Recent cases have highlighted a number of safety and operational concerns connected with the carriage of baled Refuse Derived Fuel (RDF). The cargo is increasingly traded, but its behaviour at sea remains variable and, at times, hazardous. These issues are often linked to limited cargo information and to the absence of an IMSBC or IMDG Code classification. This circular provides an outline of the main hazards and the potential implications for Members.

Background

RDF is produced from mixed municipal and commercial waste after sorting and removal of non‑combustible materials. The remaining fraction can contain a significant biodegradable component and often varies considerably in composition. Moisture levels, storage duration and the condition of the bale wrapping influence how the cargo behaves during transport. Since RDF is not covered by an IMSBC schedule, the Master cannot rely on established reference criteria. Safe carriage depends to a large extent on the accuracy and completeness of information provided by the shipper.

Misdeclaration

Misdeclaration continues to be a recurring issue. Declarations may describe the material in broad terms or compare it to conventional biomass without addressing characteristics relevant to maritime carriage. Details regarding moisture content, storage history, contamination or bale integrity are often absent. When the cargo behaves inconsistently with the declaration, Members may face operational delays and disagreements with charterers or receivers concerning responsibility for additional measures or costs.

Cargo Hazards

RDF may generate toxic gases such as hydrogen sulphide and carbon monoxide, as well as methane and other flammable gases. Oxygen depletion inside the hold is possible. Heat development may occur as the biodegradable fraction decomposes. These conditions can arise gradually or without warning and may make the hold unsafe to enter. Adjacent spaces can also be affected if not fully sealed or adequately ventilated.

Operational and Commercial Impact

The hazards described above may result in restrictions at the port of discharge. Authorities may delay entry or require verification of safe atmospheric conditions before berthing. Stevedores may decline to commence discharge until acceptable readings are obtained. At certain ports, the presence of specialist personnel or firefighting units is required before hatches are opened. Such measures can lead to time at anchorage, increased port costs and possible shifting between berths.

Members may face off‑hire exposure, claims for delayed delivery or disputes concerning liability for specialist attendance, atmospheric testing or disposal of contaminated residues. Where declarations prove incomplete, establishing the cause of delay can become contentious.

Recommendations

Members are advised to obtain detailed cargo information before accepting RDF for shipment. Any uncertainty concerning composition, moisture content, storage duration or bale condition should be addressed directly with the shipper. A documented inspection of the cargo at the terminal is recommended.

Regular monitoring of the hold atmosphere should be conducted during the voyage, and all readings should be recorded. Abnormal values should be reported to the Shippers/Charterers and the Club without delay. On arrival, Members should be prepared for additional requirements imposed by local authorities or stevedores.

Given the absence of clear IMO guidance on the safe carriage of this cargo and the frequency of misdeclaration, a cautious approach is recommended. Members should ensure that charterparty terms clearly allocate responsibilities related to delay, hazardous atmospheres and associated costs.

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Members requiring further guidance are encouraged to contact the Club.