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Seed cake cargoes are repeatedly being declared as low-risk Group C cargo, when the shipper's own laboratory results actually show they should be Group B — usually Seed Cake UN1386(b), a Class 4.2 (self-heating) cargo. The misunderstanding arises when the IMSBC Code is misinterpreted.
These misunderstanding usually surround how “extraction method” is defined, and when self-heating testing is actually required.
A Seed Cake is the material left over once oil has been extracted from oil-bearing seeds. A common example is Soya Bean Meal (SBM) which is formed when the oil is removed from whole soya beans.
Most seed cake cargo is shipped as either a meal or a pellet; however, the Code refers to a wide range of seed cake forms.
Oil can be extracted from the seed by either mechanical means or by using a solvent.
Solvent extraction
Oil is removed using chemical solvents. Before shipment, the cargo must be checked to confirm it is substantially free of residual solvent which is flammable.
Mechanical extraction
Oil is removed by crushing / pressing (“expelling”) the seed. No solvents are used.
Group B seed cakes can self-heat because of oxidation of the oil left in them. So, the cargo's oil content and moisture content are what determine the propensity for the cargo to self heat.
The extraction method determines the amount of residual oil remaining. For some mechanically expelled seed cakes, the cargo is not automatically safer because of the lack of solvent. In fact, it can have a higher residual oil content, hence schedule UN1386 (a), which have been mechanically extracted and have a comparatively high oil content.
If the oil and moisture content falls inside certain limits, the cargo is Class 4.2 and therefore automatically Group B.
The last two schedules exist so that every seed cake cargo — not just ones that neatly match UN1386 or UN2217 — is properly tested and checked for self-heating before it is allowed to be declared as the low-risk Group C.
Image Resource - The five IMSBC Code schedules for seed cake
The following illustrates the oil and moisture content of the different seed cake schedules:
NorthStandard has repeatedly seen shippers misapply the Code when classifying seed cake as ‘Seed Cakes & Other Residues of Processed Oily Vegetables, Group C’.
This must not be dismissed as being “just paperwork”; the actions required by the crew while on passage differ depending on whether the cargo is carried as Group B or Group C.
An accurate declaration is therefore essential to voyage safety.
The actual oil and moisture contents of the cargo from the Shipper’s testing certification and described extraction method put it within the UN1386 (b) schedule.
The UN1386 (b) schedule lists a small set of named cargoes and oil/moisture combinations that are exempt — meaning they genuinely fall outside Class 4.2 and can be Group C.
Reference: exemptions under UN1386(B)
Solvent-extracted rape seed meal, rape seed pellets, soya bean meal, cotton seed meal and sunflower seed meal (≤4% oil, ≤15% oil and moisture combined);
mechanically expelled citrus pulp pellets (≤2.5% oil, ≤14% combined); corn gluten meal (≤11% oil, ≤23.6% combined); corn gluten feed pellets (≤5.2% oil, ≤17.8% combined); and
beet pulp pellets (≤2.8% oil, ≤15% combined).
In this case, the cargo did not fall within the exempted list. It therefore indicated that it fell within the UN1386 (b) schedule characteristics.
Separately, the UN1386 (b) schedule's own description is broad — it covers a long list of named products including bran pellets, oil cake, palm kernel, rice bran, mill feed pellets and many more, shipped as pulp, meal, cake, pellets or expellers.
It may be asked why couldn't it be declared as UN2217 instead? But UN2217 only applies to seed cake with oil ≤ 1.5% and moisture ≤ 11%, backed by a shipper's certificate. This cargo's oil and moisture content did not meet that threshold either — ruling UN2217 out too.
✗ ASSUMPTION 1 | ✓ REALITY |
✗ ASSUMPTION 2 “If it tests negative for self-heating, it can't be Group B.” | ✓ REALITY |
If the oil and moisture content and extraction method puts a cargo inside the Class 4.2 zone, it is automatically Group B.
The self-heating (MHB SH) test is irrelevant in that situation and is not even required to be carried out. A “negative” self-heating test cannot override the UN classification.
Loading a cargo known to be misdeclared, without first checking it can be carried under the vessel's Document of Compliance (DOC) for hazardous cargo and that the right procedures are in place, can be treated as imprudent, unsafe or unduly hazardous.
This can put P&I cover at risk. If Members have any doubt, they should contact the Club for assistance.
Masters and operators should exercise due diligence when reviewing cargo declarations: check the oil and moisture content and the extraction method that has been given, and confirm the cargo is correctly categorised under the IMSBC Code before loading starts.
Getting this right at the load port is both a compliance matter and a core part of protecting the safety of the voyage and the Member's insurance position.
Disagreements can arise within the charterparty chain when a Master questions what is being loaded. The Code is clear, though: it is the shipper's responsibility to declare the cargo correctly, and that declaration is what guides the Master's actions on passage.
Where there are valid grounds to believe a cargo has not been properly declared, the Master is entitled to a reasonable amount of time to assess the situation and get expert advice, so the cargo is handled in line with the Code both before and during the voyage.
The Master's actions on passage depend entirely on which schedule the cargo falls under — so they should always check the declaration carefully.
When reviewing the shipper’s declaration and accompanying certification, look for:
✓ | What type of seed cake cargo is it? (e.g. soya bean meal) |
✓ | What is the method of extraction — solvent extracted or mechanically expelled? |
✓ | Has the actual oil and moisture content been provided? If not, ask for it. |
✓ | Does the cargo type, extraction method and oil/moisture content match one of the listed exemptions from UN1386 (a)/(b) or UN2217? |
✓ | If not, does the oil and moisture content instead match the requirements for UN1386(b) or UN2217 — meaning it should be declared Group B? |
