Sowing the Seed of Confusion

The amendments, which have been in place on a voluntary basis since 1 January 2020, significantly change the seed cake schedules. The existing schedule for SEED CAKE UN 1386 (b) has been revised, the SEED CAKE (non-hazardous) schedule has been removed and two new seed cake schedules have been created.

SEED CAKE, containing vegetable oil UN 1386 (a) mechanically expelled seeds, containing more than 10% of oil or more than 20% of oil and moisture combined

What’s changed?

There are no changes to this schedule.

What to look out for?

The IMSBC Code states UN 1386(a) is to be carried in bulk only with special permission from the competent authority.

SEED CAKE, containing vegetable oil UN 1386 (b) solvent extractions and expelled seeds, containing not more than 10% of oil and when the amount of moisture is higher than 10%, not more than 20% of oil and moisture combined

What’s changed?

The IMSBC Code includes a list of products where this schedule does not apply as they have been proven not to be class 4.2 (intimating they should have been tested as per section 9.2.2) One of these listed exceptions is “solvent extracted rape seed meal, soya bean meal, cotton seed meal and sunflower seed meal, containing more than 4% oil and 15% oil and moisture combined”. The 2018 edition of the IMSBC Code did not include rape seed pellets in this list of exceptions, but it did include the additional text “and being substantially free from flammable solvents” which has been removed for the 2020 edition.

Despite removing “and being substantially free from flammable solvents” from the list of exceptions, the instructions in the UN 1386 (b) schedule makes it clear that any seed cake cargo shipped under this schedule must be substantially free from flammable solvents and that the cargo should be properly aged.

Previous editions of the Code require the shipper to provide a certificate from a person recognised by the competent authority stating that the provisions of the exemption have been met. However, the new edition states that the certificate must show the oil and moisture content is as specified in the list of exceptions.

What to look out for?

If the cargo presented as UN 1386 (b) is solvent extracted, it must be substantially free from flammable solvents. However, the schedule could be interpreted to mean that there is no need to state this in a declaration, only requiring a certificate stating the oil and moisture content. Therefore, we recommend that the master asks for written confirmation that solvent-extracted cargo is indeed substantially free from flammable solvents.

Despite not being listed clearly in the schedule as a requirement, section 4.2.2 of the code states that the cargo information should include details of any toxic or flammable gasses which may be generated by the cargo.

SEED CAKE UN 2217 with not more than 1.5% oil and not more than 11% moisture

What’s changed?

The 2018 edition of the Code stated that the schedule for UN 2217 seed cake did not apply to “solvent-extracted rape seed meal pellets, soya bean meal, cotton seed meal and sunflower seed meal containing not more than 1.5% oil and not more than 11% moisture and being substantially free from flammable solvent”. However, the 2020 edition omits “and being substantially free from flammable solvent” and replaces rape seed meal pellets with rape seed meal and rape seed pellets.

Previously, the Code required that “a certificate from a person recognized by the competent authority of the country of shipment should be provided by the shipper, prior to loading, stating that the provisions for the exemption”. Now, the need for a certificate stating the provisions for exception are met has been removed due to the new requirements on testing that the cargo does not meet the criteria for a class 4.2.

What to look out for?

There are no changes to the documentation requirements, the Master still needs a certificate from a person recognized by the competent authority of the country of shipment specifying the oil content and moisture content to be issued as well as a full and correct cargo declaration.

The cargo should be substantially free from solvents, however, as mentioned earlier for UN 1386 (b) cargoes, some shippers may interpret this to mean that they do not need to supply this declaration on any documentation. Again, we recommend the master asks for written confirmation.

Seed Cake (non-hazardous)

The schedule for non-hazardous seed cake has now been removed.

SEED CAKES AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES – GROUP B

What’s changed?

This is a new schedule and applies to products that are substantially free from flammable solvents and chemicals. It is classed as a Group B cargo and must have undergone prescribed testing to be classified as a ‘material hazardous in bulk’ (MHB) due to its self-heating properties. Such cargoes have been tested and cannot be classified as a class 4.2 cargo.

What to look out for?

Despite the cargo being tested and not shown to be class 4.2, it should be stowed and segregated as if it were a class 4.2 cargo.

It should only be accepted on board with a temperature that does not exceed the lower of either 55°C or the ambient temperature + 10°C.

Masters should try to prevent sources of ignition, especially if the cargo is generating dust. The cargo can be loaded by blower and this equipment and piping shall be earthed. Due to the dust that can be generated, crew should use the appropriate PPE during load and discharge.

Due to the chemical properties of the cargo, the atmosphere may become dangerous and persons should not enter the cargo holds. All holds and adjacent spaces should be treated as enclosed spaces.

During the voyage, the temperature of the cargo is to be measured at a number of depths in the cargo spaces and recorded during the voyage.

The cargo should be substantially free from flammable solvents and chemicals and properly aged dependant on the oil content.  However, some shippers may interpret this to mean that they do not need to declare this on any documentation. Again, we recommend that if it is not supplied, then request confirmation. It is also a requirement that the cargo has been tested as per section 9 of the Code and that is not class 4.2. We also recommend that the vessel receives such a declaration from the shipper.

SEED CAKES AND OTHER RESIDUES OF PROCESSED OILY VEGETABLES – GROUP C

What’s changed?

This is another new schedule. To be classified as this Group C cargo, it must be substantially free from flammable solvents and chemicals.

What to look out for?

The Master must be provided with a certificate stating the requirements for exclusion from UN 1386 (b) or UN 2217 have been met. The certificate must also state the material does not meet the criteria for self-heating in bulk or for inclusion in class 4.2.

Solvent-extracted cargo must only be loaded if it is substantially free from flammable solvents and we recommend confirmation of this fact is sought.

Despite this being a Group C cargo, the hold and all adjacent spaces should be considered dangerous and proper enclosed space entry procedures followed.

Summary of seed cake schedules

The table below summarises the new requirements. It must be read in conjunction with the IMSBC code.

Follow the Code

Once the master has been provided with the appropriate declarations and documentation and is satisfied, follow the specific schedule in the Code that outlines all the hazards and procedures.

Don’t forget your DoC

To enable your vessel to carry the new cargo Seed Cakes and Other Residues of Processed Oily Vegetables GROUP B, it should be included on the vessel’s document of compliance for hazardous cargo.

Acknowledgements

With thanks to CWA International for their assistance with this article.

Call to action

These changes were broadly outlined by North in their industry news article that can be read here.

North’s loss prevention briefing on seed cake cargoes can be found here.