Cargo Securing Manual and Cargo Lashing

The provision is SOLAS VI/5.6, not Chapter VI at large: “Cargo units, including containers, shall be loaded, stowed and secured throughout the voyage in accordance with the Cargo Securing Manual approved by the Administration”. Regulation VII/5 extends the same duty to dangerous goods in packaged form. Above both sits the general duty in regulation VI/5.1: cargo, cargo units and cargo transport units carried on or under deck shall be so loaded, stowed and secured as to prevent, as far as is practicable, damage or hazard to the ship and the persons on board, and loss of cargo overboard.

The scope is wider than is usually stated. The SOLAS criterion is the cargo, not the tonnage: Regulation VI/5.6 covers “all cargoes, other than solid and liquid bulk cargoes, cargo units and cargo transport units”, and Regulation VII/5 does the same for dangerous goods in packaged form. Neither sets a tonnage threshold. On the contrary: Regulation VI/1 and Regulation VII/2 expressly extend their Chapters to cargo ships of less than 500 gross tonnage; for Chapter VI the Administration may substitute “other effective measures” only by reason of the sheltered nature of the voyage, and Chapter VII does not even offer that valve. A 400 gross tonnage cargo ship carrying cargoes other than bulk, on an international voyage, does have the Manual.

Where the 500 figure comes from. From 33 CFR § 97.100, whose title is however Applicability — Electronic documentation: it does not define the scope of the Convention obligation, it presupposes it, since it applies to vessels “that must comply with Chapter VI/5.6 or Chapter VII/5”. It is the scope of a US subpart on electronic documentation, and it is narrower than the SOLAS one by choice of the American legislator. Presenting it as the SOLAS scope goes in the restrictive direction: a 400 gross tonnage ship would conclude it did not need one. The proof that the baseline is wider lies in flag practice — the United Kingdom had to issue an express exemption for ships under 500 gross tonnage, and limited it to non-international voyages and to Chapter VI alone, leaving the Manual in place for dangerous goods.

The supporting instruments are not Conventions. The CSS Code is resolution A.714(17) as amended, with Annex 13 revised by MSC.1/Circ.1352/Rev.1; preparation of the Manual follows MSC.1/Circ.1353/Rev.2. These are recommendations: they bind only to the extent the Administration-approved Manual adopts them, and it is the Manual — not the circular — that a PSCO holds the crew to.