Guidelines for the Safe Carriage of Bagged Rice - Risk Alert 105

• Any dunnage and other protective materials used during the loading operation should be of good quality, clean, and dry and applied in line with industry standards. Dunnage by means of placing wooden pallets in the tank top and hoppers is intended to avoid direct contact between the cargo and the vessel steelwork. The pallets are commonly overlaid with craft paper or plastic sheets on both the tank top and the sides of the hold. On completion of loading, the top layer of the cargo should be covered with a layer of plastic sheet or craft paper to protect the cargo from any ship sweat that may form on the vessel structure. Various alternative types of dunnage such as bamboo sticks, Styrofoam or plastic/polythene sheets and craft paper are also common in certain parts of the world. It should be borne in mind that some countries have restrictions on the discharge of certain cargo protection materials in their ports, and this should be a consideration when determining which materials should be employed at the load port. The provision of adequate, appropriate and approved cargo protection/dunnage materials is very important and is to be to the satisfaction of master.
• It has been determined that in some claims, at the time of loading, the cargo protection material had not been applied in the correct manner. The protection material (kraft paper/plastic sheeting) should be laid in such a way as to assist any “sweat” to run to the bilges, that the sweat is run-off behind the sheets and does not come into contact with the cargo itself.
• The stowage plan should be checked to verify that the cargo is appropriately and properly stowed in relation to the overall volume of cargo to be loaded in the hold. The stowage should allow for proper ventilation channels to facilitate effective circulation of air. Due attention should be given to the structure of the cargo hold including steel frames, pipes and shape of the cargo hold, allowing proper for separation of cargo from the steel structure.
• The loading and discharging of rice bags should be carried out utilising slings and nets which presents a lower risk of cargo damage, although this does involve a lot of manual handling for the correct stowage and discharge of rice bags. Some stevedores use hooks which should be avoided as this can damage the rice bags and result in cargo spillage with the associated potential for shortage claims.

Cargo Documents:

• All relevant cargo documentation is to be provided to the master, this should include the Cargo Quality Certificate and any Shippers instructions for the safe carriage of the cargo.
• The average moisture content for rice should not exceed 14% and would be stated in the Cargo Quality Certificate. A moisture level above 14% would present an inherent risk of damage and therefore appropriate steps to protect against potential cargo damage claims at the discharge port should include rejecting cargo of a high moisture content.
• The vessel should have onboard appropriate publications to guide on the stowage and care of rice cargo onboard vessels. The vessel should comply with the approved CSM (cargo securing manual) for the safe stowage and securing of the cargo and to also ensure that adequate stability is maintained for the entire voyage.
• Dunnage Certificate: Phytosanitary certificate requirements vary from country-to-country and are intended to protect the country against any harmful and detrimental species being introduced into the local environment. Disposal of dunnage on completion of discharge might be challenging without the appropriate certification.

Cargo operations & Stevedore Handling:

• It is a good practise to have a pre cargo operation and toolbox meeting between all concern parties prior to the commencement of the initial cargo operations and at the start of each day thereafter. With many companies incorporating this practise into their SMS procedures.
• Handling issues can result in damage to bagged rice cargo and members should be aware of this potential for damage during cargo operations (loading and discharging). Multiple handling of bagged rice cargo, such as the loading from or discharging to barges may exacerbate the possibility of damage
• Stevedores handling of cargo must be effectively and constantly monitored and, where mishandling has occurred, Letters of Protest (LOP) should be issued on each occurrence. When issuing LOPs, members should include as much detail as possible with the objective of making it easier to defend any subsequent claims should they arise.
• Most bagged rice cargoes are loaded and discharged using slings and nets as stated above. This reduces the risk of damage while allowing multiple bags to be lifted at the same time. The dragging of slings is to be avoided, and slings that are used should be of an approved type, be clean and have the relevant certification readily available.
• The risk of other physical damage during cargo operations also exists, and that include the spillage of drinks and in some cases urinating on cargo by the stevedores. The tallying should be monitored by the crew and the independent preload cargo surveyor.  
• Maintaining a constant record of the temperature of the cargo during the loading operation is essential, with future decisions regarding ventilating of the holds during the course of the voyage being based on the average cargo temperature during loading. The ship's crew should continuously monitor for rain during the loading process, ensuring timely closure of hatch covers to prevent wetting damage to the cargo. A detailed record of any rain occurring during the time of cargo operations must be documented in the rain log.
• To prevent damage to the rice bags the use of hooks and any other sharp objects should be avoided, and this should be discussed during pre-cargo operations toolbox talks. In the event of damage to the rice bags any spillage should be collected and tallied separately to minimise any potential shortage claims. Any deviations from the arrangements (as agreed in the pre-cargo operations meeting) should be recorded and LOP issued with detailed explanation.
• It is good practise for the ship’s officers to carry out an “intermittent internal draft survey” at the end of each stevedoring shift, this assists in assessing the quantity loaded onboard and can serve as a counter check with the Tally, reducing the chance of ambiguities in the quantity of cargo loaded or discharged.
• Mate’s receipts (MRs) are to be issued as and when necessary, stating the actual condition of cargo loaded onboard and becoming part of the B/Ls. The preload surveyor should assist in the issuance of these documents.
• Cargo holds where no cargo operations are in progress should be kept closed and this applies to both loading and discharge cargo operations.
• On completion of final cargo loading, the cargo holds are to be closed and battened down and, in the presence of all concerned parties, the hatch cover and hatch access seals applied. A hatch sealing certificate should be provided to certify that the hatches covers and accesses hatches have been sealed. This activity is to be documented, and the same is recorded in the deck logbook with details of the seals.
• On completion of cargo operations, and in the presence of all concerned parties, a Final Draft survey is to be carried out, the final loading figures agreed, and the Bills of Lading (B/Ls) are issued. All of these activities are to be properly and diligently, logged and filed onboard.

Fumigation: 

Rice is a cargo that may be liable to infestation and is therefore required to be fumigated. Fumigation is a process that is intended to prevent insects, pests, and potentially rodents that may be concealed within plant products from infestation of the cargo.

The fumigation of cargo holds is covered by SOLAS Ch. VI – Part A – Regulation 4 – The use of pesticides in ships, which refers to MSC.1/Circ.1264  – Recommendations on the Safe Use of Pesticides in Ships Applicable to the Fumigation of Cargo Holds, which was amended by MSC.1/Circ.1396 .

There are three main types of infestation:

1. Introduced – brought on board with plant and animal cargoes.
2. Cross – transfer to other cargoes
3. Residual – left in cargo holds from previous cargoes.

For fumigation of rice cargo the following should be considered:

• Appointing a certified and reputable fumigator-in-charge and team of fumigators.
• Certificate of fumigation and clear guidance from the fumigating company detailing the type of fumigant and quantity used together with clear concise instructions advising the crew when to start ventilating.
• Detailed instructions, training, and equipment for monitoring gas concentrations during the course of the voyage in void spaces and crew accommodation.
• Once fumigation has been undertaken the cargo holds are to be considered an Enclosed Space and NO ENTRY signs are to be posted at all cargo hold access points. There is to be no entry into the cargo holds until such time as the holds have been well ventilated and certified gas free by a competent chemist.

Members are reminded to refer to the recommendations on the safe use of pesticides onboard vessel for further details refer to IMO Circulars MSC.1 - Circ.1264. pdf  and its amendment MSC.1/Circ. 1396.  

Transit passage:

• Upon completion of the final draft survey, and having sealed the cargo holds, the vessel will set sail for port of discharge (POD). As a good practise, where possible and practicable, the condition of the vessel upon arrival at the discharge port should be the same as that upon sailing i.e. ballast and fuel tanks condition, with exceptions being the use of bunkers and other consumables during the course of the passage.
• Unless required for stability reasons, or in the event of an emergency, any transfer of ballast water is to be avoided and should be kept to the minimum.
• Bilges and ballast tanks are to be sounded on a regular basis, ideally daily, and accurate logs maintained.
• The seals of the cargo holds are to be checked frequently.  In the event a seal is found to be broken it should be replaced with one of those specifically provided onboard. All parties, including charters and shippers, should immediately be notified in the event of any broken seals being identified, with the broken seals being retained onboard for inspection at the discharge port. All this activity including seal numbers and photographic evidence should be retained to defend possible claims and should be accurately recorded in the deck logbook.
• The cargo hold weathertightness is to be monitored throughout the course of the passage and appropriate action taken to ensure the continued weathertight integrity of the holds, especially during rough weather conditions. Accurate details of the weather conditions and sea state are to be recorded in the deck logbook.
• The accurate recording of all the above activities is very important when defending any potential cargo damage claim, demonstrating that the carrier has exercised due diligence in meeting their obligation to properly prosecute the voyage, using all available resources and the practice of good seamanship. This may include any alteration to course/speed if the circumstances dictate in order to protect the cargo.
• The ventilation of the cargo holds is to be undertaken as and when appropriate with detailed and accurate records being maintained.

Ventilation: