201322 Iron ore fines that may contain DRI (C)

Edited from UK P&I Club LP Bulletin 859 - 12/12

The process of manufacturing Direct Reduced Iron (DRI) from iron ore and the subsequent hot briquetting procedures generate unwanted by-products in the form of dust and broken chips during most of the stages. Some manufacturers recover these materials and offer them for shipment.

In the 2009 edition of the IMSBC Code, such a material is listed as DIRECT REDUCED IRON (C) (By-product fines), and the definition of the material is based only on its production, particle size and density, without reference to the metallic iron or moisture content.

Despite extensive publicity and in clear violation of regulations, shippers continue to use misleading names for patently DRI cargoes (e.g. re-oxidised iron fines, iron fines (blend), iron ore pellet chips, oxide fines, pond fines, sludge fines, remets, clarifier slush and dust, spent iron fines and lodos etc.). Other similar cargoes include DRI in the description, but are offered on the basis that they are not DRI (C) and therefore do not need to be carried in accordance with the DRI (C) Schedule of the Code. Mariners should also be aware that, even if the cargo offered is not DRI (C), in some instances, stockpiles of different DRI cargoes are usually located in close proximity in the open, and non DRI cargo can become contaminated with DRI fines. DRI (A) and (B) cargoes typically contain about 85% metallic iron, whereas in blends containing DRI (C), it can be as low as1% or 2%. Such blended cargoes should be regarded as the hazardous commodity DRI (C) and be carried in accordance with the provisions of the Code.

Precautions before loading
Cargo blends containing DRI (C) can be identified by their chemical composition, details of which must be requested. The chemical composition must include the total iron content (Fe), the metallic (or free) iron content and the moisture content. This information should preferably be supported by a certificate from an independent testing laboratory and must relate to the cargo that is being offered for shipment. The certificate should state the method and standards that have been followed when obtaining the samples that have been tested (preferably ISO 10835: 2000) and the standards that have been followed to determine the metallic iron content (preferably BS ISO 5416: 2006). The date on which the sampling took place should also be checked to ensure relevance.

Having identified the cargo as DRI (C), the following documents/ evidence/information must be provided to the Master:
1 A certificate issued by a competent person recognised by the National Administration of the port of loading, stating that the cargo, at the time of loading, is suitable for shipment; that it conforms with the requirements of this Code;
2 The moisture content is less than 0.3% and the temperature does not exceed 65°C;
3 The cargo meets the loading criteria in regards to ageing and material temperature;
4 Comprehensive information on the cargo and safety procedures to be followed in the event of emergency;
5 After loading, a certificate shall be issued by a competent person recognised by the National Administration of the port of loading, confirming that throughout the whole consignment of fines and small particles, the moisture content has not exceeded 0.3% and the temperature does not exceed 65°C.

Exemptions from the requirements of the IMSBC Code

For cargoes that are listed in Appendix 1 of the IMSBC Code, such as DRI (C), Section 1.5 allows a competent authority to authorise any other provision or exemption if satisfied that such alternative provision is at least as effective and safe as that required by the Code. Three competent authorities are recognised: the Port State of departure, Port State of arrival and the Flag State. Prior to any shipment covered by such an exemption, the recipient of the exemption must notify the other competent authorities concerned, who may or may not accept that exemption. For cargoes that are offered for transport in accordance with an exemption as described above, the loading, carriage and safety procedures must be clearly stated. In particular, the Master must be advised of the ventilation rates and durations for each cargo space; the required standard of explosion protection of the ventilation fans; details of the arrangement of ventilation ducts into the holds; the method and
frequency of monitoring the hydrogen concentrations in each cargo space; the method and frequency of monitoring the cargo temperatures in each cargo space; the criteria defining an emergency; the procedures to follow in the event of emergency; shipper’s contact numbers in the event of emergency; and the procedures to follow before and during discharge.

The IMSBC Code schedule for DRI (C) sets maximum allowable moisture content as 0.3% for carriage. When cargoes are offered with moisture content in excess of this, then they are not compliant, and at higher moisture contents they may additionally pose a realistic risk that they may liquefy in a similar manner to certain iron and nickel ore cargoes. Therefore, any Declaration relating to such cargoes must classify the material as Group A and B and the accompanying test certificate(s) must state the Transportable Moisture Limit (TML) and actual moisture content (MC) of the shipment.