This test procedure details the laboratory determination of TML for coals up to a nominal top size of 50mm. The procedure is based on a modification of the Proctor/ Fagerberg test involving testing of a coal sample of up 170kg.
While the IMSBC Code applies primarily to the seaborne carriage of cargoes, Adams said there is a “definite crossover”, but bulk terminal operators are often left behind during the regulatory decision-making process which, given that five billion tonnes of bulk commodities are transported annually, needs to change.
“There has to be greater representation at IMO. Liquefaction remains a serious concern for all sectors of industry but there is no international legislation governing the storage, segregation, handling and monitoring of such cargoes at the terminal — only guidelines,” he said.
Turning to the issue of HME classification (cargoes harmful to the marine environment under Marpol Annex V), Adams pointed out that there is no definitive list of HME cargoes, and in his opinion, quite rightly so. “It remains the responsibility of the shipper to declare whether a cargo is
HME and to source the necessary cargo residue and wash-water reception facilities,” he said.
The certification of HME cargoes was also considered problematic, with ICHCA members commenting on a perceived increase in the number of falsified TML certificates. This, many agreed was due to the lack of mandatory procedures for carrying out TML tests and full depth sampling of stockpiles, which ports will restrict for obvious safety reasons.