When vessels are scheduled to load multiple grades of the same commodity or different commodities altogether then some form of separation is typically required. Natural hold separation is certainly the most ideal type as there are no extra costs associated (aside from the possibility of the vessel not being to lift their maximum cargo intake) and there is no chance of contamination between the grades/commodities. When natural separation is not possible or economical, then the need for an artificial separation is required. This involves building a separation using artificial materials which contain a mix of oriented strand board and poly cloth. There are two types of separations that are commonly built along the West Coast of Canada: full oriented strand board style (i.e. Kobe style) and crash pad style separations.

OSB separations are by far the most common type of artificial separation as the chances of cross contamination between the two cargoes is minimized. In this process, the lower part of the hold is loaded with whichever cargo needs to be discharged off the vessel last. Often times, the suppliers will order a second labour gang to build the separation while loading continues in another hold to avoid delays in loading operations. To prepare the hold for the separation, longshoremen will drop a bombardier into the hold to level the cargo and ensure it is flat. Additional labourers will then hand shovel some of the harder to reach areas to make everything as even keel as possible. Once complete, the poly cloth is laid flat across the entire cargo with all corners and edges sealed with rib fillers. The rib fillers are then held down with smaller pieces of OSB board for further security. Finally, a full floor of OSB board is laid down onto the hold. Each piece overlaps the other at each side by about 6-10 inches. See the above photo for an example of this style of separation.

Alternatively, the process for a crash pad style separation is slightly less intensive. The initial process remains the same whereby a bombardier is used to level the cargo followed by hand levelling with shovels. The poly cloth is once again laid flat with the corners and edges sealed with rib fillers and secured with small OSB pieces. Where the two separations differ is that only the area under the hatch square is covered in OSB board as opposed to the entire hold. Because less OSB boards are required, the crash pad style is typically less costly than the full OSB style.

The above processes can be further complicated if fumigation needs to occur for the cargo on the bottom. In this case, recirculation piping will be pre-installed in the bottom of the hold prior to loading so that the fumigators are able to safely apply the fumigant after the separation has been built. If the top portion of the hold needs to be fumigated as well, regular fumigation methods can be used afterwards. Another method involves the cutting of holes/openings into the OSB boards to allow the fumigant to successfully permeate through the separation. The poly cloth is left undisturbed to ensure the cargoes are still safely separated. The holes that need to be cut have to be done so in a specific pattern and with certain measurements.

Finally, there can be some logistics involved in getting the separation materials safely on board (including the bombardier). If the terminal permits (not all do), then the materials and equipment can be loaded shore side using the vessel’s cranes (including bombardier). Longshoremen can be quite tedious in checking the crane’s certificates and overall condition before use so it is important for the vessel to ensure all required paper work/certification is in order. For terminals that do not allow this, a barge would be required to tie up on the water side with the equipment/materials which are then loaded on board. In a worst-case scenario, the terminal does not allow the vessel to stay along the berth then the vessel would shift to a local anchorage and the equipment would be barged to the vessel along with the longshoremen to build it there. To add a little more complication, weather can and often will impede progress as the hold would have to remain shut during periods of rain which can cause significant delays.

The “shipper’s declaration” or “cargo declaration” as it is often known, is a document prepared by the shippers of a cargo and presented to the Master prior to any loading operations. For grain specific cargoes, this document is quite important as it has some information on it that Transport Canada requires in order to review the grain stability calculations and grant the vessel a “Readiness to Load Grain Certificate.”

According to Transport Canada, this declaration is not described anywhere in the IMO Grain Code. Instead, the governing regulation falls to the Canadian Cargo, Fumigation, and Tackle Regulations (CFTR). Under Division 3 of the CFTR, it is clearly stated that “The master of a vessel shall ensure that the requirements of the following are met:

(a) regulation 3.1 of Chapter VI of SOLAS;

(b) Part B of Chapter VI of SOLAS, except in so far as the requirements apply to the terminal representative; and

(c) subject to section 117, the BC Code.”

It is the reference to Part B of Chapter VI of SOLAS that defines the requirements guiding shippers about what is necessary on a cargo declaration. The regulation outlines the following –

“1 The shipper shall provide the master or his representative with appropriate information on the cargo

sufficiently in advance of loading to enable the precautions which may be necessary for proper stowage and safe carriage of the cargo to be put into effect. Such information shall be confirmed in writing† and by appropriate shipping documents prior to loading the cargo on the ship.

2 The cargo information shall include:

1. in the case of general cargo, and of cargo carried in cargo units, a general description of the cargo, the gross mass of the cargo or of the cargo units, and any relevant special properties of the cargo. For the purpose of this regulation the cargo information required in sub-chapter 1.9 of the Code of Safe Practice for Cargo Stowage and Securing, adopted by the Organization by resolution A.714(17), as may be amended, shall be provided. Any such amendment to sub-chapter 1.9 shall be adopted, brought into force and take effect in accordance with the provisions of article VIII of the present Convention concerning the amendment procedures applicable to the annex other than chapter I.
2. in the case of solid bulk cargo, information as required by section 4 of the IMSBC Code.
3. in the case of a bulk cargo not classified in accordance with the provisions of the IMDG Code, as defined in regulation VII/1.1, but which has chemical properties that may create a potential hazard, in addition to the information required by the preceding subparagraphs, information on its chemical properties.

3 Prior to loading cargo units on board ships, the shipper shall ensure that the gross mass of such units is in accordance with the gross mass declared on the shipping documents. The “shipper’s declaration” is not described anywhere in the IMO Grain Code (IGC).”

Mentioned in the above, is a reference to the International Maritime Solid Bulk Cargoes (IMSBC) Code which regulates the information for solid bulk cargo. The relevant section, Section 4, deals with the “assessment of acceptability of consignments for safe shipment” and the provision of information. In this sub section, the shipper is tasked with providing the “master or his representative with appropriate information on the cargo sufficiently in advance of loading to enable the precautions which may be necessary for proper stowage and safe carriage of the cargo to be put into effect.” Additionally, the specific information that needs to be included on the declaration is described which contains, among other things, the following –

1. the BCSN when the cargo is listed in this Code. Secondary names may be used in addition to the BCSN;
2. the cargo group (A and B, A, B or C);
3. the IMO Class of the cargo, if applicable;
4. the UN number preceded by letters UN for the cargo, if applicable;
5. the total quantity of the cargo offered;
6. the stowage factor;
7. the need for trimming and the trimming procedures, as necessary;
8. the likelihood of shifting, including angle of repose, if applicable;

In conclusion, Transport Canada Marine Safety is required to follow the regulations put forth by the Cargo Fumigation and Tackle Regulations which is applicable to foreign vessels loading or discharging grain cargoes in Canada. It is up to the individual shippers to provide this information, through the agent, to the vessel prior to inspections. Often times, when there are multiple cargoes and/or suppliers, the vessel may be presented with multiple declarations at a given time.

For an example of a cargo declaration as recommended by the IMSBC code, please see below –

Every now and then we get questions pertaining to the fumigation procedures for grain vessels. Certainly, these questions are founded as the costs involved for a vessel to fumigate on completion of loading are not inconsequential. There are two authorities involved in regulating fumigation procedures in Canada; Transport Canada and Health Canada. Transport Canada concerns themselves with the responsibilities of each involved party and the safe management of hazards to the vessel. Health Canada on the other hand aims at minimizing any potential risks posed by the related pesticides/chemicals used in the fumigation process. The purpose of in-transit fumigation on grain laden vessels is to protect and ensure the integrity of a particular commodity. Most often, these procedures relate to the fumigation of in transit cargoes (i.e. grain), however, there are circumstances where empty holds need to be fumigated as well.

The use of fumigants is regulated under the Cargo, Fumigation and Tackle Regulations (SOR/2007-128) which is based on the requirements set out by the International Maritime Organizations. The regulations outline the strict procedures that must be followed, where the fumigation can commence, and which parties are authorized to perform the fumigation. Fumigators are required to perform a pre-inspection of the space “in which the cargo is to be fumigated before the cargo that is to be fumigated is loaded on board and has determined that, during the fumigation, no fumigant is likely to leak from the space containing the cargo and into an adjoining space or out of the vessel” and has provided the name of the fumigant to be used, any known hazards, and the precautions for the crew to follow.

Once loading has completed and the holds that require fumigation have been identified, the fumigation team will board the vessel prior to leaving the berth. The vessel will then depart the berth with a shifting pilot and proceed to a local anchorage as assigned by the Harbour Master. Upon arrival at anchorage and disembarkation of the shifting pilot, a safety meeting will take place with the ship’s officers and fumigators. Fumigation cannot commence until “the loading of cargo onto the vessel is completed and all persons, other than the persons who are engaged in the fumigation or who will sail with the vessel, have disembarked.”

Fumigation in the West Coast of Canada almost always occurs at anchorage due to the requirement to have a gas-free certificate issued by the fumigator-in-charge. That is not to say that fumigation cannot occur alongside a berth it is just very impractical to do so. If a vessel were to remain at the berth for fumigation, the terminal would then effectively lose shipping time as no longshoremen would be permitted near the vessel for 24 hours until a gas free certificate can be issued. The fumigator-in-charge will remain on board for these 24 hours preceding the commencement of fumigation to “ascertain whether there is any leakage of the fumigant has elapsed.” Once it can be determined no leakage has occurred, the gas free certificate will be issued and the departure pilot will board.