this activity is available here: 

Copper Concentrates Transported in Bulk

Application to the assessment of substances “Harmful to the Marine Environment” (HME) as set out under the 2012 Annex V MARPOL Convention amendments.

Copper Granules Transported in Bulk

Application to the assessment of substances “Harmful to the Marine Environment” (HME) as set out under the 2012 Annex V MARPOL Convention amendments.
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