Published: 1 August 2015

The Club has recently noted a number of incidents involving bulk carriers.  The majority of these claims fall into two types.  The first is where the loading, stowage and securing of break bulk cargoes has been inadequate and has led to cargo shifting and stows collapsing.  As well as damage to the cargo this has also led to problems with the stability of the ship.  The second type is where vehicles have been incorrectly carried as non-dangerous cargo.  In this article, we look at examples of both types of incidents and aim to provide guidance as to how such incidents can be avoided.

Members are reminded that cargo must always be loaded, stowed and secured in accordance with the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) and the ship’s cargo securing manual (CSM).

  1. Problems identified with respect to improper stowage and securing:

There have been a number of incidents where vehicles and heavy project cargoes have been stowed on top of bagged cargo which does not always provide a firm enough base for safely stowing or securing the heavier cargo.

Other cases have shown that wheel-based cargoes are often  secured to other cargo and not to the ship as they should be in order to comply with the ship’s CSM.  Cargoes of vehicles are often lashed to non-approved lashing points on bulkheads and sometimes they are even lashed to each other.  Lashings are not always checked and tightened regularly and the failure of any one lashing or lashing point in the chain could mean that vehicles in the stow shift.

It is often the case that insufficient dunnage, chocking and shoring is provided for vehicles, steel coils, project cargo and bagged cargoes when stowed together.

The crew should be aware of the following prior to carriage:

    • A list of the proposed cargo must be obtained from the shipper / charterer, including any stowage or lashing requirements and restrictions (SOLAS, Chapter VI, Regulation 2 and CSS Code sub-chapter 1.9).
    • A risk assessment must be undertaken to assess the carriage considerations, cargo care, stowage, lashing requirements and any limitations.
    • Any ship, including bulk carriers, that carries break-bulk or general cargo is required to carry an approved and up-to-date CSM, drawn up to a standard at least equivalent to the IMO guidelines and which is appropriate for all the cargoes to be carried on board that ship. If required, the CSM should be updated to make sure that it covers the cargo proposed for carriage.
    • Responsibilities for stowage and lashing should be clarified and agreed in the charterparty in line with the ship’s CSM, and appropriate instructions issued to the master.
    • If required, a suitable port captain or surveyor should be appointed to assist the master.

Pre-loading checks:

    • Any additional lashing points in the cargo holds or on deck must be approved by the appropriate flag state administration.
    • Suitable dunnage and lashing equipment must be provided, taking into account the dimensions and stability of the cargo, the expected weather conditions en-route and the requirements of the ship-specific CSM, the CSS Code and/or SOLAS, as appropriate.

During loading:

    • All loading and lashing must be supervised by the ship’s staff to ensure that the cargo is stowed in compliance with the approved loading and lashing plan.
    • Appropriate lashings should be attached to approved lashing points.
    • Dunnage, chocking and lashing must be checked and verified prior to signing any relevant documentation.


    • Regular checks of the cargo and lashing must be carried out, particularly prior to and after any heavy weather and lashings must be tightened as required.
    • If any damage is noted, the owners/managers, P&I and other relevant parties must be notified promptly.

At the discharge port:

    • The discharge operation should be monitored by the ship’s staff and any damage noted and signed for.
    • Photographs and other evidence should be obtained and retained for investigation.
  1. The safety issues identified with the carriage of vehicles as non-dangerous cargo

The carriage of vehicles is covered by the IMDG Code UN No 3166 (including special provisions 961 and 962) which allows motor vehicles with fuel in their tanks for their own propulsion to be carried in specially designed ‘vehicle spaces’.  If certain criteria are met (fuel tanks being empty and installed batteries being protected from short circuit) then vehicles can be accepted as non-dangerous goods, otherwise the vehicles must be declared as Class 9 dangerous goods.

SOLAS regulation II-2/3.49 defines ‘Vehicle Spaces’ as:  ‘cargo spaces intended for carriage of motor vehicles with fuel in their tanks for their own propulsion.’

Points to note:

    • When vehicles or dangerous goods are carried in general cargo holds or on deck, as class 9 UN No 3166 dangerous cargo, the stowage instructions of the IMDG Code shall be followed and stowage shall be in line with the ship’s certificate of fitness to carry dangerous cargo (per SOLAS Reg. II-2/10).
    • Bulk carriers do not usually have fixed fire extinguishing systems fitted in cargo holds, unless they are designed for the carriage of dangerous cargoes and provided with a Document of Compliance for the Carriage of Dangerous Goods.
    • A ship engaged in the carriage of dangerous goods in any cargo spaces shall be provided with a fixed carbon dioxide or inert gas fire-extinguishing system complying with the provisions of the Fire Safety Systems Code (or equivalent).

Securing vehicles:

    • They should be secured to the ship by lashings made of material with strength and elongation characteristics at least equivalent to steel chain or wire.
    • If carried as part cargo, they should be stowed close to the ship’s side or in stowage positions which provide plenty of securing points of sufficient strength, or they should be block stowed from side to side in the cargo space.
    • They should be stowed in a fore-and-aft direction rather than athwartships. If stowed athwartships, additional securing of sufficient strength may be necessary.
    • Brakes should be set and the wheels blocked to prevent shifting.

Full details of how to secure vehicles is covered by the CSS Code, Annex 4.


The master and crew must ensure that they have a comprehensive working knowledge of the stowage and securing capabilities of their ship and that they carry out risk assessments for all cargoes carried.  Particular attention needs to be given to the carriage of all break bulk cargoes.  Where vehicles are being carried, proper consideration needs to be given to the potential fire risk on board.  This will require full appraisal of fire hazards, including the fuel tanks and batteries of the vehicles.