MARCH 9, 2010 CIRCULAR NO. 09/10 TO MEMBERS OF THE ASSOCIATION Dear Member: CARRIAGE OF DIRECT REDUCED IRON (DRI) BY SEA – CHANGES TO THE IMO CODE OF SAFE PRACTICE FOR SOLID BULK CARGO Members will be aware of the general concerns that exist with regard to the carriage of direct reduced iron (DRI) by sea. These concerns have increased significantly since the loss of life arising from the carriage of DRI on board the YTHAN (2004) and the deliberate sinking by the French authorities of the ADAMANDAS (2003) with her cargo and bunkers on board. The explosion and accompanying tragic loss of life on the YTHAN resulted from the interaction between the vessel’s cargo of “HBI Fines” and the fresh water (moisture) contained in the cargo at the time of loading. At the time of the incident the IMO Code of Safe Practice for Solid Bulk Cargo (the Code) categorized two types of DRI, namely hot molded briquettes or hot briquetted iron – subsequently re-designated as DRI (A) – and pellets, lumps etc. – subsequently re-designated as DRI (B). The DRI/HBI fines cargo could not in reality be categorized as either (A) or (B) under the Code and the expert advice was to treat it as the more dangerous and reactive type of DRI (B). Following the above mentioned incidents and their subsequent investigation, the IMO Subcommittee on Dangerous Goods, Solid Cargoes and Containers (DSC) considered amendments to the relevant schedules of the Code as part of a review of the Code. The Marshall Islands, Intercargo and the International Group of P&I Clubs proposed that DRI Fines should be individually classified and designated DRI (C) and both DRI (B) and (C) should be carried under an inert (nitrogen) atmosphere with maximum allowable moisture content of 0.3% in respect of DRI (C). It was recommended by the DSC at its 12th session held in September 2008 that these (and other minor) amendments be adopted by the IMO through the IMO Maritime Safety Committee (MSC). The MSC adopted the recommendations in November 2008 and the Code was renamed the International Maritime Solid Bulk Cargo Code (IMSBC Code). The main changes to the Code in relation to the carriage of DRI (A), (B) and (C) can be summarized as follows: DRI (A), Briquettes, hot-molded - a maximum limit on the moisture content of 1%. - cargo is to comprise essentially whole briquettes. Fines of less than 6.35mm and dust are limited to 5%. - concentration of hydrogen to be measured throughout the voyage. If it exceeds 25% LEL appropriate precautions to be taken. - surface ventilation only shall be conducted as necessary. When mechanical ventilation is used, the fans shall be certified as explosion-proof and shall prevent spark generation. - wire mesh guards shall be fitted over inlet and outlet ventilation openings. DRI (B), Lumps, pellets, cold-molded briquettes - average particle size is limited to 6.35mm to 25mm. Fines of less than 6.35mm and dust are limited to 5% - loading conveyors are to be dry. - prior to loading, an ultrasonic test or another equivalent method with a suitable instrument shall be conducted to ensure weather tightness of the hatch covers and closing arrangements. - moisture content must be less than 0.3% and must be monitored during loading. - any cargo that has already been loaded into a cargo space and which subsequently becomes wetted, or in which reactions have started, shall be discharged without delay. - carriage is only permitted under an inert gas blanket. - the ship shall be provided w