Caution when Carrying Ivory Coast Nickel Ore

Focusing on operations in the port of San Pedro, the primary concerns are on the moisture content of cargoes at the time of loading, the validity of cargo sample test results and doubts on the status of an operational competent authority.

Sampling and Testing

Under the International Maritime Solid Bulk Cargoes Code (IMSBC Code), nickel ore is a Group A cargo (liable to liquefy) and the shipper is required to arrange for the cargo to be properly sampled and tested prior to loading.

The shipper must then provide the Master with the information and documentation required in sufficient time, before loading, to ensure that the cargo can be safely loaded, carried and discharged from the ship.

This includes certifying the transportable moisture limit (TML) and moisture content of the cargo to be loaded. This is to be issued by an entity recognised by the competent authority (CA) of the country. The Master is also to be provided with a document issued by the CA stating the shipper’s procedures for sampling, testing and controlling moisture content have been approved.

However, in Ivory Coast there have been doubts on whether samples drawn are truly representative, calling into question the validity of the test results for the cargo consignment put forward for shipment. There are also reservations regarding the accuracy of the moisture content results from local laboratory facilities.

Furthermore, the status of an operational competent authority (CA) is unclear. According to BC.1/Circ.74/Corr.1 (3rd October 2019), Ivory Coast has a competent authority listed. However, there is some uncertainty as whether the listed CA is operational. Investigations have found two companies are authorised by the Ivorian Ministry of Mines to conduct testing, but it is understood that there is currently no involvement by a CA in the approval of procedures.

Therefore, laboratories issuing TML certificates and moisture content declarations may not have had their sampling and testing procedures approved by a CA.

To date, TML testing of Ivory Coast nickel ore cargoes has been carried out by laboratories in Estonia. Whilst there is no reason to doubt the quality of these testing facilities, the results often come with a warning from the laboratory that the samples were collected by the shipper and the laboratory carries no responsibility for the representativeness of the samples with respect to the cargo intended for loading.

It is also common for the shipper to declare a single TML result obtained from a single cargo sample, and to consider that sample as suitably representative of all mined material in a six-month period.  This practice raises concerns as mined materials are unprocessed and highly variable natural products.

Ensuring Cargo Safety

Given the issues outlined above, it is imperative that the Master uses all available means to ascertain that the cargo being loaded is safe for carriage.

We recommend that Members inform the club of their intention to load nickel ore in any of the Ivory Coast ports to allow us to assist wherever possible and consider the appointment of a local surveyor to assist the Master in all the relevant checks to the cargo before and during loading.

North’s nickel ore cargo care checklist can assist in assessing if the cargo is safe to carry. Although it may be difficult to get all the information stated in the checklist, try to get as much as possible as this will assist in a remote check of the cargo properties and allow further expert advice to be provided.

Charterparty Protection

Members should consider how they might protect themselves contractually before agreeing to carry nickel ore cargoes, e.g. including an appropriate clause in any charterparty.  Equally, Members should not be pressurised into entering into charterparties which restrict their right to fully apply the provisions of the Code, appoint independent surveyors of their choice or take and test cargo samples.

Acknowledgements

Thanks to Roxburgh for their kind assistance in writing this article.

Find out more

Based on our experiences of nickel ore cargoes from Indonesia and the Philippines, we have also produced the following on nickel ore cargoes:

• Nickel Ore Cargo Care Checklist
• Nickel Ore Loss Prevention Briefing
• Liquefaction Loss Prevention Briefing