IMO CCC 10: Interim guidelines for ammonia and hydrogen as fuel

The 10th session of the IMO Sub-Committee on Carriage of Cargoes and Containers (CCC 10) was held from 16 to 20 September 2024. CCC 10 agreed on interim guidelines for use of ammonia as fuel, completed the review of the IGC Code, and revised recommendations on entering enclosed spaces.

Technical News 21

Relevant for ship owners and managers, fuel and cargo tank manufacturers and yards.

Meeting highlights

  • Finalized work on interim guidelines for use of ammonia as fuel.
  • Continued work on interim guidelines for use of hydrogen as fuel and on interim guidelines for use of low-flashpoint fuels.
  • Completed review of the IGC Code.
  • Worked on amendments to the IMSBC and IMDG Codes.
  • Completed revised recommendations for entering enclosed spaces aboard ships.
  • Agreed on a work plan to address loss of containers at sea.

Amendments to the IGF Code and development of guidelines for alternative fuels and related technologies

CCC 10 finalized interim guidelines for the safety of ships using ammonia as fuel. The guidelines include functional requirements for all sections. Due to time constraints, detailed provisions could only be developed for parts of the guidelines. For the remaining parts the principles of the IGF Code should be taken into consideration. 

CCC 10 also continued work on the interim guidelines for the safety of ships using hydrogen as fuel, agreeing on functional requirements for all sections of the guidelines, and on certain fundamental design principles. Work on the interim guidelines will continue in a Correspondence Group aiming for finalization in 2025. 

The interim guidelines for use of oil fuels with a flashpoint between 52°C and 60°C as fuel were not discussed, but work will, if time permits, continue in a Correspondence Group reporting to CCC 11 in 2025.  

Proposals for amendments and Unified Interpretations to the IGF Code were not considered in detail at CCC 10. They will be discussed by a Correspondence Group and further considered at CCC 11 in 2025.

Review of the IGC Code 

CCC 10 completed the review of the IGC Code, agreeing on the following key items applicable for all ships:

  • More details to be provided on the IGC Code Certificate for vessels using Ch.19 products only as fuel. The fuel product, when carried in dedicated gas fuel deck tanks, shall be carried with location requirements as for a cargo. However, it will not impact damage stability requirements.
  • New definitions like essential safety functions; gas-tight, integrated systems; and reversionary control.
  • Water spray on vertical surfaces and for structures not having a clearly defined horizontal or vertical surface; spacing of nozzles protecting lower areas may take account of anticipated rundown from higher areas.
  • Decreased ventilation requirements possible where hold spaces and cofferdams accessed shall be provided with ventilation not less than the capacity of 2 air changes per hour, compared to originally 8 air changes for fixed installations
  • Alternative, equivalent function testing of high-level alarms, other than raising the cargo liquid level, may be accepted.
  • Ch.15 related to filling limits has been completely rewritten. A requirement for to prevent/avoid vapour pockets for increased filling above 98% has been removed. Increased filling on cargo tanks with MARVS on 0.07 MPa can only be performed on a case-by-case basis.
  • Ch.16 is now updated with detailed requirements for both LPG and ethane as fuels.
  • Requirement for double block and bleed on inert lines connected permanently to gas fuel lines.
  • Liquefied CO2 is merged to one product name only and has been identified as toxic for the purpose of the IGC Code only. 
  • Updated table of shutdown-related system functions in Ch.18.

The following was agreed, applicable for ships constructed on or after 1 January 2028:

  • Access requirements within cargo areas.
  • Updated fatigue verification criteria for type C tanks if found relevant.
  • Updated requirements for emergency shutdown (ESD) valves close to the tank, allowing this regardless of tank pressure.
  • Updated material requirements for cargo piping in salt-laden atmospheres. 
  • Updated requirements for cold and hot surface protection of cargo pipes. 
  • A two-phase flow vent system is mandatory on tanks above 0.07MPa if the vessel does not use the pressure relief valves (PRV) set point as a reference temperature related to the filling limit.
  • Detailed hold space and inter-barrier space overpressure relief requirements. 
  • Additional requirements for overflow protection where both high-level alarms will be required independently from the level gauging.

A Correspondence Group may be established, pending a decision by MSC, to consider the development of interim guidelines for the use of ammonia cargo as fuel. 

The complete amendment proposal will be further considered by MSC 109 in 2024, aiming for adoption in 2025 and entry into force on 1 January 2028. 

Safety of personnel entering enclosed spaces on board ships 

CCC 10 completed a revision of Resolution A.1050(27) “Revised Recommendations for Entering Enclosed Spaces Aboard Ships”, which will be forwarded to MSC 110 in 2025 for approval. 

Measures to prevent the loss of containers at sea

CCC 10 agreed on a work plan to address harmonized performance standards for lashing software and the development of measures to prevent the loss of containers at sea. No technical issues were discussed in detail, and a Correspondence Group was established to work on these matters, reporting to CCC 11 in 2025. 

Amendments to the IMSBC Code and supplements  

CCC 10 discussed proposals for improving and amending MSC.1/Circ.1264 regarding the safe use of pesticides for fumigation of cargo holds. The matter was forwarded to Editorial and Technical Group (E&T) 41, to be held in the week after CCC 10, for finalization.

The following topics were discussed and forwarded to E&T 41, for consideration and implementation in the 08-25 amendment of the IMSBC Code:

  • Deletion of the alternative that allows entering a cargo hold for temperature measurement from the schedule for UN 2793 FERROUS METAL BORINGS, SHAVINGS, TURNINGS or CUTTINGS. 
  • Re-classification of fish meal of group B as MHB (SH) and class 9.
  • New individual cargo schedules for aluminium sulphate granular, apatite concentrates, asphalt granulates, crushed granodiorite (coarse), ferric sulphate granular, fish meal of group C, pea protein concentrate pellets, phosphate rock fines (uncalcined), tuff (coarse) and untreated incinerator bottom ash (U-IBA).
  • Introduction of the apparent density as safety criteria for DIRECT REDUCED IRON (A).
  • Harmonization of the segregation table for MHB cargoes and dangerous goods in packaged form with the table in the IMDG Code.

The 08-25 amendment to the IMSBC Code is expected to be adopted by MSC 110 in 2025.

The following topics were discussed and forwarded to E&T 41 for consideration and to provide advice to CCC 11:

  • Risk of oxygen depletion of mineral concentrates.
  • IACS Unified Interpretation on ventilation requirements for DIRECT REDUCED IRON (D).

Amendments to the IMDG Code and supplements

Various topics were discussed for implementation in a future amendment of the IMDG Code, such as:

  • Review of column 17 of the dangerous goods list regarding the possible deletion of unnecessary text. The matter will be further discussed at E&T 42 in spring 2025.
  • The stowage provisions for vehicles were discussed and will be further worked on at CCC 11.
  • Risk-prevention-related areas in connection with containership safety extracted from EMSA’s CARGOSAFE study were discussed and will be further worked on at
    CCC 11.
  • Special provision for the degree of filling of portable tanks was discussed. The matter will be further discussed at
    E&T 42.

Recommendations

DNV recommends that customers note the development of interim guidelines for use of ammonia as fuel, as well as the complated review of the IGC Code. 

As CCC is a Sub-Committee, all decisions concerning rules, regulations and dates are subject to further consideration and approval by the Maritime Safety Committee (MSC). 

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