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INTERNATIONAL MARITIME
ORGANIZATION (IMO):
SHIPPING CODE UPDATES
Classification Information and
Tools for Compliance
December 2012
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TABLE OF CONTENTS
page
1. Executive Summary …………………………………………………………….……3
2. Summary of IMO Code changes………………………………………………………4
3. Summary of classifications…….. ……………………………………………………..5
4. Summary of classification criteria …………………………………………………….6
5. Manganese ores ……………….……………………………………………………….7
6. Mn ore classification flow chart………………………………………………………..8-9
7. FeMn ferroalloy…………………………………………………………………………10
8. SiMn ferroalloy………………………………………………………………………….11
9. Definitions and Abbreviations………………………………………………………....12
The layout of this document is straightforward and detailed in the table of contents above.
Certain original documents are embedded in the text for reference. Appendices and flow
charts were developed with the assistance of ICF International (http://www.icfi.com/) using
information provided by the IMO, GHS Annexes 9 and 10, the International Council on
Mining and Metals (ICMM), the IMnI and some IMnI members.
The document is on the IMnI website and will be updated as and when new data are
available. Members will be informed of updates and invited to review the latest information
on the IMnI website.
Disclaimer: The International Manganese Institute believes that the information presented is technically correct.
However, IMnI does not represent or warrant the accuracy of the information contained in this document or its
suitability for any general or specific use. The material contained herein is by necessity general in nature; it
should not be used or relied upon for any specific or general application without first obtaining competent advice.
IMnI, its members, staff and consultants specifically disclaim any and all liability or responsibility of any kind for
loss, damage, or injury resulting from the use of the information contained in this publication.
17, rue Duphot – 75001 Paris – France
Tel : +33 (0) 1 45 63 06 34 Fax : +33 (0) 1 42 89 42 92
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1. EXECUTIVE SUMMARY
The aim of this IMnI information pack is threefold:
1. To raise awareness amongst IMnI members of the IMO changes
2. To clarify the classification of known solid bulk cargoes in the manganese industry
3. To provide classification information for IMnI members to retain for presentation to
authorities and other interested parties if requested.
The International Maritime Organization (IMO) has updated its shipping codes to include
hazard assessment in-line with the UN’s Globally Harmonised System for Classification and
Labelling (GHS).
The two relevant Codes (or regulations) that shippers of solid bulk cargoes such as Mn ore
and Mn-ferroalloys must comply with are:

MARPOL Annex V, and

The International Maritime Solid Bulk Cargoes Code (IMSBC),
Importantly, these are not new regulations specifically targeting ores and alloys, but a
refinement of existing shipping codes.
The IMnI and its industry members have used available data for assessment purposes. The
conclusion is that (in the vast majority of cases) Mn ores, FeMn alloys and SiMn alloys are
not harmful to the marine environment.
This does not mean that shippers of these products escape MARPOL Annex V, but the
compliance steps are less onerous, only involving notification of this unclassified status to
the shipmaster and the necessary authorities.
For suppliers of ore/alloy that lie well outside the industry specification norm (impurities, for
example), this guide provides a comprehensive tool and supporting documentation that will
allow you to self-classify. Assistance is available from the IMnI if required.
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2. SUMMARY OF IMO CODE CHANGES
What has happened?
The IMO has updated two of its shipping codes; namely
1. MARPOL Annex V, which has the objective of preventing pollution of the marine
environment by ships from operational or accidental causes, and
2. The International Maritime Solid Bulk Cargoes Code (IMSBC)*, which aims to facilitate
the safe stowage and shipment of solid bulk cargoes (safety of onboard personnel).
Will these changes affect me?
Yes, if you ship solid bulk (including ore, alloy, slag, concentrate and scrap)
No, if you ship in containers, or transport only by land or inland waterway.
When do these changes start?
MARPOL Annex V changes are effective from 1 January 2013.
IMSBC changes are effective from 1 January 2014 on a voluntary basis, becoming
mandatory from 1 January 2015
What must I do for MARPOL Annex V?
First, you must determine if your solid bulk cargo is harmful to the environment according to
the criteria detailed in MARPOL Annex V.
Second, from 1 January 2013, solid bulk cargoes must be declared by the shipper as to
whether or not they are harmful to the marine environment and inform the shipmaster and
competent authorities of the port State of loading and unloading.
*IMSBC code changes are not dealt with in detail in this document as the amendments are mandatory
only from 1 January 2015 (being voluntary from 1 January 2014). The IMnI will provide separate
information on this during 2013.
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3. SUMMARY OF CLASSIFICATIONS
MARPOL Annex V covers the disposal of garbage at sea. Residue/wash water of a cargo
that is harmful to the marine environment can no longer be dumped at sea; instead, it must
be collected at port reception facilities.
The IMnI and its industry members used available data to determine if cargoes are harmful
to the marine environment. This data, including an assessment of peer-reviewed scientific
publications going back some 50 years, was recently used for registration under the EU’s
REACH Regulation as well as for EU-CLP (GHS) notifications.
The following classifications are recommended for the referenced solid bulk cargoes:
Solid Bulk Cargo
Manganese ores
(see flow diagram for individual guidance)
FeMn alloys
(irrespective of C content)
SiMn alloys
(irrespective of C content)
Harmful or not to the marine environment?
Not harmful to the marine environment based on MARPOL
Annex V criteria: Unclassified
Not harmful to the marine environment based on MARPOL
Annex V criteria: Unclassified
Not harmful to the marine environment based on MARPOL
Annex V criteria: Unclassified
An overview of the discharge provisions of the revised MARPOL Annex V (resolution
MEPC.201(62)) is available in the PDF below.
MARPOL V Discharge
Provisions
Detailed evidence of classification (data, literature review etc) does not need to be provided,
but you should retain this guidance pack in case the assessment is queried by the
shipmaster, competent authorities or other interested parties.
Note: a declaration that the bulk cargo is not harmful to the marine environment must be
included in the information required in section 4.2 of the International Maritime Solid Bulk
Cargoes Code (IMSBC) that can be found in the PDF below.
IMSBC Code
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4. SUMMARY OF CLASSIFICATION CRITERIA
Cargo residues are included in the definition of garbage within the meaning of MARPOL
Annex V. Such residues are considered harmful to the marine environment (and subject to
Regulations 4.1.3 and 6.1.2.1 of MARPOL Annex V) if they are residues of substances that
are classified according to the following parameters 1:
1. Acute Aquatic Toxicity Category 1; and/or
2. Chronic Aquatic Toxicity Category 1 or 2; and/or
3. Carcinogenicity2 Category 1A or 1B combined with not being rapidly degradable and
having high bioaccumulation; and/or
4. Mutagenicity2 Category 1A or 1B combined with not being rapidly degradable and
having high bioaccumulation; and/or
5. Reproductive Toxicity2 Category 1A or 1B combined with not being rapidly
degradable and having high bioaccumulation; and/or
6. Specific Target Organ Toxicity Repeated Exposure Category 1 combined with not
being rapidly degradable and having high bioaccumulation; and/or
7. Solid bulk cargoes containing or consisting of synthetic polymers, rubber, plastics, or
plastic feedstock pellets (this includes materials that are shredded, milled, chopped
or macerated or similar materials).
Criteria 1-6 are relevant to ores and alloys; criterion 7 is relevant to bulk scrap that may
contain plastic.
Whilst assessment of criteria 1, 2 and 7 shall be made by 1 January 2013, more time is
available for the other criteria if sufficient data are not available. Assessment of criteria 3, 4,
5 and 6 then has to be made by 31 December 2014, with provisional classification during the
interim.
The outcome of this assessment must be included in the shipping documents provided to the
shipmaster and classification must be notified to the competent authorities of the ports of
loading and unloading.
MARPOL Annex V
Implementation
guidelines
National Authority
Contacts
________________________________________________________________
1) The criteria are based on UN GHS, fourth revised edition (2011). For specific products (e.g. metals and inorganic metal
compounds) guidance available in UN GHS, annexes 9 and 10 are essential for proper interpretation of the criteria and
classification and should be followed.
2) Products that are classified for Carcinogenicity, Mutagenicity, Reproductive toxicity or Specific Target Organ Toxicity
Repeated Exposure for oral and dermal hazards or without specification of the exposure route in the hazard statement.
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5. MANGANESE ORES
The flow diagram (page 8) will lead each supplier through the process of self-classification.
However, based on data for identified major constituent, most, if not all, Mn ores are NOT
classified as harmful to the marine environment according to MARPOL Annex V criteria as
below:
MARPOL Annex V Criteria
Criterion
met?
Comments*
Acute Aquatic Toxicity Category 1
No
Major chemical constituents (such as MnO2,
MnCO3, MnS) do not meet this criterion
Chronic Aquatic Toxicity Category 1 or 2
No
Major chemical constituents (such as MnO2,
MnCO3,, MnS) do not meet this criterion at the
levels normally found in Mn ores
Carcinogenicity2 Category 1A or 1B combined
with not being rapidly degradable and having
high bioaccumulation
No
Major chemical constituents (such as MnO2,
MnCO3,, MnS) do not meet this criterion
Mutagenicity2 Category 1A or 1B combined with
not being rapidly degradable and having high
bioaccumulation
No
Major chemical constituents (such as MnO2,
MnCO3,, MnS) do not meet this criterion
Reproductive Toxicity2 Category 1A or 1B
combined with not being rapidly degradable and
having high bioaccumulation
No
Major chemical constituents (such as MnO2,
MnCO3,, MnS) do not meet this criterion
Specific Target Organ Toxicity Repeated
Exposure Category 1 (STOT RE1) combined
with not being rapidly degradable and having
high bioaccumulation
No
Major chemical constituents (such as MnO2,
MnCO3, MnS) do not meet this criterion
Solid bulk cargoes containing or consisting of
synthetic polymers, rubber, plastics, or plastic
feedstock pellets (this includes materials that
are shredded, milled, chopped or macerated or
similar materials).
No
Mn ore shipments are substantially free of
synthetic polymers, rubber, plastics, or plastic
feedstock pellets
*These chemical substances were registered under the EU-REACH Regulation and the assessment
uses data submitted for the purposes of REACH registration and EU-CLP notification using UN-GHS
(4th Rev) Annexes 9+10 http://www.unece.org/trans/danger/publi/ghs/ghs_rev04/04files_e.html
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Is my Manganese Ore classified as Harmful to the Marine Environment under MARPOL Annex V?
Does your ore cargo contain synthetic polymers,
rubber, plastics, or plastic feedstock pellets?
Identify the general composition of your Mn ore
Yes
Classified as “harmful to the
marine environment” under
MARPOL Annex V
No
No
Does your ore contain any constituents
classified
No
as Aquatic Acute 1 or Chronic 1/2? Such as:
Is
No
T/Dp
Does your ore contain any of the following
constituents present at the concentrations
listed below (if yes, ore classified as CMR
and/or STOT RE 1)2?
No
•
•
Does your Mn ore meet the UN GHS (Rev. 4) classification
criteria as Aquatic Acute/Chronic 1, or Chronic 2 when
applying the following formula (i.e., the summation method) 4?
N
o
Conc. of
Aquatic
Chronic 2
constituent
(M x 10 x Conc.
of Aquatic
Chronic 1
constituent)
Yes
Example:
≥ 25%
Aquatic
Chronic 2
No
N
o
•
•
Aquatic Acute 1
Aquatic Chronic 1 or 2
No
Does your Mn ore constituent
also meet the UN GHS (Rev. 4)
Annex 9 classification criteria
for high bioaccumulation (not
relevant to Mn) AND not
rapidly degradable?6
Classified as “harmful to
the marine environment”
under
MARPOL Annex V
See next page for footnotes
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Does your Mn ore meet the
UN GHS (Rev. 4) Annex 9 & 10
classification criteria (based
on T/Dp data)3 for:
No (or currently
unknown)
Not classified as
“harmful to the marine
environment” for these
endpoints under
MARPOL Annex V
Yes
Yes
Note, other constituents classified as Acute 1 or Chronic 1/2 and present at
0.1%/M also need to be taken into account.5
Asbestos ≥ 0.1%
Pb compounds ≥ 0.1%
Yes
Aquatic
Acute/Chronic 1
≥ 25%
No
Note, other constituents classified as CMR or STOT RE 1
also need to be considered.
Yes
(M x Conc. of Aquatic
Acute/Chronic 1
constituent)
Yes
available for your Mn ore?
Yes
• MnS (classified as Aquatic Chronic 2)
• Pb compounds (classified as Aquatic
Acute/Chronic 1, M = 10)
Yes
data1
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Mn ores that do not meet any of the
MARPOL Annex V criteria should be
shipped according to their current
Schedule.
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Footnotes to the Mn ore flow-chart (page 8).
1
Available Transformation/Dissolution protocol (T/Dp) data must be considered for
classification for environmental hazards under MARPOL Annex V.
2
UN GHS (Rev. 4) provides authorities with the flexibility to select the cut-off
value/concentration limit at which a substance (classified as Repr. Tox 1A) present in a
mixture (i.e., the Mn ore) would trigger classification of the mixture as Repr. Tox. 1A. The
cut-off values/concentration limits are ≥ 0.1 or 0.3% for Repr. Tox. 1. However, no
recommended cut-off value/concentration limits are given in MARPOL Annex V.
3
Annex 9 and 10 (specific guidance on classification of metals and metal compounds) of
the UN GHS (Rev. 4) should be followed.
4
The summation method takes into account all constituents classified for Aquatic
Acute/Chronic Toxicity and in a metals context assumes the free metal ion is the toxic
entity. More weight is given to metal ion entities that are ‘highly toxic’ (Acute/Chronic 1)
and for these entities Multiplication (M) factors are assigned.
5
Presence of Cu-containing chalcopyrite (classified as Aquatic Acute 3 according to EU
CLP criteria) does not impact the classification under MARPOL Annex V since Aquatic
Acute 3 category has not been adopted.
6
UN GHS criteria for classification of metal compounds as not rapidly degradable are not
currently defined (see Annex 9 & 10 of the UN GHS). However, high bioaccumulation
AND not rapidly degradable are potentially relevant to metals like Pb and Hg.
A printable, high resolution version of the Mn ore classification flowchart is available here:
Mn Ore Flow Chart
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6. FERROALLOYS: FEMN (ALL CARBON GRADES)
FeMn does not meet the criteria for classification as harmful to the marine environment
based on the following UN GHS (Rev. 4) hazard endpoints specified in the revised MARPOL
Annex V criteria as detailed in the Implementation Guidelines 2012:







Acute Aquatic Toxicity Category 1; and/or
Chronic Aquatic Toxicity Category 1 or 2; and/or
Carcinogenicity* Category 1A or 1B combined with not being rapidly degradable and
having high bioaccumulation; and/or
Mutagenicity* Category 1A or 1B combined with not being rapidly degradable and
having high bioaccumulation; and/or
Reproductive Toxicity* Category 1A or 1B combined with not being rapidly
degradable and having high bioaccumulation; and/or
Specific Target Organ Toxicity Repeated Exposure* Category 1 combined with not
being rapidly degradable and having high bioaccumulation; and/or
Solid bulk cargoes containing or consisting of synthetic polymers, rubber, plastics, or
plastic feedstock pellets (this includes materials that are shredded, milled, chopped
or macerated or similar materials).
A full review of the FeMn alloy classification assessment can be found in the ICF document
below.
ICF- FeMn and SiMn
classification
* Products that are classified for Carcinogenicity, Mutagenicity, Reproductive toxicity or Specific
Target Organ Toxicity Repeated Exposure (STOT RE) for oral and dermal hazards or without
specification of the exposure route in the hazard statement.
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7. FERROALLOYS: SIMN
SiMn does not meet the criteria for classification as “harmful to the marine environment”
based on the following UN GHS (Rev. 4) hazard endpoints specified in the updated Revised
MARPOL Annex V criteria as detailed in the Implementation Guidelines 2012:







Acute Aquatic Toxicity Category 1; and/or
Chronic Aquatic Toxicity Category 1 or 2; and/or
Carcinogenicity* Category 1A or 1B combined with not being rapidly degradable and
having high bioaccumulation; and/or
Mutagenicity* Category 1A or 1B combined with not being rapidly degradable and
having high bioaccumulation; and/or
Reproductive Toxicity* Category 1A or 1B combined with not being rapidly
degradable and having high bioaccumulation; and/or
Specific Target Organ Toxicity Repeated Exposure* Category 1 combined with not
being rapidly degradable and having high bioaccumulation; and/or
Solid bulk cargoes containing or consisting of synthetic polymers, rubber, plastics, or
plastic feedstock pellets (this includes materials that are shredded, milled, chopped
or macerated or similar materials).
A full review of the SiMn alloy classification assessment can be found in the ICF document
below.
ICF- FeMn and SiMn
classification
* Products that are classified for Carcinogenicity, Mutagenicity, Reproductive toxicity or Specific
Target Organ Toxicity Repeated Exposure (STOT RE) for oral and dermal hazards or without
specification of the exposure route in the hazard statement.
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8. DEFINITIONS AND ABBREVIATIONS
Cargo residues means the remnants of any cargo which remain on the deck or in holds
following loading or unloading, including loading and unloading excess or spillage, whether
in wet or dry condition or entrained in wash water but does not include cargo dust remaining
on the deck after sweeping or dust on the external surfaces of the ship.
Competent authority means any body or authority designated or otherwise recognized as
such for any purpose in connection with this Code.
Consignor means any person, organization or Government which prepares a consignment
for transport.
GHS means the third revised edition of the Globally Harmonized System of Classification
and Labelling of Chemicals, published by the United Nations as document
ST/SG/AC.10/30/Rev.4.
Shipper means any person by whom or in whose name, or on whose behalf, a contract of
carriage of goods by sea has been concluded with a carrier, or any person by whom or in
whose name, or on whose behalf, the goods are actually delivered to the carrier in relation to
the contract of carriage by sea.
Solid bulk cargo means any material, other than liquid or gas, consisting of a combination
of particles, granules or any larger pieces of material, generally uniform in composition,
which is loaded directly into the cargo spaces of a ship without any intermediate form of
containment (this includes a material loaded in a barge on a barge-carrying ship).
CLP: Regulation (EC) No 1272/2008 on the classification, labelling and packaging of
substances and mixtures as amended
DSC IMO: Sub-Committee on Dangerous Goods, Solid Cargoes and Containers
IMO: International Maritime Organization (http://www.imo.org/Pages/home.aspx)
IMDG Code: International Maritime Dangerous Goods Code
IMSBC Code: International Maritime Solid Bulk Cargoes Code
MARPOL 73/78: International Convention for the Prevention of Pollution from Ships,
1973/78, as amended
MEPC: Marine Environment Protection Committee (IMO)
MSC: Maritime Safety Committee (IMO)
SOLAS 74: International Convention for the Safety of Life at Sea, 1974, as amended
Disclaimer: The International Manganese Institute believes that the information presented is technically correct.
However, IMnI does not represent or warrant the accuracy of the information contained in this document or its
suitability for any general or specific use. The material contained herein is by necessity general in nature; it
should not be used or relied upon for any specific or general application without first obtaining competent advice.
IMnI, its members, staff and consultants specifically disclaim any and all liability or responsibility of any kind for
loss, damage, or injury resulting from the use of the information contained in this publication.
17, rue Duphot – 75001 Paris – France
Tel : +33 (0) 1 45 63 06 34 Fax : +33 (0) 1 42 89 42 92
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