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What did you miss at the third meeting of the BIMCO Dry Bulk Cargo Network?

Published: 05 September 2024

The network held its third meeting, where members took the opportunity to network, share and get further clarification surrounding the compliance of MARPOL Annex V for the discharge of cargo residues for the IMSBC Code cargoes and Group C cargoes that can liquefy. 

With over 110 owner members signed up to the BIMCO Dry Bulk Cargo Network so far, the third meeting held on 29 August was truly a successful network meeting. It was filled with a lot of questions coming from our members leading to an exchange of experiences, information, clarification and recommendations shared covering the following topics: 

  • Materials harmful to the marine environment (HME), MARPOL Annex V & Discharge of Cargo Residues  
  • How to categorise Group C cargoes that can liquefy under the IMSBC Code* 

As the discussion was lively, we could not finish the 2nd topic and it will be carried forward to our 4th meeting to be held on Thursday, 28 November 2024.  

Below are some of the takeaways from the 3rd meeting:  

Materials harmful to the marine environment (HME), MARPOL Annex V & Discharge of Cargo Residues 

  • HME declaration as required by the IMSBC Code and MARPOL Annex V does not apply to grain cargoes 
  • Frequency of owners requesting for a HME certificate evidencing the classification of the cargo as HME or non-HME. 
  • Understanding of meeting just one of the HME criteria will classify the cargo as HME 
  • What is considered cargo residues including the clarification of bilge water collected from cargo hold 
  • Definition of cargo hold washing water 
  • Applicability of HME MARPOL Annex V discharge criteria for bagged cargoes 
  • Question of whether the spillage from bagged cargoes is treated as bulk and the applicability of MARPOL Annex V 
  • Importance of determining the port of destination within the special area at the port of discharge for the discharge of non-HME cargo residues within special areas to apply. 
  • Importance of having reception facilities that are approved and use of GISIS recommended 
  • Issue of fumigated non-HME cargoes becoming HME due to the fumigants used. 

How to categorise Group C cargoes that can liquefy 

  • New definition of Group C cargoes effective 1 December 2023 
  • Particle size distribution (PSD) formula being used to distinguish Group A cargoes from Group C 
  • Difficulties with getting PSD certification from shippers and solutions recommended 
  • Issues with the loading of Chromite Ore (to be continued due to time restraints) 

We would like to thank Martin Kondrup from Lauritzen Bulkers for his excellent chairing once again.  Without his presence and extensive experience, we would not have been able to facilitate the meeting any better. We are truly grateful and appreciative of him for accepting to take on the chair for a third time. 

The 4th and last meeting for 2024 

The 4th meeting of this network and the last one for this year will be held on Thursday 28 November 2024 at 08:00-09:30 UTC and will focus on the following topics, based on a result of a poll conducted at this meeting and the carried-forward topic from the 3rd meeting.   

  • How to categorise Group C cargoes that can liquefy under the IMSBC Code  
  • Materials hazardous only in bulk (MHB) 
  • Understanding seed cake requirements   

The BIMCO Dry Bulk Cargo Network - mission 

The BIMCO Dry Bulk Cargo Network is a network created with the sole intention of allowing working professionals involved in the shipment of dry bulk cargoes the opportunity to learn from each other. Meetings are thus neither recorded nor minuted, and operate under the Chatham House Rule**.  

To enable the network to work progressively, it will be driven by the needs of its members. We encourage members to attend the meetings regularly, because the more they can get to know each other, the more comfortable they will be sharing knowledge and having friendly discussions in the network. In turn, this will assist their business operations with sea transport of solid bulk cargoes. In addition, members facing any challenges are welcome to send us the same so that they can be raised at the network meetings for a full discussion.  

To Join the Network 

 For more information about this network and how you can join, please contact Henriette Dybkær HDY@bimco.org 

*IMSBC Code – The International Maritime Solid Bulk Cargoes Code 
**When a meeting, or part thereof, is held under the Chatham House Rule, participants are free to use the information received, but neither the identity nor the affiliation of the speaker(s), nor that of any other participant, may be revealed. 



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Ai Cheng Foo-Nielsen

CONTACT BIMCO

Ai Cheng Foo-Nielsen

Regulatory Manager

Copenhagen, Denmark