Canadian Biomass • November/December 2015 • Final Thoughts

Once a year the IMO Sub-committee for Carriage of Cargoes and Containers (CCC) convene in London, United Kingdom at the IMO head office for hearing of new classifications proposals and amendments to existing regulations.

The work is done in working committees, editorial and technical committees and plenary sessions lasting a week to 10 days. When consensus has been reached, the proposed regulation is presented in a separate meeting before the Maritime Safety Committee (MSC) once a year for ratification and inclusion under the International Maritime Solid Bulk Cargoes (IMSBC) Code.

By definition under the SOLAS Convention, carriage of all cargoes shall be done in ocean vessels equipped with “Fixed Gas Fire-Extinguishing Systems or Fire Extinguishing Systems giving equivalent protection”. There is, however, a list of cargoes for which this requirement may be exempt.

Wood pellets have so far only been allowed to be shipped in ocean vessels fully equipped with such systems, which has limited the selection of bulk carriers in which wood pellets could be legally carried. The new amended schedule under IMSBC Code was approved by MSC on June 12, 2015, allowing for exemption of this requirement starting on January 1, 2016 on a voluntary basis for vessels obtaining certification under the Class Society under which the vessels are classified.

Starting on January 1, 2017, after completion of a tacit procedure among voting IMO members, this new amended Code will become part of the mandatory IMSBC Regulation. The change will result in increased flexibility for carriage of wood pellets not containing any additives and/or binders in vessels with, as well as without, Fixed Gas Fire-Extinguishing Systems.

The first IMO Schedule for Wood Pellets was drafted by Wood Pellet Association of Canada (WPAC) and submitted to Transport Canada for further submission to IMO in 2002 as a result of the MV Weaver Arrow fatal off-gassing accident in Rotterdam. This first schedule became part of the Solid Bulk Cargoes Code (BC Code) in December 2004 and revised in 2009 when the BC Code was upgraded to the IMSBC Code. In 2012, IMO introduced new criteria under the new IMSBC Code to qualify for exemption to the requirement to have fixed gas fire extinguishing systems on board. The new requirements included proof that the material would not emit flammable composite gas, would not self-heat and would not have a burnrate above a certain level.

Extensive research in close collaboration between WPAC and University of British Columbia was concluded in March 2013 to qualify ”wood pellets not containing any additives and/or binders” as exempt. Amendments to the schedule for wood pellets was drafted and processed in close collaboration between WPAC and Transport Canada and the first reading before IMO was done in September 2013. Subsequent editorial and technical reviews were concluded by working committees during 2014 and culminating in ratification by MSC on June 12, 2015.

The time for establishing schedules for new commodities or to amend existing schedules is three-to-four years before a new or amended code under IMSBC becomes ratified and in force and requires significant research in order to backup classification data. This is something to keep in mind when introducing, for example, new pellets containing additives and/or binders or agricultural pellets. The current IMSBC Code has a schedule for torrefied wood (including torrefied pellets) which specifies up to three per cent binders. To change this percentage or any other part of the current schedule could be a time consuming process and may require substantial research similar to what WPAC and UBC did for regular wood pellets.

The benefit with the IMSBC Code is the regulatory and legal framework it provides for manufacturers, shippers, ocean carriers and buyers. Since the shipments of wood pellets from Canada on a regular basis to Europe in 1998, the enforcement of compliance with the IMSBC Regulations has increased and so has the requirement for due diligence when introducing new schedules and amendments. Besides the regulations in the IMSBC Code under the UN IMO SOLAS Convention there are also regulations applicable to wood pellets under the IMO MARPOL (Marine Pollution) Convention.