No official guidelines appear to exist for Brazil.

Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium

phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

and ventilating it.

Fumigation of soybean cargo may be required because of insect infestation found at loading, compliance with contractual
specifications, or to issue a phytosanitary inspection certification. Voyage times between countries where soybeans are grown and
countries where soybeans are in demand, can range from three to six weeks. Rather than undertaking a lengthy fumigation at the port
of origin, soybeans are normally fumigated on passage. In recent months, it has become apparent that fumigators are requesting much
longer fumigation times than has previously been the case.

12-15°C 5 days (120 hours)

16-20°C 4 days (96 hours)
> 20°C 3 days (72 hours)

USDA Handbook
The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.
  Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the plUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.
Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge
Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.
Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
 time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

and ventilating it.

Fumigation of soybean cargo may be required because of insect infestation found at loading, compliance with contractual
specifications, or to issue a phytosanitary inspection certification. Voyage times between countries where soybeans are grown and
countries where soybeans are in demand, can range from three to six weeks. Rather than undertaking a lengthy fumigation at the port
of origin, soybeans are normally fumigated on passage. In recent months, it has become apparent that fumigators are requesting much
longer fumigation times than has previously been the case.

12-15°C 5 days (120 hours)

16-20°C 4 days (96 hours)
> 20°C 3 days (72 hours)

USDA Handbook
The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.
Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the plUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge
Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.
Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
 time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.
Click to enlarge

Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

If the planned fumigation time allows few or no chances to ventilateUSDA Handbook

The most comprehensive and specific guide on in-transit fumigation of soybeans is the USDA’s Fumigation Handbook**. This provides
recommended minimum fumigant exposure times according to the depth of stow and the method of fumigation.

Table 2 - Minimum fumigation time by commodity depth (reproduced from USDA Fumigation Handbook), 18 days being a frequently
specified application period for Handymax and Panamax size ships.

Click to enlarge
Other Guidelines
No official guidelines appear to exist for Brazil. Brazilian fumigators often stipulate in-transit fumigation periods of 10 days at aluminium
phosphide concentrations of 28.5 grams per 1,000 cubic feet - significantly lower than the 45 grams per 1,000 cubic feet recommended
by the USDA. It is not clear if these shorter periods or lower doses relate to different pest profiles or previous fumigation of the cargo
whilst on shore.

Problems for Master of the Vessel

Fumigation requirements can pose problems for the Master, not just for safety reasons, but also because it may prevent him from
ventilating the cargo during the voyage. If the Master does not ventilate the cargo he is open to criticism if the surface is degraded on
arrival. Further, the Chinese courts in particular have previously found owners liable for cargo damages, which they believe are could
have been prevented by ventilation, particularly when ventilation was not carried out or there was a failure to keep a proper ventilation
record.

Recently, many US and South American fumigators have stipulated that holds must remain under fumigation for the duration of the
voyage. Further, the USDA Handbook recommends that fumigated holds remain sealed throughout.

Advice

 On most Handymax and Panamax vessels, the fumigant is possibly of limited effect if only applied to the surface of the stow,
and would be far more effective if “trenched-in”. For ships with holds deeper than 20 m, typically cape-size vessels, the use of
a recirculation system needs to be considered.

 Using a recirculation system can reduce the fumigation period on typical Handymax and Panamax ships from 18 to 9 days or
less.

 Paragraph 3.5 of the 2009 IMSBC Code, which was mandatory from January 2011, addresses (broadly) ventilation during the
voyage with 3.6 briefly addressing fumigation - which is explored in greater detail in a supplement to the Code : MSC.1 Circ
1264. At Paragraph 3.3.2.1 of that supplement it is stated that in-transit fumigation should only be carried out at the discretion
of the master. This again places a burden on the Master in making a decision, that should preferably be addressed ahead of
time in the charterparty and contract of carriage (as embodied in the Bills of Lading).

 Keeping accurate records of when the cargo was under fumigation and when it was ventilated is very important. As is the
record of any days when ventilation was not possible, either because fumigation has not been completed and / or conditions at
sea do not permit ventilation to take place.

 If the planned fumigation time allows few or no chances to ventilateanned fumigation time allows few or no chances to
ventilate on the passage, the Owners should inform all interested