01/18/2026
Implementation of the Grain Code Amendment (MSC.552(108)) in Canadian Ports
Regulatory Interpretation, Practical Application, and Inspection Implications
1. Background and Regulatory Context
The International Code for the Safe Carriage of Grain in Bulk (hereinafter referred to as the Grain Code), originally adopted under Resolution MSC.23(59), establishes mandatory stability and loading requirements for vessels carrying grain cargoes.
On 23 May 2024, the International Maritime Organization adopted Resolution MSC.552(108), introducing a significant amendment to the Grain Code. This amendment formally recognizes a new grain loading configuration intended to address long-standing operational and practical challenges encountered during grain loading operations.
The amendment enters into force on 1 January 2026 and applies to new or renewed grain loading approvals issued on or after that date.
2. Transitional Application and Validity of Existing Documentation
2.1 Vessels Holding Existing Documents of Authorization
Vessels holding a valid and unexpired Document of Authorization (DoA) issued under the pre-amendment Grain Code may continue to load grain cargoes until the expiry of the existing DoA, provided that:
• No major structural or stability-affecting modifications have been made, and
• Grain is loaded only in configurations already approved in the vessel’s existing Grain Stability Booklet.
In Canadian ports, Transport Canada Marine Safety does not prohibit grain loading solely because a vessel has not transitioned to the amended Grain Code, provided the existing DoA remains valid and applicable.
3. New Grain Loading Configuration Introduced by MSC.552(108)
3.1 Definition of the New Loading Condition
The amendment introduces a formally recognized loading condition described as:
“A specially suitable compartment, partly filled in way of the hatch opening, with ends untrimmed.”
As defined in section A.2.8 of the amended Code, this configuration means that:
• The compartment is specifically designed and approved for this loading pattern;
• The cargo space is not filled to the maximum extent under the hatch opening;
• The grain level reaches at least the bottom edge of the hatch end beams;
• Outside the periphery of the hatch opening, the grain may remain at its natural angle of repose, in accordance with section A.10.4;
• Full levelling below deck, normally required for partly filled compartments, is not mandatory for this configuration.
4. Operational Rationale for the Amendment
The new loading configuration reflects operational realities frequently encountered in bulk grain trade, including but not limited to:
• Discrepancies between declared and actual stowage factors;
• Shortfall in cargo quantity at completion of loading;
• Under-keel clearance restrictions;
• Ballasting and deballasting limitations;
• Terminal equipment constraints affecting trimming efficiency, particularly below deck.
Prior to the amendment, such conditions often resulted in non-compliant loading arrangements that could not be satisfactorily corrected at the end of loading.
5. Mandatory Stability Data and Grain Loading Manuals
5.1 Pre-Approval Requirement
The amendment does not permit ad-hoc use of the new loading configuration.
To load grain under this arrangement, the vessel’s approved grain stability information must already include the necessary supporting data, as required under section A.6.3 of the Code.
5.2 Required Technical Data
The approved Grain Stability Booklet or Grain Loading Manual must include:
a. Stability Curves and Tables
• Curves or tables of hypothetical volumetric heeling (inclining) moments for the relevant hold(s);
• Curves or tables showing:
o Grain volume versus height; and
o Corresponding vertical centres of gravity (VCG).
b. Approved Practical Examples
• Sample loading plans demonstrating at least one hold loaded in the new configuration;
• Examples covering both departure and arrival conditions.
5.3 Unchanged Requirements
• All assumptions in Part B of the Grain Code remain applicable;
• Existing onboard stability software does not require modification solely due to this amendment.
In practical terms, if the new loading configuration is not already approved and documented, it cannot be used.
6. Continued Role of the Document of Authorization (DoA)
The Document of Authorization remains the primary statutory instrument governing grain loading approval.
6.1 Post-2026 Compliance Requirement
From 1 January 2026, Canadian port authorities will require:
• A valid DoA explicitly reflecting compliance with MSC.552(108); and
• An updated Grain Loading Manual approved by the Flag Administration or a Recognized Organization.
A vessel that technically complies with the amended Grain Code but does not hold a renewed or re-issued DoA will not be permitted to load grain.
Demonstrated compliance without formal approval is insufficient.
7. Canadian Grain Calculation Forms and Documentation
As of the date of writing:
• Transport Canada has not issued a new standardized national grain calculation form specific to MSC.552(108);
• Canadian ports continue to accept:
o Stability calculations prepared in accordance with the amended Grain Code, and
o Calculations approved by the vessel’s Administration or Classification Society.
Any future changes are expected to be promulgated through Ship Safety Bulletins (SSBs).
8. Inspection and Port State Control Implications
Cargo inspectors may encounter three distinct situations:
8.1 Situation 1 – Approved Configuration
• Stability booklet includes the new loading configuration;
• Inspector may assess stability normally;
• Ready for Loading (RTL) and Fitness to Proceed (FTP) may be issued.
8.2 Situation 2 – Unapproved Configuration Before Loading
• Stability booklet does not include the new configuration;
• RTL will be refused;
• Loading in the new configuration will not be permitted.
8.3 Situation 3 – Unapproved Configuration After Loading
• Vessel is found loaded in an unapproved configuration;
• FTP will be refused;
• The master must take corrective action, which may include unloading and re-loading in accordance with approved conditions.
Such situations may lead to operational delays, additional costs, and commercial disputes.
9. Practical Guidance for Owners, Masters, and Surveyors
To ensure uninterrupted grain operations in Canadian ports:
• Apply early for renewal or re-issuance of the DoA;
• Ensure the DoA explicitly references MSC.552(108);
• Update Grain Loading Manuals or attach approved addenda;
• Confirm loading configurations are approved before commencement;
• Maintain close coordination with:
o Flag Administration,
o Classification Society, and
o Terminal operators.
10. Conclusion
The Grain Code amendment under MSC.552(108) introduces necessary operational flexibility while reinforcing the fundamental principle of prior approval and documented stability compliance.
In Canadian ports, grain loading approval will remain documentation-driven, with inspectors relying on approved stability information and a valid Document of Authorization rather than operational intent or post-loading justification.
Kamal Ahmed (15N)
Port Warden
Port of Quebec City
