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E News - Transportable Moisture Limit (TML) Testing For Bulk Cargo Transport: Latest Legislation Changes

E News - Since 1988, liquefaction of solid bulk cargoes in transit has been identified as the possible cause of over 20 incidents of bulk carriers capsizing. The resulting loss of lives and resources called for a review of the International Maritime legislation regarding the export of metal ores and concentrates.

Over the last few years ATC Williams has worked in its NATA accredited testing laboratory towards further developing and refining the Flow Table and Proctor/Fagerberg procedures as part of the Transportable Moisture Limit (TML) test that is required to characterise the liquefaction potential of transported materials

This e-newsletter has been created in association with Dr. Maria Davoren to summarize the changes in legislation, as a means of increasing your understanding and to give you appropriate contacts should you have further questions.

Maria is Principal Consultant & Director at Davoren Environmental Pty Ltd - a niche environmental consulting firm which specializes in the hazard classification of solid bulk cargoes for transport. With several years of experience working with a wide range of cargo types i.e. ores, concentrates, coals, mineral sands etc. Maria has detailed knowledge of the relevant regulations that apply and how to conduct the appropriate hazard assessment required for classification and compliance.

John Walker is the Laboratory Manager at ATC Williams and is responsible for transportable moisture limit (TML) test work as well as standard soils tests and calibrations, complex in-house test methods on mine tailings, daily running of the laboratory and quality assurance activities such as internal audits and proficiency testing. John has over 25 years’ experience in laboratory supervision and management.

Summary of the code changes and what is becoming mandatory (group A and B)

The IMSBC Code is subject to updates every two years to keep pace with the nature and variety of solid bulk cargoes presented for shipment, as well as developments in the safety standards of transporting established solid bulk cargoes. The most recent edition of the IMSBC Code (2016 Edition) is amended by resolution MSC.393(95) (IMO, 2015), and incorporates amendment 03-15, which may be applied from 1 January 2016 on a voluntary basis, anticipating its envisaged official entry into force on 1 January 2017.


  • Group A – Cargoes that may liquefy

1. Updates relevant to Group A cargoes in the IMSBC 2016 edition, is the incorporation of the new subsection 1.4 in Appendix 2 – Modified Proctor/Fagerberg Test Procedure for Iron Ore Fines.

  • Group B – Chemical Hazards
Two relevant updates:

1. Amongst the adopted amendments (03-15) specific changes are included in Section 9 of the Code Material Hazardous only in Bulk (MHB).

According to the adopted amendments:

a. Where a cargo is found to meet one or more of the chemical hazards for MHB designation, a notational reference for each hazard must be included in the “Class " cell of the characteristics table for each individual schedule for cargoes classified as MHB.

b. Where deviations from the chemical hazards described in 9.2.3.2 to 9.2.3.7 of IMSBC Code have been determined as Other Hazards (OH)), they shall be properly recorded with justifications.

c. Other Hazards are to be included in the section for Hazard in the individual schedule.

2. Amongst the adopted amendments (03-15) are included specific changes to Sections 4 and 14 of the IMSBC Code relating to classification of solid bulk cargoes as harmful to the marine environment (HME) under MARPOL Annex V.

For further information on how to classify your solid bulk cargo to address the new MHB designation requirements or for classification relating to MARPOL Annex V (HME) or for any other maritime transport compliance query please contact Maria by email at maria@davorenenvironmental.com.au or telephone +61 4 4707 9022.

Moisture content below the flow moisture point (below)


Moisture content above the flow moisture point (below)


Dr Maria Davoren is Principal Consultant & Director at Davoren Environmental Pty Ltd - a niche environmental consulting firm which specializes in the hazard classification of solid bulk cargoes for transport. After several years of working in this area and experience with a wide range of cargo types (ores, concentrates, coals, mineral sands etc.), Maria has detailed knowledge of the relevant regulations that apply and the ability conduct the appropriate hazard assessment required for classification and compliance.

Davoren Environmental service include:

  • Ensuring clients understand the relevant regulations that apply to their product and identify any additional testing requirements and coordinate that testing with both national (NATA) and international test facilities.
  • Conducting a hazard assessment on the product(s) using the latest scientific principles and assessment tools to deliver a comprehensive and accurate classification against applicable transport regulations.


Over the years ATC Williams has developed several specialised laboratory test procedures relating specifically to the ever growing mining industry and its demand for optimised, cost effective designs and increased OH&S requirements encompassing all aspects of mining.

The Transportable Moisture Limit of cargo is the maximum gross water content by weight that liquefiable solid bulk cargo may contain during transport without risk of liquefaction. The liquefaction phenomenon can see materials, most commonly fine grained ores and mineral concentrates, transform from a semi solid state to become plastic or to behave as a fluid.

Liquefaction can occur with the compaction of cargo under its own weight and through the vibration of both the ship’s engine and the wave motion that occurs during a voyage, with poor weather conditions or high seas sometimes aiding this process. When cargo suddenly liquefies it can greatly reduce the stability of bulk cargo ships and for decades this was one of the main causes of incidents at sea.

For ATC Williams TML Testing information please follow this link:

http://atcwilliams.com/projects/transportable-moisture-limit-testing

For further information please contact:

John Walker on 0424 831 263 or via email at johnwa@atcwilliams.com.au

Charles Vuillier on 0435 087 562 or via email at charlesv@atcwilliams.com.au