Introduction
Jumbo Bags, known technically as Flexible Intermediate Bulk Containers (FIBCs), are in regular use for packaging dry bulk products for transport by sea. The FIBC concept is simple. But understanding and guarding against the potentially fatal hazards which inadequate FIBC structure and their often high risk cargo content can generate is complex. This Risk Bulletin looks at the hazards, the regulation and the critical loss prevention steps required to avoid costly consequences.
Background
At first glance, FIBCs appear to provide a handy and low-cost solution to the easy packaging, handling and transport of dry bulk products. In many cases, it’s as straightforward as it seems. However, it can also go very wrong, particularly during the transport by sea stage.
As reported by well-known fire and chemical cargo consultants, Burgoynes, numerous fire incidents have occurred in FIBCs containing hazardous chemicals loaded in ship cargo holds. Numerous factors are involved including the wetting of water reactive cargoes prior to loading and/or during the voyage. Other factors include inadequate stowage plans resulting in the positioning of interactive chemicals in close proximity to each other. Another fire source has been identified as static electricity discharges caused by FIBC movement in the holds with resulting friction and static charge buildup between bag fibres and cargo content.
Other hazard sources include FIBC stow collapses due to improper stowage and securing. Stow collapses can also be initiated or intensified by bag splitting and cargo content spillage. The result has been loss of ship stability and serious ship list scenarios.
An associated bag splitting problem and cause of loss has been the contamination of any general cargo which may have been stowed underneath the FIBCs. The underlying problem is often a lack of safe stowage knowledge and the use of the wrong type of FIBC for the rigours of sea transport.
All these FIBC related hazards – inclusive of cargo hold fires, loss of stability due to cargo shifts and the possible contamination of other cargo – can of course prove highly dangerous to crew, stevedores and the ship itself. Such incidents are of course also very expensive in terms of claims resolution and loss of hire.
In summary, the key to loss prevention lies in understanding: 1. The range of FIBC types and the certification of their construction and durability. 2. The precise specification and special requirements of cargo content. 3. The correct stowage and securing process for FIBCs. These issues are discussed below.
FIBC Types and Certification
The construction and suitability of all FIBCs for the purpose of transporting all dry bulk goods anywhere is essential to ensuring safe handling and undamaged content delivery. However, for the transport by sea of dangerous goods, the selection and use of appropriately matched FIBCs is critical to ship, crew and stevedore safety.
For non-dangerous goods, the ISO Code for FIBC construction and testing is provided by ISO 21898:24(en). This standard specifies the requirements for design, construction, safety testing, and labelling to ensure safe handling and transportation of bulk solid materials. It includes the details of heavy duty and standard duty re-useable FIBCs, single trip FIBCs, safety factors, safe working loads (SWLs), protective layers, protective electrostatic treatment and fire retardant treatment.
For dangerous goods, the International Maritime Dangerous Goods (IMDG) Code provides a comprehensive framework for safe handling, including recommendations on classification, packing, marking, labelling, stowage, segregation, and emergency response procedures. The latest edition is the 2024 Edition (Amendment 42-24) and this update become mandatory on January 1, 2026.
NOTE: The updated IMDG Code became applicable voluntarily on January 1, 2025. Copies can be purchased directly from IMO e-Publications. A copy should be made accessible on board all Member vessels which are or may be engaged in the carriage of dangerous goods in FIBCs or otherwise.
IMDG Code, Part 4, Packing and Tank instructions, provides the requirements for FIBCs used for packaging and transporting dangerous goods. Reference must also be made to the UN’s ‘Orange Book’ (Model Law) which sets out rigorous UN testing procedures for FIBCs. In combination, the IMDG Code and the ‘Orange Book’ establish an internationally recognised UN certified level of FIBC construction and testing. Only FIBCs which are manufactured to this very high standard may be marked as ‘UN Certified’.
Reference to FIBC manufacturing websites show that only FIBCs constructed and tested to UN Certified standards are recommended for the transport of dangerous goods by sea. Members are referred to the CODEFINE webpage and explanatory article, ‘The Importance of UN Certified Bulk Bags (2025 Guide).
FIBC Cargo Content, Classification and Governing Regulation
A careful assessment of all cargos intended to be loaded into FIBCs is required to ascertain whether they are to be classified as dangerous goods. This assessment will establish: 1. The type of FIBC which should be utilised and 2. The special care required in terms of stowage, separation, securing and ventilation during the voyage.
The tools for making the above assessment include the IMDG Code, Volume 2, Part 3: Dangerous Goods List (DGL), which provides the names and details of dangerous cargo. This extensive list includes the UN number, proper shipping name PSN), class (e.g. Class 4, Flammable Solids), packing group, and any applicable special provisions for each substance or article listed.
NOTE: A useful ‘Introduction to the IMDG Code’ is provided on the Hazcheck eLearning webpage. It provides a Code content outline, examples of the Code compliance check process and advice on crew and shore staff dangerous cargo training courses.
If an FIBC cargo to be loaded does not appear to be listed in the IMDG Code, then a check should also be made of the IMSBC Code which is designed to assess the risks associated with the carriage of unbagged bulk cargoes. The reason being that shippers are known to sometimes avoid IMSBC Code regulations for Group A cargo (which may to liquefy) and Group B cargo (which may pose chemical hazard) by shipping these cargos in FIBCs.
In relation to Group A cargo in FIBCs, some Group A cargoes are also categorised under UN Number 3077 (Environmentally Hazardous Substances, Solid, N.O.S., Not Otherwise Specified). Some Group B cargoes will also have a UN number. These are typically ‘Dangerous goods in solid form in bulk’ which will have a UN number and others known as ‘Materials Hazardous only in Bulk’ (MHB), which may have a UN number.
NOTE: The UN Code for Dangerous Goods and the IMDG Code are separate but closely related. The UN provides the foundational “Model Regulations” and the UN numbers, which the IMDG Code incorporates and applies specifically for sea transport, adding maritime-specific requirements for packaging, stowage, and segregation.
In summary, if any dry cargo shipped in an FIBC has been allocated a UN number, then the UN and/or IMDG Code safety requirements relating to that cargo – whether loaded in bulk or as contained within an FIBC (and therefore technically not loaded in bulk) should be fully complied with. Members should also ensure that the cargo shipper provides the UN/IMDG Code obligated Dangerous Goods Declaration (DGD) document and an obligatory Materials Safety Data Sheet (MSDS) which must contain the full and accurate details of the cargo to be loaded.
NOTE: An MSDS is structured to accord with the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). Key information includes:
- Identification: Chemical name and identity.
- Hazards: Health and physical hazards associated with the substance.
- Ingredients: Information on the chemical’s components.
- First Aid: Measures to take in case of exposure.
- Firefighting: Information on how to combat fires involving the chemical.
- Handling & Storage: Procedures for safe handling and storage.
- Exposure Controls: Personal protective equipment and exposure limits.
- Toxicology: Information on health effects.
- Disposal: Guidance for safe disposal.
FIBC Stowage and Securing
IMDG Code referenced segregation of FIBC dangerous goods from potentially incompatible substances in other FIBC units is essential at the planning stage. Other stowage considerations include careful positioning of dangerous goods to avoid contact with heated bulkheads or placement on top of heated bunker double bottom tanktops in the cargo holds.
Care must also be taken to ensure that multi-tier stowage planning does not exceed FIBC marked stacking height limits so as to avoid FIBC bursting, spillage and possible cargo shifting and contamination. In this respect UN certified bags should be considered as being the safest (with a safety factor of 6:1) and most structurally secure available.
In terms of FIBC securing, SOLAS Chapter VI, Carriage of Cargoes, Part A Reg.5.6 requires an approved Cargo Securing Manual (CSM), for all ships engaged in the carriage of cargo other than solid and liquid bulk cargoes. IMO Guidelines on the preparation of the CSM are set out in MSC/Circ.745 which includes guidance on the securing of ‘unit loads’ such as FIBCs. Additionally, the IMO’s Cargo Safe Stowage (CSS) Code (2021 Edition) provides supplementary guidance for securing FIBCs.
All Member dry cargo ships should already have a flag state approved CSM on board. A useful example of a well-constructed and fully complaint CSM is provided by the Class Bureau Veritas Guidelines for the Preparation of a Cargo Securing Manual. Guidance relating to the securing of FIBCs is provided at Section 3.3.13 Safe, Stowage and Securing of Unit Loads.
Conclusion and Takeaway
The use of FIBCs for the packaging and transport by sea of all dry bulk cargoes requires due care and attention to ensure the safety of crew, stevedores and the ship itself. However, if the FIBC cargo is comprised of IMDG Code and/or UN Code listed dangerous goods, then additional and special care and attention must be exercised to avoid the associated hazards.
Based on IMO or similar NCVS regulation and industry best practice, MMIA’s recommendations to Members who operate dry cargo vessels which transport FIBC units are as follows:
- Prior to loading FIBCs on board, obtain the full details of the cargo inclusive of its UN Code Proper Name so as to ensure its correct assessment as either a benign or dangerous cargo.
- If the cargo is identified (inclusive of an IMSBC Code cross check) as an IMDG Code or a UN Code dangerous cargo, then a Materials Safety Data Sheet (MSDS) and a signed Dangerous Goods Declaration (DGD) must be obtained from the shipper and, preferably, its accuracy independently verified.
- Obtain full details of the construction and cargo compatibility of the FIBCs to be used. This should include details as to whether the FIBCs are constructed and labelled as ‘ISO 21898:2024(en)’ for benign cargo use or ‘UN certified’ for chemical cargo and transport by sea use. FIBC construction which is not cargo compatible or not suitable for transport by sea should not be accepted for loading. Independent assessment and advice may be required.
- FIBC stowage pre-planning should include the IMDG Code advised segregation of incompatible chemical cargos as well as the placement of all such cargoes well away from heated surfaces such as bunker fuel DB tanktops.
- FIBC stack heights during loading should never exceed the height marked on the FIBC label. On completion of loading, FIBC securing should always be in full compliance with each vessel’s approved CSM and the CSS Code.
- Ensure that all shore staff and ship crews involved in the transport of FIBCs carrying dangerous cargo have received training to IMDG Code, Chapter 1.3 mandatory requirements, inclusive of refresher training and record keeping.
Finally, Members are respectfully reminded that MMIA P&I cover may be prejudiced in the case of non-compliance with applicable flag state IMO or similar NCVS regulations inclusive of SOLAS, the CSM obligations, the CSS Code and the IMDG Code. If Members have any concerns or are in any doubt as to their FIBC loading and transport obligations, they should consider obtaining expert advice to assist in ensuring full compliance.