MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert – September 3 , 202 6 1 SEPTEMBER 3, 2026 INDIA: LOADING OF INTERNATIONAL MARITIME SOLID BULK CARGOES (IMSBC) CODE GROUP A CARGOES Following the very recent loss of the Panama-flagged bulk carrier OCEAN WINNER, the Principal Officer, Mercantile Marine Division (MMD) Kolkata has, with immediate effect, imposed additional controls on the loading and sailing of vessels carrying iron ore fines, sand and other Group A (prone to liquefaction) cargoes as designated by the IMSBC Code from ports under Kolkata Port jurisdiction, this would include Kolkata, Haldia, Budge Budge, Diamond Harbour, Paradip, Dhamra, Gopalpur and Port Blair. Vessels loading and due to load such cargoes at these ports — Paradip in particular — should anticipate additional permissions, port-conducted risk assessments, mandatory multi-stage surveyor attendance. Detailed procedures are stated to be under preparation and the position is evolving. The controls invoke the existing framework under Merchant Shipping (MS) Notice 9 of 2010 (safe loading, stowage and carriage of iron ore fines in fair and foul season), read with the shipper’s declaration requirement the authority attributes to MS Notice 2 of 2017. Para 5(iv) of MS Notice 9 of 2010 sets out port/terminal responsibilities, including covering of stockpiles liable to be affected by monsoon precipitation. Revised requirements as presently notified as communicated by the Principal Officer (PO), MMD Kolkata: (a) Explicit prior loading permission — permission must be obtained from the PO, MMD Kolkata before commencement of loading of the subject cargoes; (b) Explicit departure/sailing permission — separate permission from the PO must be obtained prior to departure; (c) Port risk assessment — a risk assessment is to be carried out by the port and submitted to the PO for any liquefiable cargo, addressing at least expected rainfall, jetty condition (open or closed) and cargo storage arrangements; (d) Shipper’s declaration — to be submitted as per MS Notice 2 of 2017; (e) Mandatory surveyor attendance at each stage — surveyor attendance now operates as a gate on the loading operation itself: an MMD surveyor must attend and clear each stage, and loading may not commence, resume after any stoppage, or be treated as complete in the surveyor’s absence. The survey covers: MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert – September 3 , 202 6 2 (i) the storage location prior to loading, with the arrangement for covering the cargo in the shortest time in the event of rain to be demonstrated; (ii) any rain stoppage — loading is to halt, the surveyor informed and the cargo covered, with the surveyor’s go-ahead required before loading resumes; (iii) continued transportable moisture limit (TML) testing on board; and (iv) a further attendance on completion of loading; and (f) Declaration of the full path (chain of custody) of the cargo — the Owners/Agents/Shippers are to submit a document detailing the full path of the Group A cargo up to sailing of the vessel: where the cargo is stored, how it is transported, when sampling is carried out and by whom, how and where testing is