The American P&I Club has raised concerns that have arisen regarding the loading of finished and unfinished steel products alongside break-bulk, containerized, and project cargoes in the same cargo hold of bulk carriers.
Examples of break-bulk, containerized, and project cargoes include large, heavy, oversized items, machinery parts, crates, and heavy-duty wheeled items such as trucks, cranes, or pay loaders. Unlike vessels dedicated to carrying break-bulk, containerized, or project cargoes, bulk carriers are not fitted with suitable lashing and securing arrangements.
The irregular sizes, shapes, and weights of such non-pure-bulk cargoes are challenging to safely lash and secure, and typically require makeshift arrangements. Furthermore, such arrangements are challenging for the crew to supervise for safety when a vessel is at sea.
Wheeled cargoes pose a particular risk due to their higher propensity to shift. The stowage and securing of wheeled cargoes are addressed specifically in Annex 4 of the Cargo Stowage and Securing (CSS) Code.
Similarly, break-bulk or project cargoes are often stowed atop steel cargoes. While specified finished and semi-finished steel cargoes are subject to a pre-load survey, as stipulated in the August 19, 2024, Club Circular No. 16/24, Steel Cargo Pre-Load Surveys, operators should also consider employing experienced surveyors familiar with the stowage and securing of break-bulk, containerized, and project cargoes intermixed with or over stowed on top of other cargoes, given the related risk of damage caused by excessive weight or improper securing of such non-pure-bulk cargoes.
The cost of utilizing an experienced surveyor outweighs the potential losses to the cargo, vessel, or injuries to the crew that may arise from a lack of expert assistance during loading.
The essential steps that should be in hand and approved prior to loading cargo are as follows:
– The vessel’s stowage plan should be made available well in advance of loading.
– Upon receipt of the stowage plan, the Master should input the relevant data into the loadicator to ensure the vessel’s shear force bending moment (SFBM) and stability are within the applicable limits.
– It should be clear how the cargo is to be secured as per the Cargo Securing Manual (CSM), and that relevant stowage and lashing materials and equipment are available aboard the vessel in compliance with the CSS Code.
Some important points regarding stowing, improper stowage, and improper securing of heavy cargoes, containers, and project cargoes include:
– Vehicles and heavy project/break-bulk cargo stowed on top of other cargo may not provide a firm surface for the over-stowed cargo.
– Cargo stowed atop other cargoes may damage or deform the cargoes below due to their weight.
– Vehicles or heavy cargo should be provided with securing/lashing points to assist in securing these cargoes. These securing points are usually marked by the manufacturer.
– Vehicles should not be secured to each other but should be secured independently to strong lashing points on the vessel’s structure.
– Dunnage should be placed under break-bulk/project cargo to provide even surfaces and distribute weight so that the maximum load on tank tops is not exceeded.
– Lashings should be able to be tightened by the crew during the voyage as cargo settles. The use of turnbuckles is recommended.
– An understanding that bulk carriers are not specifically designed to carry cellularized cargoes. In considering the carriage of containers in any number or for any duration, it is important to consider the many factors associated with such carriage, as specified in the October 4, 2021, Club Alert, The Carriage of Containers on Noncellular Vessels.
– Attention should be given to the September 30, 2024, Club Circular No. 20/24, Project Cargoes, which recommends that marine warranty surveyors be employed for large, heavy-duty, and high-value project cargoes.
Shipowners have the responsibility to ensure that the vessel is suitable and fit for purpose to carry break-bulk cargo, containers, and project cargoes with due regard to statutory regulations and classification society standards. The flag State-approved CSM should be on board the vessel as it provides the approved lashing and securing arrangements, in addition to detailing the lashing devices available on board. However, the lashing material for break-bulk cargo, containers, and project cargoes is usually provided by the charterers.
If specified cargoes are not allowed to be loaded as per the vessel’s CSM, the owners should notify the charterers and consult their classification society and/or flag State for further guidance. The Master ultimately has the responsibility to ensure that the cargo is safely handled, stowed, and secured as per applicable regulations. Therefore, the Master is obliged to:
– Decline to load specific cargo that does not comply with regulations. For example, loading vehicles with fuel in fuel tanks if the vessel is not equipped with a fire extinguishing system for cargo holds is not acceptable practice.
– Ensure that the cargo stowage will not result in damage to the vessel during the voyage if there is evidence of improper securing (e.g., wires passing through sharp objects liable to part due to the rigors of sea passage), that the vessel maintains the SFBM and stability within prescribed limits, or that the load density of the cargo tank top has been exceeded.
– Take advantage of any charter party provisions or clauses that may be to the master’s and/or owner’s advantage.
