Shipping Regulations For Oilseed Meal Cargoes

The bulk cargo shipping name of oilseed meals in the IMSBC Code is "seed cake". There are five types of "seed cake" currently listed in the IMSBC Code¹:

1. Seed Cake, containing vegetable oil UN 1386 (a) - residue remaining after the oil has been expelled mechanically from oilseeds, containing more than 10% of oil or more than 20% of oil and moisture combined.

This type of seed cake presents the highest risk of self-heating of all types of seed cake cargoes.
It is assigned to the IMDG Code Class 4.2 (spontaneously combustible substances) and classified in the IMSBC Code as Group B cargo (cargo with chemical hazards).
This type of seed cake shall be accepted for loading only if the cargo temperature at the time of loading is not higher than 10ºC over the ambient temperature or 55ºC, whichever is lower.
The vessel carrying this type of seed cake must have on board a Certificate of Fitness for the Carriage of Solid Bulk Cargoes listing this type of seed cake as a permitted cargo and a Certificate of Fitness for the Carriage of Dangerous Goods and must be equipped with systems for injecting inert gas or carbon dioxide (i.e. with a nitrogen or a carbon dioxide generator) in the event that the cargo temperature exceeds 55ºC.

2. Seed Cake, containing vegetable oil UN 1386 (b) - residues remaining after the oil has been extracted by solvent or expelled mechanically from oilseeds, i.e. solvent extractions and expelled seeds, containing not more than 10% of oil and when the amount of moisture is higher than 10%, not more than 20% of oil and moisture combined.

It is assigned to the IMDG Code Class 4.2 (spontaneously combustible substances) and classified in the IMSBC Code as Group B cargo (cargo with chemical hazards).
This type of seed cake shall be accepted for loading only if it is substantially free from flammable solvent and a certificate stating the oil and moisture content is provided to the vessel`s Master by a person recognised by the competent authority of the country of shipment.
The solvent-extracted rape seed meal, rape seed pellets, soya bean meal, cotton seed meal and sunflower seed meal that contain not more than 4% oil and not more than 15% oil and moisture combined will be exempted from the conditions of carriage stipulated by the IMSBC Code for seed cake UN 1386 (b), if the shippers provide prior to loading a certificate issued by a person recognised by the competent authority of the country of shipment stating that the provisions for the exemption from the conditions of carriage for seed cake UN 1386 (b) are met and that the cargo does not need to be carried as "hazardous seed cake".
During the sea carriage, the cargo temperature must be measured regularly at a number of depths in the cargo holds and recorded by the ship`s crew. If the cargo temperature reaches 55ºC and continues to increase, the mechanical ventilation shall be stopped and then carbon dioxide or inert gas shall be introduced in the cargo holds.
The vessel carrying this type of seed cake must have on board a Certificate of Fitness for the Carriage of Solid Bulk Cargoes listing this type of seed cake as a permitted cargo and a Certificate of Fitness for the Carriage of Dangerous Goods and in case of voyages exceeding five days must be equipped with systems for injecting inert gas or carbon dioxide (i.e. with a nitrogen or a carbon dioxide generator) in the event that the cargo temperature exceeds 55ºC.

3. Seed Cake UN 2217 - residue remaining after the oil has been extracted by solvent from oilseeds, with not more than 1.5% oil content and not more than 11% moisture content.

It is assigned to the IMDG Code Class 4.2 (spontaneously combustible substances) and classified in the IMSBC Code as Group B cargo (cargo with chemical hazards).
This type of seed cake shall be accepted for loading only if it is substantially free from flammable solvent and a certificate stating the oil and moisture content is provided to the vessel`s Master by a person recognised by the competent authority of the country of shipment.
The solvent-extracted rape seed meal, rape seed pellets, soya bean meal, cotton seed meal and sunflower seed meal that contain not more than 1.5% oil and not more than 11% moisture are exempted from the conditions of carriage stipulated by the IMSBC Code for seed cake UN 2217, if the shippers provide prior to loading a certificate issued by a person recognised by the competent authority of the country of shipment stating that the provisions for the exemption from the conditions of carriage for seed cake UN 2217 are met and that the cargo does not need to be carried as "hazardous seed cake".
During the sea carriage, the cargo temperature must be measured regularly at a number of depths in the cargo holds and recorded by the ship`s crew. If the cargo temperature reaches 55ºC and continues to increase, the mechanical ventilation shall be stopped and then carbon dioxide or inert gas shall be introduced in the cargo holds.
The vessel carrying this type of seed cake must have on board a Certificate of Fitness for the Carriage of Solid Bulk Cargoes listing this type of seed cake as a permitted cargo and a Certificate of Fitness for the Carriage of Dangerous Goods and in case of voyages exceeding five days must be equipped with systems for injecting carbon dioxide or inert gas (i.e. with a carbon dioxide or nitrogen generator) in the event that the cargo temperature exceeds 55ºC.

4. Seed Cake Cargoes With Self-Heating Risk (Seed Cakes and Other Residues Of Processed Oily Vegetables, i.e. residues remaining after the oil has been mechanically expelled or extracted by solvent or other chemical processes from oilseeds.)

It refers to the seed cake cargoes that do not meet the criteria for classification as dangerous goods in the IMDG Code but present significant self-heating risk when shipped in bulk.
The seed cake cargoes with self-heating risk are classified in the IMSBC Code as MHB (Materials Hazardous Only In Bulk) cargo and Group B Cargo (cargo with chemical hazards).
Solvent-extracted seed cake shall be accepted for loading only if it is substantially free from flammable solvent and the cargo temperature at the time of loading is not higher than 10ºC over the ambient temperature or 55ºC, whichever is lower. During the sea carriage, the cargo temperature must be measured regularly at a number of depths in the cargo holds and recorded by the ship`s crew. If the cargo temperature reaches 55ºC and continues to increase, the mechanical ventilation shall be stopped and then carbon dioxide or inert gas shall be introduced in the cargo holds.

5. Non-Hazardous Seed Cake (Seed Cakes and Other Residues Of Processed Oily Vegetables, i.e. residues remaining after the oil has been mechanically expelled or extracted by solvent or other chemical processes from oilseeds.)

It refers to the non-hazardous seed cake cargoes that do not meet the criteria for classification as dangerous goods in the IMDG Code nor present self-heating risk when shipped in bulk. The solvent extracted or mechanically expelled meals exempted from Seed Cake UN 1386 (b) or Seed Cake UN 2217 and any other oilseed meals that do not present a hazard during the carriage can be declared as non-hazardous seed cake cargoes.
The shippers must provide prior to loading a certificate issued by a person recognised by the competent authority of the country of shipment stating that the requirements for exemption from the conditions of carriage for seed cake UN 1386 (b) or UN 2217, whichever is applicable, are met and that the cargo does not present self-heating risk when shipped in bulk.
The non-hazardous seed cake is classified in the IMSBC Code as Group C cargo.

The shippers of oilseed meals in bulk must give the vessel`s Master before loading a cargo declaration in which to provide all the relevant cargo information to allow the Master to prepare the vessel for loading and safe carriage. In the cargo declaration the shippers must provide the bulk cargo shipping name, state whether the cargo is classified as dangerous goods or MHB or whether is  non-hazardous seed cake, state Group of the cargo, UN Number, cargo quantity, moisture content, stowage factor, trimming requirements and self-heating properties of the cargo.
Provided the oilseed meal cargo is properly declared, the shippers shall not be held liable in case of incidents occurring during or after loading or during the sea carriage or discharge, because the English Courts consider that in such case the carrier accepted the risks known to be associated with such cargo<sup>2</sup>. If however, the vessel is damaged due to cargo`s hazardous characteristics unknown to the vessel`s Master at the time of shipment which the shippers should have known, the shippers will have to indemnify the carrier.

by Vlad Cioarec, International Trade Consultant

This article has been published in Commoditylaw`s Grain Trade Review Edition No. 5.

Endnotes:

1. See 2019 Edition of the IMSBC Code adopted by the IMO Maritime Safety Committee on 13 June 2019 by Resolution MSC.462(101), IMO document MSC 101/24/Add.3 at IMODOCS.
2. See The "Athanasia Comninos", [1990] 1 Lloyd`s Rep. 277