The Shipping Regulations For Copper Concentrates
Copper Concentrate is listed in the IMSBC Code under four schedules:
1. Metal Sulphide Concentrates;
2. Metal Sulphide Concentrates, Corrosive UN 1759;
3. Metal Sulphide Concentrates, Self-Heating UN 3190;
4. Mineral Concentrates.
1. Metal Sulphide Concentrates
The term "Metal Sulphide Concentrates" is a general description of worldwide application for metal concentrates such as copper concentrates, zinc concentrates and lead concentrates.
These cargoes are categorised as Group A cargoes according to the criteria of the IMSBC Code because it may liquefy if shipped with a moisture content in excess of the transportable moisture limit.
These cargoes possess chemical hazards that meet the criteria for classification as Group B cargoes and as MHB (SH), MHB (TX) and MHB (CR).
MHB (SH) – Materials Hazardous Only In Bulk, Self-Heating Solids – refer to cargoes that self-heat when transported in bulk and do not meet the criteria of the IMDG Code for inclusion in Hazard Class 4.2 (Substances liable to spontaneous combustion).
MHB (TX) – Materials Hazardous Only In Bulk, Toxic Solids – refer to cargoes that have toxic hazards to humans if inhaled when loaded, transported in bulk or unloaded and do not meet the criteria of the IMDG Code for inclusion in Hazard Class 6.1 (Toxic substances).
MHB (CR) – Materials Hazardous Only In Bulk, Corrosive Solids – refer to cargoes that are corrosive to metal and do not meet the criteria of the IMDG Code for inclusion in Class 8 (Corrosive substances).
2. Metal Sulphide Concentrates, Corrosive UN 1759
This schedule was included in the IMSBC Code in 20161 following a proposal submitted by the Australian delegation to IMO in 20142 relating to a copper concentrate shipped from Australia (Mount Garnet Copper Concentrate). The test results for the respective copper concentrate showed that it could liquefy if the moisture content exceeds the TML of 9.1% so that it can be categorised as Group A cargo3 and that it possesses chemical hazards that meet the criteria for classification as Group B cargo, according to the criteria of the IMSBC Code, as dangerous goods in Hazard Class 8 (Corrosive substances), according to the criteria of the IMDG Code and as Materials Hazardous Only In Bulk, Self-heating solids and Solids that evolve toxic gas when wet, according to the criteria of the IMSBC Code.
The chemical hazards of Mount Garnet Copper Concentrate are:
(a) the corrosion risk (Class 8 in the IMDG Code). The moisture content of Mount Garnet Copper Concentrate forms sulphurous acid which is corrosive to the ship`s steel structure so that the cargo holds should have adequate coating. After discharge of the cargo, the cargo residues must be washed away from the ship`s holds.
(b) the self-heating risk (MHB(SH)). Mount Garnet Copper Concentrate does not meet the criteria for inclusion in Hazard Class 4.2 from the IMDG Code but presents a self-heating risk when shipped in bulk so that the carrying ship must be fitted with a fixed gas fire extinguishing system.
(c) the generation of toxic gases (MHB (WT)). Mount Garnet Copper Concentrate is extracted from copper ore with the use of flotation reagents. The residues of flotation reagents remain attached to the copper concentrate until it is loaded in the ship`s holds for sea carriage. During the sea carriage, the copper concentrate will oxidize consuming the oxygen in the cargo holds. Concurrently with the cargo oxidation, the toxic gases generated by the residues of the flotation reagents will accumulate in the cargo holds4 so that the carrying ship must be fitted with gas detectors.
The gas concentrations must be measured regularly during the voyage by the ship`s crew and the results of the measurements must be recorded and kept on board.
The ship carrying this type of copper concentrate must have on board a Certificate of Fitness for the Carriage of Solid Bulk Cargoes and a Certificate of Fitness for the Carriage of Dangerous Goods listing "Metal Sulphide Concentrates, Corrosive UN 1759" as a permitted cargo and a Cargo Manifest and a Stowage Plan setting forth the location of copper concentrate on board.
3. Metal Sulphide Concentrates, Self-Heating UN 3190
This schedule was included in the IMSBC Code following a proposal submitted by the Australian delegation to IMO in 20175 relating to a copper concentrate shipped from Australia (Boddington Copper Concentrate). The test results for the respective copper concentrate showed that it could liquefy if the moisture content exceeds the TML range of 9.5% to 10.5%6 so that it can be categorised as Group A cargo according to the criteria of the IMSBC Code and that it possesses chemical hazards that meet the criteria for classification as Group B cargo according to the criteria of the IMSBC Code, as dangerous goods in Hazard Class 4.2 (Substances liable to spontaneous combustion) according to the criteria of the IMDG Code and as Materials Hazardous Only In Bulk, Solids that evolve toxic gas when wet (MHB(WT)), Toxic Solids (MHB(TX)) and Corrosive Solids (MHB(CR)) according to the criteria of the IMSBC Code.
The chemical hazards of Boddington Copper Concentrate are:
(a) the self-heating risk (MHB(SH)). Boddington Copper Concentrate meets the criteria for inclusion in Hazard Class 4.2 (Substances liable to spontaneous combustion and self-heating, UN 3190). The cargo shall be accepted for loading only if the cargo temperature does not exceed 55ºC. The cargo temperature shall be measured during loading and sea carriage and the cargo holds shall not be ventilated during the carriage.
(b) the generation of toxic gases (MHB (WT) and (TX)). During the sea carriage, Boddington Copper Concentrate will oxidize consuming the oxygen in the cargo holds. Concurrently with the cargo oxidation, the toxic gases generated by the residues of the flotation reagents will accumulate in the cargo holds7 so that the carrying ship must be fitted with gas detectors.
The gas concentrations must be measured regularly during the voyage by the ship`s crew and the results of the measurements must be recorded and kept on board.
The ship carrying this type of copper concentrate must have on board a Certificate of Fitness for the Carriage of Solid Bulk Cargoes and a Certificate of Fitness for the Carriage of Dangerous Goods listing "Metal Sulphide Concentrates, Self-Heating UN 3190" as a permitted cargo and a Cargo Manifest and a Stowage Plan setting forth the location of copper concentrate on board.
(c) the corrosion risk (MHB(CR)).
4. Mineral Concentrates
Copper concentrates described as "Mineral Concentrates" are categorised as Group A cargoes according to the criteria of the IMSBC Code. It may liquefy if shipped with a moisture content in excess of the transportable moisture limit.
Section 4.3.2. of the IMSBC Code stipulates that:
"When a concentrate or other cargo which may liquefy is carried, the shipper shall provide the ship`s master or his representative with a signed certificate of the TML, and a signed certificate or declaration of the moisture content, each issued by an entity recognized by the competent authority of the port of loading. The certificate of TML shall contain, or be accompanied by, the result of the test for determining the TML. The declaration of moisture content shall contain, or be accompanied by, a statement by the shipper that the moisture content is, to the best of his knowledge and belief, the average moisture content of the cargo at the time the declaration is presented to the master."
Copper concentrates described as "Mineral Concentrates" are non-combustible cargoes or cargoes with low fire risks. These copper concentrates are neither categorised as Group B cargoes nor classified as MHB.
by Vlad Cioarec, International Trade Consultant
This article has been published in Commoditylaw`s Metals & Minerals Legal Brief Edition No. 1.
Endnotes:
1. See IMO Cicular Letter No. 3678/26 September 2016
2. See IMO document CCC 1/5/11/4 July 2014 and IMO document CCC 2/5/9/12 June 2015
3. See IMO document CCC 1/INF. 15/4 July 2014
4. See IMO document DSC 17/INF.8/13 July 2012
5. See IMO document CCC 4/5/2/30 June 2017
6. See IMO document CCC 4/INF.5
7. See IMO document DSC 17/INF.8/13 July 2012