Iron Ore Fines From India: A Fatal Bulker, the Moisture Limit and the Master's Right to Say No

What We Know, And What We Do Not

The Club says a bulk carrier was lost with fatalities in the Bay of Bengal after loading iron ore fines at Paradip, and was on its way to the next port. It does not name the ship, give the date or state the cause, and neither will we. What it does is use the casualty to restate why this cargo needs particular caution at Indian loading ports.

Why These Cargoes Are Dangerous

Iron ore fines that meet the particle-size criteria are Group A cargoes under the IMSBC Code: cargoes that may liquefy if shipped with a moisture content above their Transportable Moisture Limit (TML). Liquefaction can cause a rapid cargo shift, loss of stability and capsize. There may be little warning.

The Club points to Indian loading ports during and after the monsoon, particularly where cargo in open stockpiles or on barges has been exposed to heavy rain. Representative sampling is hard, especially from large or long-established stockpiles, so a certificate is only as good as the sample behind it.

What The Club Wants Members To Do

1. Tell the managers before agreeing to carry Indian iron ore fines, and appoint an experienced surveyor at the load port. Failure to do so may prejudice cover.
2. Do not start loading until the master has reviewed the cargo declaration, moisture content and TML certificates.
3. Confirm the sampling and testing were representative and carried out by laboratories approved by the Indian authorities.
4. Trace the cargo to its source, stockpile and individual barges, and match each to its certificates.
5. Be cautious if the cargo has had significant rain exposure, especially during or after the monsoon, or if declared moisture is close to the TML.
6. Monitor cargo condition and weather throughout. Stop loading immediately if you see wet cargo, free water, doubtful documents or other safety concerns.
7. Re-verify after heavy rain, with satisfactory evidence moisture is still below the TML, before resuming.
8. Use the can test only as a supplement, never as a substitute for laboratory testing.
9. Use the master’s overriding authority. Refuse or stop loading whenever you have concerns about cargo condition, moisture, sampling or certification. The Club states plainly that commercial pressure must never override safety.

The Indian Rules Behind It

The Club notes that India’s Merchant Shipping (Carriage of Cargoes and Oil Fuels) Rules, 2026 took effect on 2 September 2026, replacing the 1995 rules. Among other things, shippers must provide accurate cargo information and certificates in advance, laboratories testing iron ore fines must be approved, certificates for Group A cargoes must be signed and issued by an approved entity, and authorised surveyors may verify documents, sampling, testing and operations.

The Test That Matters

A Group A cargo is different from most bulk cargoes in one respect: the ship cannot see whether it is safe. A hold of fines just under the limit looks just like a hold just over it. This is why the Master’s review of the paperwork is not a formality. It is the only line of defence ashore, and the can test, which can show a cargo is clearly wrong, can never show it is right.

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