Issue Summary
This issue essentially concerns the definition of an exemption to the all encompassing definition “intended primarily to carry dry cargo in bulk”. Traditional bulk carriers, with hopper and topside tanks, are not at issue and have a clear definition in the CSR rules and in parts of SOLAS. However, some vessel, such as multipurpose or general cargo ships, occasionally carry dry cargo in bulk and it is argued that they should not have to comply with all of the bulk carrier requirements.