Disposal of Dry Bulk Cargo Residue

Many mariners are unaware that the disposal of dry bulk cargo residues is regulated by the requirements of MARPOL Annex V which governs garbage disposal at sea.   

The vessel’s Garbage Management Plan should include measures to mitigate the effects of spillage; spillages on deck and hatch covers should be placed in the hold with the cargo, as far as practicable, upon completion of loading. Upon completion of discharge, holds, decks and hatch covers should be thoroughly cleaned and swept down with any residual cargo being discharged to shore, as far as practicable. 

Residual dry bulk cargo on deck can be washed off the deck and hold washing water discharged overboard when a vessel is more than 12 nautical miles from the nearest land (as defined in the Annex) and is not within a Special Area. At the time of writing the Special Areas covered by the requirements of MARPOL Annex V were The North Sea, Baltic Sea, Mediterranean, Black Sea, Red Sea, Persian Gulf, Antarctic and the Wider Caribbean Region and details on the exact areas covered are prescribed in Annex V. However, there may be occasions when cargo residue has to be discharged within these areas as an “exceptional discharge”, and this should be recorded as such in the appropriate section of the vessel’s Garbage Record Book. Such a discharge would be permitted: 

1.To clear a helicopter landing or winching area to ensure the safe operation of a helicopter such that it is not hindered by dust thrown up by the down draft coming from its rotors.

2. Where there is a hindrance to the safe navigation of the vessel caused by dust being blown such as to obscure the view from the wheelhouse or bridge wings and precluding the keeping of a proper lookout.

3. Where cargo residues are causing a hazard to personnel working or transiting on deck or adjacent areas. 

All cargo residue discharge operations should be recorded as category 4 in the Garbage Record Book. Start and stop positions should be recorded along with the estimated quantity of cargo residue discharged into the sea. It should be borne in mind that records in the Garbage Record Book may be scrutinised by Port State Control inspectors. Sanctions may result in the event of falsified entries being found. 

Cargo residues contained in cargo hold bilge water are not considered cargo residues for disposal purposes as long as the residues concerned are not defined as Marine Pollutants in the International Maritime Dangerous Goods (IMDG) Code and are not covered under the discharge requirements of any other MARPOL annex. It is also accepted that a vessel at anchor for a period of time with empty holds may discharge hold bilge water which is not directly related to any hold cleaning activities. 

Further information on the disposal of dry bulk cargoes, particularly in relation to Australian waters, can be found at: http://www.amsa.gov.au/Shipping_Safety/Marine_Notices/2008/1508.pdf and http://www.amsa.gov.au/Publications/PDFs/Drybulk.pdf