A merican Club Circular No. 10/25 1 MARCH 28, 2025 CIRCULAR NO. 10/25 TO MEMBERS OF THE ASSOCIATION Dear Member: CARRIAGE OF DIRECT REDUCED IRON (DRI) Introduction Direc t reduced iron (DRI) in various forms is described in the International Maritime Solid Bulk Cargoes (IMSBC) Code, (the Code). The latest addition, which becomes a mandatory part of the Code from January 2025, is the entry for the Type D, by-product fines with a moisture content of at least 2%. This entry runs over multiple pages and contains large amount of important information and guidance. In this Circular, the main points of the Type D entry are summarized, and, where appropriate, additional guidance and observational notes have been added. This Circular has been prepared for the International Group of P&I Clubs (IG) in conjunction with Dr J H Burgoyne & Partners LLP (Burgoynes) with input from INTERCARGO. Explanatory notes provided by Burgoynes are included in blue text within the body of this Circular. It should be noted that this Circular is for guidance only and the relevant entries from the IMSBC Code, which are appended to this Circular, remain the primary source of carriage requirements which should be relied upon. Bac kground Direct reduced iron (DRI) is formed by passing hot reducing gases, such as hydrogen, methane and carbon monoxide, ov er iron ore, which is usually in the form of lumps or pellets. This produces a highly porous iron material which has a very large internal surface area available for re-oxidation. The principal hazards associated with DRI are its ability to undergo self-heating through oxidation and its ability to generate hydrogen from reac tion with water/moisture. When stowed within the confines of a cargo hold, hydrogen produced by reaction with water can form an explosive atmosphere inside the hold, presenting a risk of explosion. The principal forms of DRI are Type A (hot-molded briquettes, DRI (A)) and Type B (pellets, DRI (B)), but fines are also generated during manufacture and handling (via abrasion) and from filtering particles out of off-gases. Fines are not generally suitable for inclusion with Types A and B, so these are screened out and handled separately. Formerly, fines would be shipped under DRI Type C (DRI (C)), but the IMSBC Code entry for this type defines the moisture level of the cargo as not exceeding 0.3%. That low moisture level is often A merican Club Circular No. 10/25 2 not feasible due to handling practices for fines, such as outdoor storage and handling being subject to rain. In addition, the Code calls for DRI (C) cargoes to be shipped under inert gas, as for DRI (B). Inert gas is intended to exclude air (oxygen), thus limiting self-heating due to reaction with oxygen. However, as set out below, self-heating is typically not the main issue with fines. Instead, the prevalent risk is the generation of flammable hydrogen gas due to reaction with water, leading to a scenario where the holds need to be ventilated in order to maintain low hydrogen concentrations, below the lower explosive limit plus a margin of safety. With the production of DRI (C) fines having a moisture content not exceeding 0.3% being difficult to achieve, in the IG Clubs’ experience shippers often sought to ship such cargoes under exemptions in accordance with section 1.5 of the IMSBC Code. Those exemptions often sought to avoid shipment under inert gas, instead using mechanical ventilation as an alternative arrangement, but this proved diff