Policy & Compliance
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other than solid and liquid bulk cargoes. One challenge in this context is that bulk carriers will not generally be designed with the required lashing points and gear to secure containers, so potentially significant changes are likely to be required on board, requiring Class or flag state approval. Risk assessment Shippers should also assess risks associated with shipping more specialised cargoes, including those containers requiring power (reefer units) and those carrying dangerous goods. While the IMDG Code would continue to apply whether the cargo is shipped on board a fully cellular containership or a bulk carrier, provisions available on board a bulk carrier to fight a containerised fire, for example, may require further attention. While a bulk carrier will be provided with a ‘Document of Compliance’ by the flag state, which will detail the ‘bulk’ cargoes that may be loaded and those that may not be
loaded, seeking clarity on the carriage of packaged dangerous goods on a bulk carrier would be a prudent step. Shipping sensitive and high value cargoes in this way should also be given greater consideration. The atmosphere in the hold of a bulk carrier is likely to be different to that of a fully cellular containership; the construction of the ship and ventilation provisions could give rise to increased ambient temperatures, resulting in condensation that may lead to damage of sensitive cargoes. Consideration should also be given as to how any applicable shippers’ instructions are passed to the crew. From a supply chain perspective, it is less likely that the voyage will commence and conclude in a traditional container terminal, which in many cases will either be operating at capacity levels or contract bound, preventing them from servicing ad hoc bulk carriers. While clearly advantageous in the context of seeking to
avoid berth congestion, this may result in the need to position and collect containers from other multipurpose port facilities. Such facilities are less likely to operate purpose-built ship to shore crane equipment. This might lead to containers being loaded by either mobile harbour cranes or the ship’s crane equipment. Loading containers this way will certainly be less efficient in terms of time, but arguably also expose the container and cargo within to greater dynamic forces, increasing the likelihood of damage through the loading and discharge phases. All the matters raised here need to be discussed with your insurance provider, since they materially change the nature of the risk. Further, as chartering interests, it would be prudent to ensure that the owner’s P&I cover has not been prejudiced, seeking confirmation of cover for the specific circumstances from the owner’s P&I club.
November 2021
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