Consultation outcome

ANNEX D - DRAFT MGN - The Merchant Shipping (Carriage of Cargoes) Regulations 2024

Updated 15 April 2024

Summary

This Marine Guidance Note (MGN) draws attention to the Merchant Shipping (Carriage of Cargoes) Regulations 2024 (“the 2024 Regulations”) which revoke and replace the Merchant Shipping (Carriage of Cargoes) Regulations 1999.

The 2024 Regulations implement Chapter VI of the Annex to the International Convention for the Safety of Life at Sea, 1974 (“SOLAS”). The United Kingdom is a signatory to SOLAS which is the main international treaty concerning the safety of merchant ships engaged on international voyages. SOLAS Chapter VI sets out requirements for the carriage of cargoes (except liquids and gases in bulk). Various International Maritime Organization (“IMO”) codes, certifying documents and auditable processes flow out of this chapter including:

• The International Maritime Solid Bulk Cargoes (IMSBC) Code

• Cargo Securing Manuals^{[footnote 1]}

• Verification of the gross mass of packed containers (VGM)^{[footnote 2]}

• Precautions for the use of pesticides in ships^{[footnote 3]}

1. Introduction

1.1 SOLAS is an important international treaty concerning the safety of merchant ships engaged on international voyages. The main objective of SOLAS is to specify minimum standards for the construction, equipment and operation of ships, compatible with their safety.

1.2 The 2024 Regulations largely retain the regulatory provisions for implementing SOLAS Chapter VI requirements for the carriage of cargoes which have been in force since 1999.  However, there are some differences between the Merchant Shipping (Carriage of Cargoes) Regulations 1999 and the 2024 Regulations which have replaced them. These differences are:

• The format of the 2024 Regulations is more succinct than that in their predecessor. Rather than expressly replicating the requirements in SOLAS and relevant mandatory codes, the 2024 Regulations point directly to the relevant requirements of SOLAS Chapter VI and the associated mandatory codes.
• The 2024 Regulations include ambulatory reference (AR) provision which is intended to ensure that amendments to international safety standards can be efficiently implemented in the UK and to ensure that a gap does not develop between UK regulations and accepted international standards.
• The 2024 Regulations make provision for the full implementation of the IMSBC Code in the UK which, until this point, has been in part implemented through the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 and in part through non-mandatory Marine Guidance Notes.
• The 2024 Regulations implement the prohibition on the at-sea blending of bulk liquid cargoes as set out in Regulation 5-2 of SOLAS Chapter VI.
• The requirement in Regulation 5-1 of SOLAS Chapter VI for the provision of a material safety data sheet for oil or oil fuel as defined in Annex I of the International Convention for the Prevention of Pollution from Ships, 1973 (“MARPOL”) was previously implemented in the UK through the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 and this provision can now be found in the Merchant Shipping (Carriage of Cargoes) Regulations 2024 although the provision itself remains unchanged.

2. The Regulations

2.1 The Merchant Shipping (Carriage of Cargoes) Regulations 2024 entered into force on XX XXXX 2024, revoking and replacing the Merchant Shipping (Carriage of Cargoes) Regulations 1999.

2.2 The 2024 Regulations incorporate and implement all recent amendments to SOLAS Chapter VI and include provisions to ensure that UK keeps in step with international maritime safety standards.

3. Application

3.1 The 2024 Regulations apply to the carriage of cargoes in general by UK ships wherever they may be and by non-UK ships whilst in UK waters. The 2024 Regulations mirror the provisions of SOLAS Chapter VI and do not include aspects covered by other SOLAS chapters. As the requirements for the carriage of bulk liquid and gas cargoes are covered generally by SOLAS Chapter VII, the 2024 Regulations do not apply to the carriage of bulk liquid and gas cargoes save for the specific provisions in SOLAS Chapter VI on material safety data sheets and blending of bulk liquid cargoes, details of which are included in Annex A to this MGN. Since SOLAS Chapter VII covers the special provisions for dangerous goods thereby limiting the application of Chapter VI to aspects not covered in Chapter VII, application of the 2024 Regulations to dangerous goods is similarly limited to aspects not covered in the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997^{[footnote 4]}.

3.2 Since the SOLAS Convention concerns the safety of merchant ships, the 2024 Regulations also reflect the general application provisions of SOLAS in that there are certain ship types to which the 2024 Regulations do not apply. These ship types include warships, pleasure vessels and fishing vessels, though this should reflect the actual use and employment of the vessel and not simply its original designation.

3.3 In keeping with the application provisions of SOLAS Chapter VI and the customary legal mechanisms within UK Merchant Shipping legislation, the 2024 Regulations make provision for exemptions and equivalences. Further details can be found in Annex A of this MGN, including how to make an application to the Maritime and Coastguard Agency (“MCA”) for an exemption or equivalence. A general exemption for certain cargo ships is also included in Annex D to this MGN.

3.4 Where SOLAS Chapter VI makes reference to cargoes which, owing to their particular hazards to ships or persons on board, may require special precautions, it must be borne in mind that whilst the characteristics of some cargoes, such as flammability, toxicity or propensity to shift in bulk, present clear hazards, even otherwise benign cargoes requiring no special considerations prior to loading may pose a hazard to the ship or personnel once on board. In setting out requirements for the carriage of cargoes, SOLAS Chapter VI makes clear that all aspects of the proper handling of any cargo, such as the provision of cargo information, the provision of the verified gross mass of cargo transport units, proper stowage, trimming and securing, the provision and use of a Cargo Securing Manual etc. are important components in the safe carriage of any cargo and, where any aspect of the proper handling of that cargo falls down, a potential hazard to the ship or personnel may arise. As such, whereas SOLAS is principally a maritime convention applied to vessels and their operators, SOLAS Chapter VI also makes provision in relation other parties who are ashore and beyond the ship’s rail, such as shippers and terminal representatives. The 2024 Regulations similarly make specific provision for these parties in relation to the carriage of cargoes.

3.5 Requirements from SOLAS Chapter VI and advice on compliance are set out in Annex A to this MGN. Additional information on the UK’s implementation of the Code of Practice for Safe Loading and Unloading of Bulk Carriers (BLU Code) is included in Annex B to this MGN. Further guidance on the structure and layout of a cargo securing manual is included in Annex C to this MGN. A general exemption for cargo ships of less than 500gt is set out in Annex D to this MGN.

More information

Cargoes, Safety and Pollution Prevention Team
Maritime and Coastguard Agency
Bay 2/23
Spring Place
105 Commercial Road
Southampton
SO15 1EG

Telephone: +44 (0)203 81 72000

Email: Cargoes@mcga.gov.uk

Website: www.gov.uk/mca

Please note that all addresses and telephone numbers are correct at time of publishing.

ANNEX A

Requirements from SOLAS Chapter VI

1. Cargo information

1.1 SOLAS Chapter VI, regulation 2 sets out a fundamental requirement in the carriage of cargoes, namely that a shipper or forwarder must provide the master or their representative with appropriate information sufficiently in advance of loading to enable a proper assessment of the suitability of the cargo for the ship on its intended voyage including stowage and segregation considerations.

1.2 The Merchant Shipping (Carriage of Cargoes) Regulations 2024 and the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulation 1997, taken together, regulate the minimum information and documentation which must be provided by shippers and freight forwarders.

1.3 The International Maritime Organization (IMO) has published generic model forms to assist shippers in the presentation of cargo information, such as the form for Cargo Information for Solid Bulk Cargoes found in section 4.2.3 of the IMSBC Code (the information is mandatory under the code, but the form set out in the template is recommendatory). Stakeholders should be aware, however, that a cargo information form is not suitable for packaged dangerous goods requiring a dangerous goods declaration in accordance with SOLAS Chapter VII. An example of a multimodal dangerous goods form can be found in The International Maritime Dangerous Goods (IMDG) Code at section 5.4.5 and a template can also be found on www.gov.uk. 

1.4 As an aid to digitization of shipping documentation, SOLAS Chapter VI also provides that Electronic Data Processing (EDP) or Electronic Data Interchange (EDI) methods may be used by shippers for providing the cargo information.

2. Verified Gross Mass (VGM)

2.1 SOLAS Chapter VI, regulation 2 requires that the gross mass of cargo (contents) carried in units, including tare weight of the container, is verified.

2.2 Marine Guidance Note, MGN 534, gives detailed advice on how UK shippers, port and terminal operators, and carriers can meet their VGM responsibilities.

3. Stowage and Securing - Cargo Securing Manual

3.1 SOLAS Chapter VI, regulation 5 requires that all cargoes, cargo units and cargo transport units are loaded, stowed and secured throughout the voyage in accordance with the ship’s Cargo Securing Manual which must be approved by the Administration. Approval of the Cargo Securing Manual for UK ships is carried out by the Maritime and Coastguard Agency (MCA) for unclassed vessels and, where they are the Classification Society, the UK Recognised Organisations are authorised by the MCA to undertake this approval for classed vessels. Details on the UK Recognised Organisations can be found on the MCA’s website.^{[footnote 5]}

3.2 When approval by the MCA is required, a ship operator should submit the ship’s Cargo Securing Manual to the Marine Office responsible for the survey of a new building or nearest to the port from which the ship operates. Fees are chargeable for approval based on the published hourly rate.^{[footnote 6]}

3.3 Annex C to this MGN contains further guidance including advice for stakeholders on the structure and layout of a Cargo Securing Manual and indicates some acceptable alternatives and modifications. Annex D to this MGN contains a general exemption for cargo ships below 500GT not engaged on international voyages from the requirements for a Cargo Securing Manual specified in SOLAS Chapter VI, regulation 5.6. This exemption does not extend to any other stowage and securing requirements specified in SOLAS Chapter VI, regulation 5, nor does it extend to the requirements for a Cargo Securing Manual specified in other SOLAS chapters and safety regulations such as those concerning the carriage of dangerous goods. 

4. Solid Bulk Cargoes - Stability information and Cargo loading manual

4.1 SOLAS Chapter VI, regulation 6 requires the owner to ensure that the master is provided with comprehensive information on ship’s stability and cargo distribution prior to loading a solid bulk cargo. Furthermore, reflecting the provision in SOLAS Chapter VI, regulation 7.2, it is the duty of the owner to ensure that the ship is provided with a cargo loading manual, written in a language with which the ship’s officers responsible for cargo operations are familiar. If that language is not English, the ship must also be provided with a manual written in the English language. The manual may consist of one or more booklets and should, as a minimum, include:

a) stability data, to the extent required by SOLAS Chapter II-1 regulation 5-1 ‘Stability Information to be Supplied to the Master’ (see regulation 32 of the Merchant Shipping (Load Line) Regulations 1998).

b) ballasting and deballasting rates and capacities;

c) maximum allowable load per unit surface area of the tank top plating;

d) maximum allowable load per hold;

e) general loading and unloading instructions with regard to the strength of the ship’s structure including any limitations on the most adverse operating conditions during loading, unloading, ballasting operations and the voyage;

f) any special restrictions such as limitations on the most adverse operating conditions imposed by the Administration or organization recognised by it, if applicable; and

g) where strength calculations are required, maximum permissible forces and moments on the ship’s hull during loading, unloading and the voyage.

4.2 Approval of vessel stability information is undertaken by the Maritime and Coastguard Agency’s stability unit. Guidance for owners and naval architects on how and where to submit ship stability information for MCA authorisation can be found on www.gov.uk.

5. Solid Bulk Cargoes - International Maritime Solid Bulk Cargoes (IMSBC) Code

5.1 SOLAS Chapter VI, regulation 1-2 requires that the carriage of solid bulk cargoes other than grain must comply with the relevant provisions of the International Maritime Solid Bulk Cargoes Code (“the IMSBC Code”). The IMSBC Code became mandatory on an international basis and replaced the previous Code of Safe Practice for Solid Bulk Cargoes (“BC Code”) when it entered into force on 1 January 2011.

5.2 The IMSBC Code is reviewed and updated biennially through the International Maritime Organization (“IMO”). Amendments are adopted by means of Maritime Safety Committee (“MSC”) Resolutions which set out both the textual changes and associated dates. In the case of IMSBC Code amendments, the MSC Resolutions customarily state that they may be applied by Governments on a voluntary basis from 12 months before the entry into force date. Accordingly, the MCA supports the voluntary early uptake of amendments to the IMSBC Code by industry, especially when considering the wider practicalities of training and familiarisation with the latest published editions of the Code.

5.3 Since 2011, the MCA has issued various Merchant Shipping Notices to advise and guide stakeholders of pertinent changes to the IMSBC Code and will continue to do so as required from time to time. Stakeholders should familiarise themselves with these documents as appropriate.

5.4 Solid bulk cargoes should only be shipped in accordance with the IMSBC Code and only those solid bulk cargoes with schedules in the Code may be shipped.

5.4 Where a solid bulk cargo is not listed in the Code but its shipment in bulk is required, section 1.3 of the IMSBC Code applies. For solid bulk cargoes not listed in the Code, all details, characteristics, test results, classifications etc. on the product should be provided to the competent authority of the port of loading. The competent authority of the port of loading will use this data to identify appropriate carriage requirements in line with the general provisions of the IMSBC Code.

5.5 Where the product is classified as Group A, Group B or Group A and B, the competent authority of the port of loading should contact the flag state of the vessel(s) to be used for this cargo and the competent authority of the port(s) of unloading to request their agreement and, where appropriate, any additional conditions or carriage requirements. For cargoes that have been classified as Group C, the competent authority of the port of loading should notify the flag state(s) and the competent authority of the port(s) of unloading of the product, its assessment as a Group C cargo and carriage requirements.

5.6 For unlisted solid bulk cargoes where the port of loading is in the United Kingdom, shippers should contact Cargoes@mcga.gov.uk in the first instance and should refer to MGN 512^{[footnote 7]} for details of the information to be provided.

6. Solid Bulk Cargoes - International Code for the Safe Carriage of Grain in Bulk

6.1 Regulations 8 and 9 (Part C – Carriage of grain) of SOLAS Chapter VI require cargo ships carrying grain to comply with the requirements of the International Code for the Safe Carriage of Grain in Bulk (“the International Grain Code”) and to hold a Document of Authorization as required by that Code. The International Grain Code was adopted by the IMO through Resolution MSC.23(59) and is implemented in the UK by the Merchant Shipping (Carriage of Cargoes) Regulations 2024. 

6.2 The term ‘grain’ includes wheat, maize (corn), oats, rye, barley, rice, pulses, seeds and processed forms thereof whose behaviour is similar to that of grain in its natural state. A ship carrying grain in bulk must have available on board a document of authorization in compliance with the International Grain Code, an approved Grain Stability Booklet/a grain loading manual and a copy of the International Grain Code.

6.3 The Alternative Compliance Scheme (ACS) or the Enhanced Authorisation Scheme (EAS) may apply to UK registered vessels which trade internationally and which meet the conditions set out in MGN 568(M)^{[footnote 8]} and MGN 561(M)^{[footnote 9]} respectively. Under the ACS or EAS, the Document of Authorization for the Carriage of Grain may be issued by one of the UK’s authorised Recognised Organisations.  Details on the UK’s Recognised Organisations can be found on the MCA’s website.^{[footnote 10]} The UK’s Recognised Organisations may also approve Grain Stability Booklets.

6.4 SOLAS Chapter VI, regulation 9.2 prohibits a ship without a Document of Authorization for the carriage of grain from loading grain unless the master satisfies the Administration that the ship will comply with the requirements of the International Grain Code in its proposed loaded condition. Where a UK registered ship is relying on this provision in order to carry grain in bulk, the master should, in the first instance, contact the relevant MCA Marine Office with a document signed by a surveyor of the certifying authority stating that the ship in its proposed loaded condition will comply with the requirements of the International Grain Code.  Only if an MCA surveyor is satisfied that the appropriate detailed requirements have been met will such an approval be given.

7. Solid Bulk Cargoes - Code of Practice for Safe Loading and Unloading of Bulk Carriers (BLU Code)

7.1 SOLAS Chapter VI, regulation 7 addresses the loading, unloading and stowage of solid bulk cargoes including grain and references the IMO’s “Code of Practice for Safe Loading and Unloading of Bulk Carriers” as amended (“BLU” Code adopted by Resolution A.862(20)) which contains detailed operational guidance, including the responsibilities of the master and the terminal representative in the cargo operations.

7.2 Further details including the requirements for agreeing loading and unloading plans can be found in Annex B to this MGN.

8. Code of Safe Practice for Cargo Stowage and Securing (CSS Code), Code of Safe Practice for Ships Carrying Timber Deck Cargoes (TDC Code) and other IMO publications

8.1 SOLAS Chapter VI, regulation 1 refers to both the IMO’s Code of Safe Practice for Cargo Stowage and Securing, as amended (“CSS Code” adopted by Resolution A.714(17)) and the IMO’s Code of Safe Practice for Ships Carrying Timber Deck Cargoes (“TDC Code” adopted by Resolution A.1048(27)).

8.2 As a general principle, the owner and master of every ship to which SOLAS Chapter VI applies must ensure that appropriate documentation relevant to the carriage, stowage and securing of cargo is carried on board. Such documentation will specify the precautions necessary for the safe carriage of that cargo by sea.

8.3 As such, for all vessels subject to and complying with the requirements of SOLAS Chapter VI, the MCA expects copies of both relevant and up to date guidance to be available on board such as the IMO’s cargo related codes including but not limited to the CSS Code, the TDC Code, the IMSBC Code, the International Grain Code and the Code of Safe Practice for the Carriage of Cargoes and Persons by Offshore Supply Vessels (”OSV Code” adopted by Resolution A.863(20)).

8.4 The provision and use of such relevant cargo guidance may also be beneficial when developing plans for key shipboard operations concerning the safety of the ship and the prevention of pollution required under SOLAS Chapter IX and the International Safety Management (ISM) Code.

9. Exemptions and Equivalents - Vessels

9.1 SOLAS Chapter VI, regulation 1 provides that for cargo ships of less than 500 gross tonnage an Administration, where it considers that the sheltered nature and conditions of voyage would make application of any specific requirements of part A (General Provisions) or part B (Special Provisions for Solid Bulk Cargoes) of SOLAS Chapter VI unreasonable or unnecessary, may take other effective measures to ensure safety.

9.2 Reflecting this SOLAS provision and in keeping with other merchant shipping safety legislation, the 2024 Regulations contain provisions which enable the Secretary of State to grant exemptions or approve equivalents in certain circumstances. Applications for an exemption or equivalence can be made in the usual way using Maritime and Coastguard Agency form MSF 1261, which may be obtained from the nearest MCA Marine Office. An exemption may be granted subject to such safety requirements as the MCA considers necessary to ensure the overall safety of the vessel. For equivalences, any fitting, material, appliance, apparatus, arrangement or other provision is required to be at least as effective as that required by SOLAS Chapter VI.

10. Equipment approval – Gas Detectors

10.1 SOLAS VI, regulation 3 requires the provision of instruments for oxygen analysis and gas detection when carrying bulk cargoes liable to emit toxic or flammable gases or cause oxygen depletion in the cargo hold. The crew of a ship should be familiar with the use of the instruments and such instruments should be regularly used during cargo monitoring. The instruments should be regularly serviced and calibrated in accordance with the manufacturers’ instructions.

10.2 SOLAS VI, regulation 3 requires that such an instrument must be to the satisfaction of the Administration. For information on design, construction and performance requirements, and testing standards, refer to MSN 1874.^{[footnote 11]} For information on approved equipment, please refer to the UK’s marine equipment database.

11. Test Facility Approval – Testing related to the Carriage of Cargoes

11.1 For test facilities in the UK, the United Kingdom Accreditation Service (“UKAS”) is the sole national accreditation body recognised by the UK Government to assess the competence of organisations that provide certification, testing, inspection and calibration services.

11.2 For further information on UK accredited organisations providing cargo testing services, please refer to the UKAS website.

11.3 Where organisations providing cargo testing services are located in the UK but are not UKAS accredited, other relevant industry standards or accreditations may be acceptable, subject to their being agreed with the MCA prior to any test documentation being relied upon in relation to the shipment of a cargo by sea. Enquiries of this nature should be directed to Cargoes@mcga.gov.uk .  

11.4 Otherwise, the results of verification and tests carried out by bodies or laboratories of other IMO member States offering suitable and satisfactory guarantees of technical and professional competence and independence will be accepted.

12. Material Safety Data Sheets - Oil

12.1 SOLAS Chapter VI, regulation 5-1 requires ships carrying MARPOL Annex I products, such as marine fuel oils, to be provided with a material safety data sheet prior to the loading of such cargoes or fuel oils. The material safety data sheet must be provided to the ship prior to the loading of such oil as cargo in bulk or the bunkering of oil fuel.

12.2 The format of the material safety data sheet can be found in the IMO Recommendations for Material Safety Data Sheets (MSDS) for MARPOL Annex I Oil Cargo and Oil Fuel (MSC.286(86)).

13. Prohibition on blending of bulk liquid cargoes

13.1 SOLAS Chapter VI, regulation 5-2 prohibits the physical blending and production processing of bulk liquid cargoes on board a ship during sea voyages.

13.2 Physical blending refers to the process whereby the ship’s cargo pumps and pipelines are used to internally circulate two or more different cargoes with the intent to achieve a cargo with a new product designation.  Production processes refer to any deliberate operation whereby a chemical reaction between a ship’s cargo and any other substance or cargo takes place. 

13.3 SOLAS Chapter VI, regulation 5-2 also provides for exceptions to the prohibition, namely that it does not apply to the blending of products or the production processes of cargoes for use in the search and exploitation of seabed mineral resources on board ships used to facilitate such operations. A well stimulation vessel would be an example of such a ship. In keeping with the general principles of the SOLAS Convention, it is also stated that the prohibition does not preclude the master from undertaking cargo transfers for the safety of the ship or protection of the marine environment.

13.4 The IMO Circular ‘Guidelines for the Carriage of Blends of Biofuels and MARPOL Annex I Cargoes’ (MSC-MEPC.2/Circ.17) draws attention to this SOLAS Chapter VI prohibition and further states that such blending operations should only be undertaken whilst a ship is within port limits.

13.5 Within port limits, such operations are subject to any local port regulations and bye-laws. Stakeholders are strongly advised to check ahead with the relevant authorities when planning such cargo operations.

14. The safe use of pesticides on ships

14.1 SOLAS VI, regulation 4 requires that appropriate precautions are taken in the use of pesticides in ships and reference is made to the following three IMO publications:

• Revised Recommendations on the safe use of pesticides in ships (MSC.1/Circ1358);
• Recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo holds (MSC.1/Circ.1264, as amended by MSC.1/Circ.1396): and
• Revised Recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo transport units (MSC.1/Circ.1361/Rev.1).

14.2 Accordingly, where pesticides are used in the cargo spaces of ships prior to, during or following a voyage, the 2024 Regulations and MSN XXX (M) require that precautions are established with regard to the relevant IMO Recommendations. As per the IMO’s Maritime Safety Committee, these Recommendations are intended to supplement the requirements of the IMDG code, the IMSBC code and the International Grain Code.

14.3 Given the breadth of this topic and its associated safety concerns, further detailed guidance is contained in our separate Marine Guidance Note MGN XXX.

ANNEX B

Loading, Unloading and Stowage of Solid Bulk Cargoes and the BLU Code

1.1 SOLAS Chapter VI, regulation 7 addresses the loading, unloading and stowage of solid bulk cargoes including grain and references the IMO’s “Code of Practice for Safe Loading and Unloading of Bulk Carriers” as amended (“BLU” Code adopted by Resolution A.862(20)) which contains detailed operational guidance, including the responsibilities of the master and the terminal representative in the cargo operations.

1.2 SOLAS Chapter VI, regulation 7.3 requires the loading/unloading plan and any subsequent amendments agreed between the master and the terminal representative to be lodged with the appropriate authority of the port State. In the UK the appropriate authority is the Harbour Authority of the port or in the case of a terminal not operated by the Harbour Authority of the area, the operator of the terminal.

1.3 The master and the terminal representative are deemed competent within their areas of responsibility under the loading / unloading plan and it is not intended that the agreed plan should be subject to any approval by the receiving authority in the port or a third party.

1.4 Information contained in the plans should be treated by the receiving authority as commercially sensitive to be released only when requested under statutory authority. The plan and any amendments to it should be retained by the master, the terminal representative and the receiving authority for a period of six months.

1.5 Information on the designated holding points for depositing the agreed plans / amendments should be included in the information on the terminal provided to the master on or before arrival. It should be noted that no cargo loading / unloading is to be commenced before the plan is agreed and signed by both the master and the terminal representative. The master should arrange for the agreed plans / amendments to be deposited at the designated holding points and make an entry in the ship’s cargo log book to that effect.

1.6 During the cargo operations, when there is a disagreement or dispute affecting safety, the Maritime and Coastguard Agency (MCA) and / or the Health and Safety Executive (HSE) are to be informed as appropriate following current practice for similar situations in port.

1.7 The master must ensure that the cargo is trimmed reasonably level, as necessary. Any requirements for trimming should be in accordance with Section 5: Trimming Procedures of “The International Maritime Solid Bulk Cargoes (IMSBC) Code”. Provisions for adequate trimming should be agreed as part of the loading plan.

1.8 SOLAS Chapter VI, regulation 7.5 provides that the master and the terminal representative shall ensure that the unloading method does not damage the ship’s structure. The terminal should make every effort to avoid damage to the ship when using unloading or hold cleaning equipment. If any damage occurs, this should be reported to the master.

1.9 When loading cargoes such as scrap metal, special care should be taken particularly at the start of loading in each cargo hold to avoid drops of heavy loads which are likely to cause damage to the tank top structure. Initial loading in the hold should consist of smaller items until the tank top is covered to a reasonable height. High free-fall drops of heavy concentrated loads should be avoided at all times.

1.10 It is desirable that cargo spaces are inspected by the ship’s staff and the terminal personnel taking practical limitations into account before and after loading/unloading operations. Accordingly, the IMO has developed specific guidance in Resolution A.866(20): “Guidance to Ship’s Crews and Terminal Personnel for Bulk Carrier Inspections”.

1.11 SOLAS Chapter I, regulation 11(c) requires the master or owner to report any damage affecting the seaworthiness, structural integrity or the ship’s essential engineering systems etc. to the Classification Society, the flag state and the port state.

1.12 It is to be noted that the 2024 Regulations apply to UK ships wherever they may be and to non-UK ships in UK waters carrying cargoes without any lower limit. In the case of small vessels, particularly those having single holds, the procedures should be simpler. Nevertheless, factors such as the depth of water, nature of the cargo and the degree of trimming may be significant and the procedures should be followed to ensure that the vessel is fit to proceed to sea after the cargo operations.

1.13 In the case of small ships engaged in a number of trips under identical conditions, the cargo loading / unloading plan may be prepared covering multiple trips subject to scrutiny periodically or when the conditions change. This will apply to dredgers which are often engaged in repeated trips between the same dredging site and unloading shore terminal where the terminal controls the unloading. Where the dredger is a self-unloader, or where the ship dredges a channel and dumps the spoil at sea, the master and the “terminal representative” are in effect one and the same. Recalling that the intention of the loading plan is to ensure that the ship sails only in an undamaged and safe loading condition after loading or unloading operations, there will be no separate parties to a loading plan and it will be sufficient for the owner and master to ensure normal safe operating practices in accordance with the ship’s loading manual and information on the dredged material. Where a loading plan covering multiple-trips is agreed between the master and a terminal, it should be lodged with the Harbour Authority.

1.14 Following EU Directive 2001/96/EC in December 2001 which sought to implement the BLU Code in a harmonised way across the EU, The Merchant Shipping (Safe Loading and Unloading of Bulk Carriers) Regulations 2003 came into force on 1 March 2004 with an accompanying MCA publication on the Safe Loading and Unloading of Bulk Carriers.

1.15 As a consequence, many provisions of the BLU Code have been mandatory and enforceable in the UK since 2004 and terminals regularly loading and unloading bulk carriers have been inspected as part of this regime.

ANNEX C

Stowage and Securing - Cargo Securing Manual

1.1 SOLAS Chapter VI, regulation 5 requires that all cargoes, cargo units and cargo transport units are loaded, stowed and secured throughout the voyage in accordance with the ship’s Cargo Securing Manual approved by the Administration.

1.2 Approval of the Cargo Securing Manual for UK ships is carried out using the IMO’s Revised Guidelines of the preparation of the Cargo Securing Manual (MSC.1/Circ.1353/Rev.2) for guidance, hereinafter referred to as the “Guidelines”.

1.3 Notwithstanding the approval of the manual by the Administration, it is the responsibility of the ship operator and the master to ensure that cargo units are secured safely on board.

1.4 The manual should be easy to use and should contain information that is directly applicable to the ship. Information that is not directly related to the ship should not be included in it.

1.5 The layout of the information should follow that shown in the Guidelines using the headings and subheadings in the order they appear in the Guidelines. Where there is no information that can be included under a heading because it refers to a type of ship other than the one for which the manual is being drawn up, the words ‘not applicable’ should be entered under the heading or the heading omitted altogether.

1.6 Other documents or manuals should cover cargo transport falling outside the scope of the requirements of the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) such as the transport of livestock. A reference to such documents should be made in the Cargo Securing Manual. This may be achieved by an entry in its ‘contents’ page.

1.7 The pages of the manual should be consecutively numbered and all text, drawings etc. should be clearly legible. There should be pages to record the dates when the manual is changed to reflect changes in plans or equipment.

1.8 The Cargo Securing Manual may be combined with other operations manuals provided the sections relating to the Guidelines are kept distinct from other matters.

1.9 The headings, layout and format of the manual should also conform to the following sub paragraphs.

i. The text of the ‘Preamble’ in the Guidelines should be copied in full in the manual except for the third and fourth paragraphs. This text should be replaced by:- “This Cargo Securing Manual has been prepared in accordance with the guidance in IMO Circular MSC.1/Circ.1353/Rev.2 –Revised Guidelines of the preparation of the Cargo Securing Manual”. The word ‘preamble’ may be changed to ‘introduction’.

ii. The definitions from paragraph 1.1 of the Guidelines should be reproduced. A further definition for cargo unit may be added as follows:- “Cargo unit means wheeled cargo, vehicle, container, flat, pallet, portable tank, packaged unit or any other entity and loading equipment or any part thereof, which belongs to the ship and which is not fixed to the ship.”

iii. The text from paragraph 1.3.1 of the Guidelines may be modified to read:-“The information in the cargo securing manual should not rule out the principles of good seamanship nor replace experience in stowage and securing practice””

iv. In the manual for a roll on roll off ship, the text of paragraph 1.3.4 of the Guidelines should be extended to include the sentence:-“All securing of cargo units in accordance with the Cargo Securing Manual should be completed before the ship leaves the berth.”

v. Chapter 2 of the manual should contain as much detail as possible directly related to the ship. Use should be made of plans or sketches but if these are too cumbersome, tables or lists may be used instead provided that the location of the devices on the ship, their type, total number of each device and other relevant details are clearly shown.

vi. For a roll on roll off ship, the matters covered by paragraph 3.4 of the Guidelines may be combined with that contained in paragraph 2.1 of the Guidelines when drafting paragraph 2.1 of the manual.

vii. Inspection and maintenance schemes referred to in paragraph 2.3 of the Guidelines may be contained in a separate document or booklet provided that the relevant paragraph in the manual contains a clear reference to this document and its location.

viii. In paragraph 3.1 of the manual, handling and safety instructions specific to the ship should be provided. It should be assumed that general health and safety and the risks from the application, removal and manual handling of securing and lashing equipment does not differ significantly from other general procedures and are covered elsewhere. Therefore, phrases of a general nature should be avoided. Specific points raised by the equipment manufacturers or from a risk assessment of specific methods to be used or from experience in the use of particular procedures, should be covered in detail.

ix. For information on the evaluation of forces acting on cargo units required by paragraph 3.2.1 of the manual, reference may be made to the ship’s approved stability booklet, or if more accurate information is available, from any other more authoritative source. This section should contain:-

a. a broad outline of the accelerations that can be expected at various positions;

b. examples of the resulting forces on the cargo units;

c. angles of roll and metacentric height values above which the forces acting on the cargo units exceed the permissible limit for specific securing arrangements; and

d. worked examples on the number and strength of the portable devices to counteract the resulting forces on cargo units.

1.10 It is not intended to introduce new, mandatory standards for cargo securing equipment. However, such equipment should reflect appropriate recognised national or international standards for the specification and testing of such equipment.

ANNEX D

General Exemption for cargo ships of less than 500 gross tonnage on domestic voyages from the UK concerning Cargo Securing Manuals

The Merchant Shipping (Carriage of Cargoes) Regulations 2024

The Secretary of State, in exercise of his power under Regulation 6 of The Merchant Shipping (Carriage of Cargoes) Regulations 2024, hereby exempts any cargo ship of less than 500 gross tonnage engaged on a domestic voyage from the United Kingdom, from the following requirements of Regulation 9(a) (Requirements in relation to ships):

In Chapter VI of the Annex to the International Convention for the Safety of Life at Sea, 1974 (“SOLAS Chapter VI”), the applicable requirements concerning Cargo Securing Manuals under paragraph 6 of regulation 5 (stowage and securing).

Owners and masters of cargo ships to which this exemption applies should note that:

1. any other relevant cargo stowage and securing requirements in SOLAS Chapter VI must be complied with; and
2. the exemption does not extend to requirements concerning Cargo Securing Manuals contained in other SOLAS Chapters.

This exemption, unless cancelled or modified in accordance with Regulation 6(4), will remain in force until the expiry of the ship’s certificate.

Dated XX XXX 2024

[SIGNATURE]

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1. Previously the subject of MGN 146, now included within this Guidance Note ↩

2. Detailed VGM guidance including company registration and approvals are set out in MGN 534 ↩

3. Mandatory requirements can be found in MSN XXX. Consolidated guidance, including the fumigation of cargoes and cargo units, can be found in MGN XXX (safe use of pesticides in ships). ↩

4. The Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations 1997 will be revoked and replaced by the Merchant Shipping (Carriage of Dangerous Goods and Harmful Substances) Regulations 2024 and reference to the 1997 Regulations includes reference to the 2024 Regulations. ↩

5. List of UK Recognised Organisations ↩

6. Maritime & Coastguard Agency quick guide to fees – November 2018 ↩

7. MGN 512 – Solid Bulk Cargoes: Cargoes not Listed in the International Maritime Solid Bulk Cargoes (IMSBC) Code ↩

8. MGN 568(M) - Surveys - Alternative Compliance Scheme ↩

9. MGN 561(M) - Surveys - Enhanced Authorisation Scheme ↩

10. List of UK Recognised Organisations ↩

11. MSN 1874 (M&F) Amendment 5 – Marine Equipment - United Kingdom Conformity Assessment Procedures for Marine Equipment – Other Approval Standards ↩