Issue Summary

This issue essentially concerns the definition of an exemption to the all encompassing definition “intended primarily to carry dry cargo in bulk”. Traditional bulk carriers, with hopper and topside tanks, are not at issue and have a clear definition in the CSR rules and in parts of SOLAS. However, some vessel, such as multipurpose or general cargo ships, occasionally carry dry cargo in bulk and it is argued that they should not have to comply with all of the bulk carrier requirements.

Intercargo Policy

Intercargo’s position is that:

(i) If a ship is primarily designed to carry dry cargoes in bulk, that is, it is designed in the first instance around dry bulk cargoes, then it should be designated a bulk carrier and comply with the pertinent requirements of SOLAS including chapter XII.

(ii) When a ship is primarily designed to carry other cargoes, for example designed around containers and break bulk, and only occasionally carries dry bulk cargo then it is not appropriate to use the bulk carrier designation. However, any additional risks associated with the carriage of dry bulk cargoes in such a ship should be identified and appropriately regulated.

Summary of Recent Developments

MSC 85, meeting in November/December 2008, adopted a resolution (MSC 277 (85)) on the clarification of the term “bulk carrier”; and guidance for application of regulations to new ships which occasionally carry dry cargos in bulk and are not determined bulk carriers under SOLAS (in reg. XII/1.1 and Ch II-1). It should be noted that this resolution does not change SOLAS, but provides guidance on how to apply relevant SOLAS requirements. While a resolution cannot provide mandatory application dates, governments are urged to apply the guidance to new ships built (keel laid) on or after 1 July 2010.