The London P&I Club is the trading name of The London Steam-Ship Owners' Mutual Insurance Association Limited and its subsidiary The London P&I Insurance Company (Europe) Limited. The London Steam-Ship Owners' Mutual Insurance Association Limited. Registered in England No 10341. Registered Office: 50 Leman Street, London, E1 8HQ. The London P&I Insurance Company (Europe) Limited, a private limited liability company registered in Cyprus, No HE410091. Registered Office: Esperidon 5, 4th Floor, Strovolos, 2001, Nicosia. 24 April 2025 TO ALL MEMBERS AND ASSUREDS Dear Sir or Madam Direct Reduced Iron (D) – by-product fines with a moisture content of ≥2% Introduction Direct reduced iron (DRI) in various forms is described in the International Maritime Sold Bulk Cargo (IMSBC) Code, (hereinafter, the Code). The latest addition, which became mandatory part of the Code from January 2025, is the entry for the Type D, by-product fines with a moisture content of at least 2%. This entry runs over multiple pages and contains large amount of important information and guidance. In this Circular, the main points of the Type D entry are summarised, and, where appropriate, additional guidance and observational notes have been added. This Circular has been prepared for the International Group of P&I Clubs (IG) in conjunction with Dr J H Burgoyne & Partners LLP (Burgoynes) with input from INTERCARGO. Explanatory notes provided by Burgoynes are included in blue text within the body of this Circular. It should be noted that this Circular is for guidance only and the relevant entries from the IMSBC Code, which are appended to this Circular, remain the primary source of carriage requirements which should be relied upon. Background Direct reduced iron (DRI) is formed by passing hot reducing gases, such as hydrogen, methane and carbon monoxide, over iron ore, which is usually in the form of lumps or pellets. This produces a highly porous iron material which has a very large internal surface area available for re-oxidation. The principal hazards associated with DRI are its ability to undergo selfheating through oxidation and its ability to generate hydrogen from reaction with water/moisture. When stowed within the confines of a cargo hold, hydrogen produced by reaction with water can form an explosive atmosphere inside the hold, presenting a risk of explosion. The principal forms of DRI are Type A (hot-moulded briquettes) and Type B (pellets), but fines are also generated during manufacture and handling (via abrasion) and from filtering particles out of off-gases. Fines are not generally suitable for inclusion with Types A and B, so these are screened out and handled separately. Formerly, fines would be shipped under DRI Type C, but the IMSBC Code entry for this type defines the moisture level of the cargo as not exceeding 0.3%. That low moisture level is often - 2 not feasible due to handling practices for fines, such as outdoor storage and handling being subject to rain. In addition, the Code calls for DRI (C) cargoes to be shipped under inert gas, as for DRI (B). Inert gas is intended to exclude air (oxygen), thus limiting self-heating due to reaction with oxygen. However, as set out below, self-heating is typically not the main issue with fines. Instead, the prevalent risk is the generation of flammable hydrogen gas due to reaction with water, leading to a scenario where the holds need to be ventilated in order to maintain low hydrogen concentrations, below the