Guidance

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

Updated 28 May 2024

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.