Bulletin No.: 06/1997
Date (Y-M-D): 1997-06-05
Subject: Cargo Matters - Fumigation
This bulletin draws attention to fumigation procedures for vessels in Canadian ports or vessels undergoing in-transit fumigation. Personnel involved in fumigation of vessel empty cargo holds or grain/cargoes inside cargo holds include fumigators, ships crews, agents, stevedores, shippers, and cargo interests.
It is important that all of the aforementioned parties are familiar with the responsibilities that may be assigned during such procedures. Recent information has indicated not all parties concerned are fully informed or aware of the responsibilities and hazards associated with such fumigation. The following draws attention to requirements for such procedures:
- The regulations for fumigation on board ships in Canada are the "Ship Fumigation Regulations", SOR/DORS/89-106. (Note also bulletin 13/93.)
- The use of fumigants allowed for use on ships is also covered by the Health Canada Pest Control Products Act. Under the PCP Act, all space fumigants are RESTRICTED products and can only be sold and used by appropriately provincially licensed applicators for those uses covered by the applicator's certification. Trained personnel must work under the direct supervision of the certified applicator. As part of the (PCP Act) label improvement program, a "Canadian Applicators Manual" (Phosphine Gas) is under development and will be available later in 1997.
- The requirements, qualifications and responsibilities for persons acting as fumigator in charge on board ships are set out in the Ship Fumigation Regulations, and fumigators must be fully familiar with these requirements.
- Transport Canada Marine Safety (formerly Canadian Coast Guard Ship Safety) is the department responsible in the application of the Ship Fumigation Regulations and port wardens or steamship inspectors from this department will enforce strict compliance with the requirements of these Regulations.
- These Regulations are based on the requirements of the International Maritime Organizations (IMO) "Recommendations on the Safe Use of Pesticides in Ships". These recommendations are intended as a guide to competent authorities, mariners, fumigators, fumigant and pesticide manufacturers and others concerned. They were first circulated in 1971 and revised by the Maritime Safety Committee in 1984, 1993, 1995 and recently in 1996. One of the highlights of the 1996 revision is the addition of a new Annex 5 which contains a " Model Checklist for In-Transit-Fumigation with Phosphine ". A copy of the checklist is attached as contained in MSC/Circular 746.
In recent times grain vessels with in-transit-fumigation commenced in Great Lakes ports were inspected on arrival in Canada and deficiencies were noticed which could have had serious consequences and included items such as:
- Leakage of fumigant from openings in the hatch coamings that should have been closed and sealed.
- Leakage was not detected by crew members, and detection equipment placed on board the vessel was not used.
- Leakage of fumigants from holds which could not be found or stopped which indicated insufficient preparation (sealing) of hold to be fumigated or even the (un) suitability of the vessel for such procedures.
- Crews on board some vessels were not informed or familiar enough about fumigation.
- Faulty equipment on board such as wrong type of filters for respiratory equipment. (Note for fumigation-in-transit commencing in Canada self-contained breathing apparatus are required).
- Visitors boarding vessels in Canadian ports prior to being declared safe by a competent person.
- Fumigation of cargo holds or cargo should only be carried out by qualified persons following the required safety procedures. Vessels not in compliance may be subject to inspections and delays and shipowners and masters are urged therefore to be fully familiarized with and to follow requirements and recommendations. It is further recommended to include the use of procedures outlined in the model checklist on board ship.
Fumigation of empty cargo holds - Methyl Bromide
- In all cases where an empty space is fumigated on board a ship, non-essential crew members shall disembark until the vessel is declared gas free.
- Agents, shippers, terminal operators, shipowners, mariners, etc shall ensure that adequate time is available to ensure the vessel is made gas-free and can be declared so by the fumigator.
- Where inspection (s) of holds are required after fumigation of empty cargo spaces those involved ie agents, inspectors, fumigators, masters, etc shall ensure adequate liaison is carried out in regards to gas freeing. Safe enclosed spaces/holds entry procedures must be followed before entry by any such personnel.
- It should be noted that fumigation of cargo in a cargo hold of a ship with Methyl Bromide is no longer recommended under the IMO recommendations as it is not possible to adequately ventilate due to absorption of this gas by the cargo and subsequent desorption. (See Annex 1, D of the Recommendations "In Ship In-Transit Fumigations with Methyl Bromide should not be carried out".)
The 1996 Edition of the IMO Recommendations is available from IMO Publications Section, 4 Albert Embankment, London, SE1 7SR at telephone number 44-0-171-735-7611 or fax 44-0-171-587-3210 or from a distributor of IMO Publications in Canada or USA.
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