Iron Ore Fines from India: Liquefaction Alert!
Following a recent fatal bulk carrier casualty in the Bay of Bengal, Members are reminded of the risks of carrying iron ore fines and other cargoes prone to liquefaction. The vessel had loaded iron ore fines at Paradip, India, and was en route to its next port when the casualty occurred. Although the cause remains undetermined at this stage, the incident underscores the importance of strict compliance with the IMSBC Code and local requirements when carrying cargoes liable to liquefy.
Liquefaction Risk
Iron ore fines meeting the relevant particle-size criteria, as described under the IMSBC Code, are classified as Group A cargoes because they may liquefy if shipped with a moisture content above the Transportable Moisture Limit (TML).
Liquefaction can result in rapid cargo shift, severe loss of stability and capsize. Caution is required when loading from Indian ports during and following the monsoon season, where cargo that is stored in open stockpiles or transported by barge may have been exposed to significant rainfall.
Representative sampling can also be difficult, particularly from large or long-established stockpiles. Certificates should therefore only be relied upon where samples are demonstrably representative of the cargo presented for loading.
Precautionary Measures
Members should refer to West’s Notice to Members No. 15 2013/2014 and the Loss Prevention article Carriage of Iron Ore Fines from Goa and other west coast ports in India, and ensure that:
- The Managers are notified before agreeing to carry Indian iron ore fines and an experienced surveyor is appointed at the load port. Failure to comply with these requirements may prejudice Club cover.
- Loading does not commence until the Master has received and reviewed the required cargo declaration, moisture content and TML certificates.
- Sampling and testing are representative of the cargo presented for shipment and undertaken by Directorate General of Maritime Administration (DGMA) approved laboratories.
- Cargo sources, stockpiles and individual barges, where applicable, can be identified and matched to the relevant certificates.
- Caution should be exercised where cargo has been exposed to significant rainfall, especially during or following the monsoon season, or where the declared moisture content is close to the TML.
- Cargo condition and weather are continuously monitored, and loading is stopped immediately where wet cargo, free water, doubtful documentation or other safety concerns arise.
- Following significant rainfall, satisfactory evidence is obtained that the moisture content of the cargo remains below its TML before loading resumes.
- A can test is used only as a supplementary check and never as a substitute for laboratory testing.
The Master retains overriding responsibility for the safety of the vessel and should refuse or stop loading whenever there are concerns regarding cargo condition, moisture content, sampling or certification. Commercial pressure must never override safety.
Indian Regulatory Update
The Merchant Shipping (Carriage of Cargoes and Oil Fuels) Rules, 2026, which superseded the 1995 Rules, came into effect on 2 September 2026. They reinforce India’s implementation of SOLAS and the IMSBC Code and clarify responsibilities throughout the cargo chain.
For cargoes liable to liquefy, Members should note that the 2026 Rules mandate:
- Shippers must provide the Master, sufficiently in advance of loading, with accurate cargo information and the required moisture content and TML certificates. For Group A cargoes, certificates must be signed and issued by an entity or laboratory approved by the DGMA.
- Sampling and testing must be representative of the cargo presented for shipment and carried out in accordance with approved procedures. The Rules include requirements for the approval of marine laboratories, including those undertaking testing of iron ore fines.
- Ports and terminals to cooperate with the vessel in planning and safely conducting cargo operations. An agreed loading/unloading plan should be followed and cargo operations effectively monitored.
- The Master must ensure that cargo liable to liquefy is not accepted where its actual moisture content exceeds the TML, unless carried in a ship specially constructed or fitted for such cargo. Loading should also remain within the vessel’s structural and stability limitations.
- Cargo operations should be continuously monitored, with loading suspended where cargo condition, documentation, weather exposure or other circumstances give rise to safety concerns.
- DGMA authorised surveyors may verify compliance, including cargo documentation, sampling and testing arrangements and the conduct of cargo operations.
The 2026 Rules should be read in conjunction with SOLAS, the IMSBC Code and any port-specific requirements imposed by the regional Mercantile Marine Department of the DGMA.
For further advice, please contact the Loss Prevention Department at LPQueries@westpandi.com.