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VOLUME 45 • NUMBER 04 BACK PAGES Coming soon What to look for at ChemUK 52 Conference diary 54 Incident Log 55 Not otherwise specified 56 NEXT MONTH Storage terminal expansion projects Tank container fleet survey Latest in industrial packaging Middle East logistics UP FRONT Letter from the Editor 03 30 Years Ago 04 Learning by Training 05 Tall Tales of Hazmat 06 REGULATIONS Keep up now UN agrees lots of changes 08 Risky business EPA announces RMP changes 18 Bits and bobs Plenty to see in PHMSA rulemaking 22 SAFETY Intensive care ECTA updates RC charter 28 Manual transmission ERG 2024 coming soon 29 Open the box WCS picks NCB to check cargo 30 Fighting fires with alcohol Methanol safety onboard 31 Keep it clean More work for marine salvors 32 News bulletin – safety 33 TANKS & LOGISTICS We do declare Industry makes a stand in Antwerp 34 Dragons’ den Suttons sees opportunities in China 36 News bulletin – tanks and logistics 38 CHEMICAL DISTRIBUTION Second best Brenntag gets strategic payoff 40 Round the corner CBA sees upturn in confidence 41 News bulletin – chemical distribution 42 TANKER SHIPPING Grab and go Options in onboard carbon capture 44 News bulletin – tanker shipping 46 STORAGE TERMINALS Carrier opportunities Exolum eyes LOHC business 48 News bulletin – storage terminals 50 HCB Monthly is published by CW Research Ltd. While the information and articles in HCB are published in good faith and every effort is made to check accuracy, readers should verify facts and statements directly with official sources before acting upon them, as the publisher can accept no responsibility in this respect. ©2024 CW Research Ltd. All rights reserved Managing Editor Peter Mackay, dgsa Email: peter.mackay@chemicalwatch.com Tel: +44 (0) 7769 685 085 Advertising sales Sarah Smith Email: sarah.smith@chemicalwatch.com Tel: +44 (0) 203 603 2113 Publishing Manager Sarah Thompson Email: sarah.thompson@chemicalwatch.com Tel: +44 (0) 20 3603 2103 Publishing Assistant Francesca Cotton Designer Petya Grozeva Chief Operating Officer Stuart Foxon Chief Commercial Officer Richard Butterworth ISSN 2059-5735 www.hcblive.com CW Research Ltd Talbot House Market Street Shrewsbury SY1 1LG
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EDITOR’S LETTER
In the 1980s, the BBC comedy series Yes Minister introduced British TV viewers to the idea that what politicians do all day is not – as might be expected – make good on the pledges they made to the electorate when they were seeking election but, rather, to do what they can to benefit their party and, quite regularly, to do so in the face of opposition and obfuscation on the part of the civil service.
I do wonder how this was taken in the US, where the series aired on PBS and where there is a clear distinction between political appointees and civil servants (though I had to have this pointed out to me, some years ago). There is a world of difference between the Associate Administrator (political) and the Deputy Associate Administrator (civil service) in US departments, just as there was between the Principal Private Secretary and the Permanent Secretary in Yes Minister.
That revelation was prompted by a disturbance to the (apparently) natural order of regulatory things in the US, at least 15 years ago. Seemingly out of nowhere, it was suddenly alleged that the Department of Transportation and its agencies were ‘too cozy’ with industry. It seemed that, for some, the very transparent system of rulemaking in the US, which ensured that all dutyholders had the opportunity to comment on proposals that could materially affect them, allowed industry to write its own rules.
This caused all sorts of problems for a few years, until more sensible heads took over. Industry has always played a large role in the framing of regulations because, when it comes
down to it, it is industry that is best positioned to be aware of the problems that any new regulations might cause. To put it another way, while politicians are responsible for legislating, when it comes to translating new legislation into regulations, civil servants need to be able to talk it through with the regulated community.
There was another disturbance in the PHMSA ether during the (first?) Trump administration, when there was a general belief that any regulation is bad. New regulation that DOT agencies dared to put forward had to be matched by two going out of the door. This worldview could not cope with the idea that industry (to be more specific, the hazmat industry) actively wanted to be regulated, wanted those regulations to be the same for all and, in an ideal world, wanted them to be the same as they were elsewhere in the world.
Lately, things have got worse. From our perspective, it started last year when, out of the blue, EPA flagged up what it saw as a problem with container reconditioning, putting forward proposals that might – if they go through to adoption – put the sector out of business. Then came the planned revisions to the Risk Management Program (see page 18) and the SCCAP to the Clean Water Act. Industry bodies have lined up to voice loud opposition to plans that they see as adding extra burdens for no safety improvements. It galls them in particular that this is coming at the same time as they are also baying for regulation under CFATS, which has still not been renewed.
If there is a second Trump administration, things may change again. For now, though, there will be a lot of shouting.
Peter Mackay
UP FRONT 03 WWW.HCBLIVE.COM
30 YEARS AGO
A LOOK BACK AT APRIL 1994
IT IS NOT too far-fetched to state that the modern world as we now know it began in the mid-1990s. Just look at the evidence from the April 1994 edition of HCB: ADR was about to become the EU-wide rulebook for the domestic transport of dangerous goods by road and, with it, a requirement for all dangerous goods drivers to be trained at an approved facility was to take effect on 1 January 1995; plastics reconditioners were seeking changes to allow plastics drums to be recycled rather than sent to landfill, which would mean greater standardisation and action by the UN regulators; the US had at long last really started to take tank containers seriously; and, perhaps most significantly of all, computers were taking over a lot of tasks.
This was the first issue of HCB to have a special section entitled ‘Computers in Transport’, though most of the computers illustrated were sitting firmly on a desk somewhere. But, with falling prices and the emergence of new satellite networks, it was becoming viable to track vehicles along the length of their journey from consignor to consignee. Satellite communication meant that the driver was always in touch, and a growing trend towards installing computers in the cabs of trucks meant that drivers could now do a lot of paperwork themselves. It was to be some years before industry got to the point of tracking unaccompanied transport assets – tank containers and rail cars, for instance – but the benefits of what we would now call ‘digitalisation’ were already being felt.
There was also a lot going on at the regulatory meetings in the
mid-1990s that has had a profound influence on the regulations we are dealing with today. HCB’s April 1994 included two extensive reports from ‘HJK’, one from London, where IMO’s Carriage of Dangerous Goods (CDG) Sub-committee had put the final touches to Amendment 27 to the IMDG Code, and another from Geneva, where the UN Sub-committee of Experts on the Transport of Dangerous Goods had a lot of work on its hands with infectious substances.
The new edition of the IMDG Code was running late as the CDG Sub-committee had subjected it to an extensive revision affecting about half of the pages in the old four-volume, ring-bound arrangement. Rather than have users go through the whole thing to replace every other page, it was felt better to organise a complete reprint – with all the costs for users that would entail – but there were some, notably the US, that were querying whether the format was still fit for purpose. It was said that, originally, the IMDG Code was found mainly onboard ships, where its size and layout could be accommodated, but it was increasingly also having to be used ashore, where its size and layout led to inconveniences. There was general support for a reformatting of the Code, though little idea of how best to go about it. It did happen, a few years later, and we do not hear many voices urging for a return to the good old days.
In the UK, fire brigades were unhappy that their plea for the Hazchem hazard warning placard to be included in the ADR Framework Directive had gone unheard. They still think it is better than Kemler codes.
HCB MONTHLY | APRIL 2022 04
LEARNING BY TRAINING
by Arend van Campen
A CRISIS OF PERCEPTION
A RECENT BOOK by Peter Oborne titled The Assault on Truth (2021) describes the cognitive failures of Boris Johnson and Donald Trump, who believe that lying gets them ahead: “Johnson was 23 when he was first sacked for lying”. This book features a listing of events, talks, political turmoil and societal effects caused by information deficit, which demonstrates that Fritjof Capra’s observation of a crisis of perception is correct. This insight is therefore of crucial importance as it offers an unusual view on the certainty by information and the uncertainty by disinformation which can be achieved by man if he or she is open to learn.
The Performance Probability Pattern of disinformation (lying, deceit) is negative because the performance of any system that seeks less information rather than ‘optimal’ can’t function fully. Entropy (disorder) can also be observed as the information we don’t like to have. This is called negative interdependence, which means that a goal can only be achieved if others can’t. In other words: I can become rich because you can’t (you pay for it). Goals that are planned that would depend on enforcement, either by suppression of information or false information, can’t be achieved due to an energy-information-matter weakness (deficit) rendering the work needed to achieve that goal insufficient.
Manipulation in any form of information to achieve an ulteriorly motivated goal ends in chaos i.e., the inability of social governance, hence the status of our planetary society. This is unnecessary and can be re-designed by changing the general perception that lying is creative and constructive, because it is the exact opposite. Lying is allowed only when personal survival in life-threatening situations is at hand. Because the human mind is either unwilling or unable
to see and understand this, society is in a state of unconsciously enforced ‘public entropy’ which can be understood as an accelerating, deteriorating disorder.
Sounds familiar? The trouble is that I can write these lines, but few are willing to change their minds, because their perception, or observation is driven by the need to jump on the bandwagon before someone else does. I just returned from the FETSA conference at StocExpo in Rotterdam and observed several speakers who jumped on the bandwagon of hydrogen, net zero and ammonia, because an investment trend is developing in that direction. But my question is: do we know enough about these risky elements and products? Have we truly studied their potential impact on life, the environment and social cohesion for the long term?
But the most important question to ask is: will the race towards net zero allow and use optimal information or is there a real risk of becoming a path-dependent rat race which has to enforced by those with vested interests? Is it the goal first to make money or to serve society with an abundant and clean form of sustainable energy? If these questions can’t be answered honestly, we have to be aware that entropy laws of physics can’t be broken nor escaped. An information deficit paradox will be the result: the act of lying to achieve a goal already consumes the energy which would have been needed to achieve it.
This is the latest in a monthly series of articles by Arend van Campen, founder of TankTerminalTraining, who can be contacted at arendvc@ tankterminaltraining.com. More information on the company’s activities can be found at www.tankterminaltraining.com.
UP FRONT 05 WWW.HCBLIVE.COM
TALL TALES OF HAZMAT
By Grahame Moody
RESTRICTED ARTICLES AND DANGEROUS GOODS
Some case examples of moving dangerous goods by air show how, early in the history of aviation, their nature threw up some difficult challenges - for instance, mercury spilling from broken thermometers being transported in mining equipment and supplies by biplane between Australia and Papua New Guinea in the 1930s, through to the transporting of house coal (yes, house coal) by air during the Berlin Airlift of 1948. Some issues along the way must also be considered such as the absolutely horrific circumstances leading to the crash of the ValuJet DC9 passenger aircraft into the Florida Everglades in 1996, caused by runaway oxygen generators. The pilot, Captain Candi Kubeck, died a hero.
Some dangerous goods accidents including fatal crashes are still happening and very probably always will, despite the best efforts of everyone involved. These include, for instance, the uncontrollable self-heating of lithium batteries beating modern quality control techniques.
It so happens that the hazardous cargo being shipped by air before 1973 wasn’t known as ‘dangerous goods’, it was called ‘restricted articles’. The generic term hazmat came along later, having originated in the US. 1973 was the year when restricted articles played a big part in the tragic crash of a PanAm 707 freighter aircraft in Boston. It was also the year that the name ‘restricted articles’ changed to ‘dangerous goods’. These changes meant a major shakeup in the legislation and applied to everyone involved, from chemist to packer to pilot.
As we have noted, it was not the first time that an aircraft had crashed because of dangerous goods, so what made it so significant in
this case? The answer to that question is that the cause was quickly identified and was directly attributed to a badly packed shipment of restricted articles. This led, in a straight line, to serious repercussions in the aviation industry.
The companies who were responsible for the packing and loading of the shipment in question (as well as their employees) soon became crystal clear as well. However, what could be done to stop anything like this from happening again? The ages-old prevention of recurrence – the bane of a politician’s life.
This accident caused a massive shift in emphasis on the shipping of dangerous goods by air partly because, until then, the whole industry was largely self-regulated (yes, I know). Among other things, self-regulation meant that no overall body was responsible for ensuring compliance and there were no targeted punishments that could be applied. Something clearly had to change.
Arising from this, the UN was designated as responsible for worldwide legislation and standards, with sanctions such as official warnings, fines and even imprisonment possible for the worst offenders.
The sanctions were actually to be applied by individual countries’ aviation authorities, such as the FAA (USA), DGAC (France) and CAA (UK) because only national legislation has the legal power to sanction transgressors in their own country.
In the beginning, the snappily-titled ‘UN Sub-Committee of Experts on the Transport of Dangerous Goods (TDG Sub-Committee) was established in 1954 and published what was called the Model
HCB MONTHLY | APRIL 2022 06
Regulations, namely the Recommendations on the Transport of Dangerous Goods. This was and is popularly known as the Orange Book. These recommendations have been adopted by the regulatory organisations responsible for all the different modes of transport, i.e. road, rail, sea and air (as well as all the other variations, such as tunnels, bridges, canals, helicopters, airships, drones and e-scooters (I may have made that last one up) [You haven’t – Ed].
We should now turn our attention first to IATA, which was established in Havana, Cuba on 19 April 1945, nine years before the UN was given the task of regulating dangerous goods.
IATA, however, was founded as the prime vehicle for inter-airline cooperation and had no interest in or responsibility for dangerous goods. But it quickly became necessary, given the risks involved and the proliferation of passengers and air freight, that the emotional engagement of transporting dangerous goods by air required urgent consideration (the Berlin Airlift took place between 1948 and 1949).
Therefore in 1952, IATA established a restricted articles working group (later known as the IATA Restricted Articles Board). This working group studied all available dangerous goods regulations by different means of transport. And now then, I know what you’re thinking: where is ICAO and their Technical Instructions in all this? The answer to that is ‘in the future’.
It was not until 1975 that ICAO was becoming involved in the field of dangerous goods regulations. It started the ICAO study group, which comprised representatives from ICAO, IATA, IFALPA, Federal Republic of Germany, US DOT, and US FAA to make recommendations. In 1977, ICAO held the first meeting of its Dangerous Goods Panel (DGP) to prepare the draft of ICAO Annex 18 to the Chicago Convention on
international civil aviation together with its associated Technical Instructions for the safe transport of dangerous goods by air.
That is a long and complicated story and without a punchline anywhere in sight. Moreover, it only goes some way to explaining what happened after 1973. In the world of international legislation, if you know anything about that subject, the whole thing is actually a triumph of will and skilful negotiators negotiating away over soft drinks and biscuits.
The failings of the UN are well-known and not for discussion here (I am already glancing over my shoulder to check for UN/Stasi agents). But the other agencies and especially IATA have stepped up to the plate and produced the modal legislation as we now know it:
• The IATA Dangerous Goods Regulations (international by air)
• IMDG Dangerous Goods Regulations (international by sea)
• ADR (European/international by road)
• RID Dangerous Goods Regulations (European by rail)
For me, the crowning glory will remain the IATA DGR as being the easiest to navigate, to learn from and be trained with, as well as being best laid out. In my honest opinion.
As for the others, how anyone could say that they enjoy consulting the two-volume ADR will remain as Toyah once said - a mythtery.
This is part of a regular series of articles by Grahame Moody, senior analyst (technical services) of Hazmat Logistics, who can be contacted at sales@hazmatlogistics.co.uk. More information on the company’s activities can be found at www.hazmatlogistics.co.uk.
*Paraphrased from Peter Drucker’s book The Effective Executive, mentioned here for transparency and compliance with copyright laws (see what I did there?).
UP FRONT 07
KEEP UP NOW
INTERNATIONAL • THERE IS PLENTY FOR THE MODAL REGULATORS TO WORK WITH AS THE UN EXPERTS CONTINUE TO TWEAK THE ORANGE BOOK IN RESPONSE TO TECHNICAL DEVELOPMENTS
THE UN SUB-COMMITTEE of Experts on the Transport of Dangerous Goods (TDG) held its 63rd session this past 27 November to 6 December. Duane Pfund (US) continued as chair and Claude Pfauvadel (France) took the vice-chair position for the last time prior to his retirement in 2024. The session was attended by representatives from 22 countries, the Intergovernmental Organisation for International Carriage by Rail (OTIF), the Food and Agriculture Organisation (FAO), the International Civil Aviation Organization (ICAO), the International Maritime Organisation (IMO), the UN Institute for Training and Research (Unitar), the World Health Organisation (WHO) and 23 nongovernmental organisations. An observer from Luxembourg also took part.
This was the second of four planned sessions to be held in 2023 and 2024 to agree and adopt the changes that will appear in the 24th revised edition of the UN Recommendations on the Transport of
Dangerous Goods – the ‘Model Regulations’ – and, as is often the case, it was this session where a lot of matters were addressed, and many settled. It is indicative of the breadth of the Sub-committee’s discussions that, in the 20-page report on the session, the first four pages are taken up with the agenda.
The first part of this two-part report on the winter session of the TDG Sub-committee (HCB March 2024, page 12) covered discussion of explosives, issues of listing and classification, new energies, packaging matters and reports from the informal working groups. This second part covers cover discussions relating to energy storage devices, the transport of gases, miscellaneous proposals for amendment, global harmonisation issues and other business.
ENERGY STORAGE SYSTEMS
The European Association for Advanced Rechargeable Batteries (Recharge) returned to the issue of the difficulty in testing some
batteries in accordance with the Manual of Tests and Criteria, paragraph 38.3, due to their design. Those where the terminals are not accessible for testing the short circuit protection cannot be dismantled in order to conduct the test, since they would not be tested as designed and as transported. Recharge proposed now to substitute a verification test for such batteries, in order to verify that the protective parts preventing the short circuit are still effective after the whole test sequence T1 to T4.
Most experts who took the floor supported in principle the purpose of the proposal but there were some concerns over the proposed text for 38.3.3(b). Recharge will work on a revised proposal for submission in an official document at the next session.
China followed up on a topic it had raised at the previous session, namely the need to establish transport provisions for hybrid batteries containing both lithium ion and sodium ion cells, termed Li-Na batteries. These new batteries are expected to find widespread used in the automotive and energy storage industries. China proposed that they be transported in accordance with the existing provisions for lithium ion batteries, which would then require largely textual amendments to the current text in the Model Regulations.
The Sub-committee was happy with this approach and, with some editorial changes, adopted the proposed amendments. The core
08
HCB MONTHLY | APRIL 2024
item is a new 2.9.4(h):
Hybrid batteries, containing both lithium ion cells and sodium ion cells (see special provision 410 of chapter 3.3), shall meet the following conditions:
(i) The lithium ion cells and sodium ion cells are electrically connected;
(ii) The battery has been tested as a lithium ion battery in accordance with 2.9.4 (a);
(iii) Each component lithium ion and sodium ion cell of the battery shall be of a type proved to meet the respective testing requirements of the Manual of Tests and Criteria, part III, sub-section 38.3.
There is also a new special provision 410:
Hybrid batteries in conformity with 2.9.4 (h) containing both lithium ion cells and sodium ion cells shall be assigned to UN Nos. 3480 or 3481, as appropriate. When such batteries are transported in accordance with special provision 188, the watt-hour rating of all batteries shall not exceed 100 Wh and shall be marked on the outside case.
Reference to special provision 410 is added to the increasingly long list of special provisions in column (6) of the Dangerous Goods List against UN Nos 3480, 3481, 3551 and 3552. There are also small additions to the existing special provisions 188(c), 310, 363(f), 388 and 389 to include reference to the new 2.9.4(h). In both special provision 360 and 388, a new sentence is added:
Vehicles powered only by hybrid batteries containing both lithium ion cells and sodium ion cells in accordance with 2.9.4 (h) shall be
assigned to the entry UN 3556 VEHICLE, LITHIUM ION BATTERY POWERED.
There are several other textual changes to add hybrid batteries of this type to existing provisions for lithium ion batteries.
China also raised the issue of the transport of articles that contain both lithium batteries and other dangerous goods, harking back to a query by the UK in 2011 regarding ‘torch’ cigarette lighters that use a lithium battery installed in the unit as well as the necessary fuel. The increasing use of lithium batteries in all manner of articles means that this question is becoming urgent and China queried whether it was felt necessary to add some restrictions on the carriage of such articles. China noted that ICAO’s Technical Instructions require that UN 3090 and 3480 batteries shall not be packed with or stowed together with dangerous goods of Class 1 (other than Division 1.4S), Division 2.1, Class 3, Division 4.1 or Division 5.1. Might this offer a way forward?
Some experts were of the opinion that cells or batteries shall be removed and transported separately, if possible – though China’s point was that in many cases the battery cannot be removed and the article as a whole is designed to be disposed of once the battery is fully discharged. Other experts felt that further work on the exemptions for limited quantities and on restrictions in the Model Regulations was needed. The Sub-committee did agree that the current provisions would benefit from clarification, particularly as
REGULATIONS 09
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regards the non-alignment of 2.0.5.6 and special provision 310 that China’s paper had highlighted.
China offered to work on a revised proposal and invited further comments.
Germany queried the applicability of special provision 188, which includes a requirement that the aggregate lithium content of a lithium metal or lithium alloy battery is no more than 2 g and that the watt-hour rating of a lithium ion battery is no more than 100 Wh. Germany has come across some examples that make it difficult to interpret this provision; for instance, there are batteries with a watt-hour rating of more than 100 Wh, consisting of two or more batteries that can be physically separated by the removal of plugs, which seems to mean there are now a number of smaller batteries, each under 100 Wh. A second variant involves the use of a ‘transport mode’ in the battery management system, which can restrict the charge to a maximum of 85 Wh during transport, though in ‘operation mode’ the battery can be charged to more than 100 Wh.
Some experts considered a switch sufficient for a disconnection of batteries and in line with the definition of a battery in the Manual of Tests and Criteria, but others believed that a switch might be a risk as it could be switched on by accident. The Sub-committee acknowledged that the current provisions in the Model Regulations are not clear and need to be reviewed.
ICAO had lobbied at the previous session for special provision 400 to be amended so that packages of UN 3551 and 3552 sodium ion cells and batteries would not need to be marked in accordance with 5.2.1.9. The Sub-committee did not agree and, instead, took cognisance of a proposal by Spain to include a specific reference to special provision 400 in 5.2.1.9.1, which already includes a reference to special provision 188. The Sub-committee adopted the suggested
change, which involves adding “or 400” after “188” in 5.2.1.9.1.
China noted that, while the Sub-committee had already adopted new entries for sodium ion batteries with organic electrolyte (UN 3551) and such batteries contained in or packed with equipment (UN 3552), there is no entry to parallel the existing UN 3536 for lithium batteries installed in a cargo transport unit. One of the main uses of sodium ion batteries is expected to be in large scale energy storage, so there is a need for a UN entry for sodium ion batteries installed in a cargo transport unit.
Some experts supported in principle the insertion in the Model Regulations of a new UN number and a new special provision as proposed by China but others expressed a preference to come up with a more generic shipping name for UN 3536, bearing in mind that China’s proposal included the same transport requirements that already exist for lithium batteries in cargo transport units. China said it would work further on the proposal and return with a revised text at the next session.
The International Air Transport Association (IATA) put forward some proposals to tidy up
the text of 2.9.4 and 2.9.5. It noted that those paragraphs describe the requirements that apply to the classification of lithium cells/ batteries and sodium ion cells/batteries, and the correct assignment to the various UN entries; however, special provisions 310, 363, 388 and 389 contain references to cells and batteries in articles, engines, machines or vehicles, which are not assigned to one of the UN numbers specified in the opening paragraphs of 2.9.4 and 2.9.5. This creates a conflict, IATA said, offering some simple methods of straightening the problem out.
The Sub-committee concurred and made the following changes. In the opening paragraph of both 2.9.4 and 2.9.5, “contained in equipment” is replaced by “contained in articles, engines, equipment or vehicles”; references to specific UN entries are deleted in both paragraphs.
IATA also sought to clarify the marking exception for lithium button cells in special provision 188. Currently, this states in sub-paragraph (f)(i) that packages containing only button cell batteries installed in equipment are not required to bear the lithium or sodium ion battery mark. IATA’s Dangerous Goods Board had raised a query in relation to
10 HCB MONTHLY | APRIL 2024
MORE WORK IS NEEDED ON THE CLASSIFICATION OF ARTICLES CONTAINING BOTH LITHIUM BATTERIES AND OTHER DANGEROUS GOODS
the transport of laptop computers, which are identified by the lithium battery mark and ‘UN 3481’; however, laptops generally also contain a single lithium button cell to power a semiconductor chip, but the accepted practice seems to be to ignore this and not show ‘UN 3091’ on the package. This is, strictly speaking, not in compliance with the regulations as they stand and it would be desirable to clear up the issue with some sort of clarifying text in 5.2.1.9.2.
While there was general support for the idea, most experts preferred to amend the text of special provision 188(f)(i). Some also wondered whether this might not be an appropriate point to define size limits for buttons cells. IATA will work up a new document so that discussion can continue at the next session.
Japan reported on technical advances in lithium ion battery design, with the
development of all-solid-state batteries that
against heat. Such batteries are expected to be available commercially in the near future. They differ in terms of material and structure
would fit with the ongoing work of the informal Association (PRBA) raised concerns about the safety implications of efforts to increase the reuse, repair and repurposing of lithium ion cells and batteries, as part of a broader effort
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to foster recycling and a circular economy. The two bodies had been working towards a proposal to include new definitions for ‘repurposing’ and ‘remanufacturing’ and to more closely define the scope of the existing provisions as regards such batteries; they intend to put forward a formal proposal at the next session but, to prepare the Subcommittee, they brought an informal document to offer suggestions for changes to 38.3.2.3 in the Manual of Tests and Criteria.
Some experts urged consistency with relevant EU legislation and the Subcommittee as a whole acknowledged that further work was required. The formal proposal from Recharge and PRBA will focus on safety, possible serving as a guideline for future work.
Finally, as far as batteries are concerned, the Secretariat has spotted that, following the introduction of new provisions for sodium ion batteries, the text of special provision 310 needed revising. Along with earlier proposals, this means that the following text is added at the end of the first paragraph: for lithium cells or batteries, and shall meet the provisions of 2.9.5 with the exception of 2.9.5 (a) and 2.9.4 (e) (vii) (as referred to in 2.9.5 (e)) for sodium ion cells or batteries.
TRANSPORT OF GASES
The International Organisation for Standardisation (ISO) presented its regular update on revisions to its standards relevant to gas cylinders. Three such standards have been revised, and the Sub-committee agreed the inclusion of references to the latest editions, which are:
ISO 11515:2022 Gas cylinders – Refillable composite reinforced tubes of water capacity between 450 l and 3000 l – Design, construction and testing
ISO 14246:2022 Gas cylinders – Cylinder valves - Manufacturing tests and examinations
ISO 22434:2022 Gas cylinders – Inspection and maintenance of valves.
ISO 11515 appears in the table in 6.2.2.1.2; the existing reference to ISO 11515:2013+Amd I:2018 will now have 31 December 2030 as an end date. ISO 14246 appears in the table in 6.2.2.3; the existing reference to ISO 14246:2014+Amd I:2017 will now also have 31 December 2030 as an end date. ISO 22434 appears in the table in 6.2.2.4; the existing reference to ISO 22434:2006 will now have 31 December 2028 as its end date.
In addition, ISO noted that there is a 2023 amendment to ISO 11114-1:2020 Gas cylinders – Compatibility of cylinder and valve
materials with gas contents – Part 1: Metallic materials. This is referenced in several places in the Model Regulations, including the table in 6.2.2.2 but also special provision 379(d)(i) and in Chapters 4.1, 6.2 and 6.7. The update is significant since it relates to the compatibility of aluminium silicon bronze (ASB) with halogenated gases.
Germany followed up on the report at the last session of the work of the intersessional working group on the pV-product limit for pressure receptacles; four proposals relating to definitions of pressure receptacles were adopted but kept in square brackets and Germany had also submitted an informal document with ideas for an additional requirement in 6.2.3.5 on the safe handling of salvage pressure receptacles.
Germany now made five specific proposals for amendment, which drew a lot of comment from the experts. After lengthy discussions and some editorial changes, the proposals were adopted. The amendments include two new definitions in 1.2.1:
Pressure volume product (pV-product) means the value resulting from multiplying the (usable) water capacity of a containment with its relevant maximum pressure during filling and usage (e.g. test pressure or charging pressure) as referenced for the relevant kind of containment. It is expressed in bar litres.
Usable water capacity means the water capacity of salvage pressure receptacles remaining after the installation of equipment into a salvage pressure receptacle, which is necessary for e.g., opening or drilling a stored pressure receptacle inside a closed salvage pressure receptacle. The usable water capacity may be lower than the water capacity originally approved and marked. It is expressed in litres.
In 4.1.1.19.3(c), the existing beginning of the first sentence, ‘The contents of the contained pressure receptacle(s) are limited in pressure and volume…’, is amended to read: ‘The contents of the contained pressure
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THE VARIOUS ROUTES TAKEN BY SPENT BATTERIES POSES A PROBLEM WHEN IT COMES TO REGULATING THEIR TRANSPORT
receptacle(s) are limited in pressure, in usable water capacity and in pressure
Do you consign Dangerous Goods?
The remaining amendments are all found in 6.2.3.5. At the end of the second paragraph,
This indication of authorized pressure
(a) The test pressure to which the salvage pressure receptacle can be loaded at maximum temperature, which limits the storage of pressure receptacles filled with liquified gases.
(b) The usable water capacity and the maximum pV-product authorized for stored pressure receptacles, which limits the storage of pressure receptacles filled with compressed gases. The value of this maximum pV-product is the lowest value of either of the following:
(i) the general limit of the pV-product
(ii) the pV-product of the salvage p ressure receptacle based on the test pressure to which it is allowed to be loaded at maximum temperature and
The last sentence of the original second paragraph becomes a new paragraph and is
A list of the materials of construction of all parts likely to be in contact with the dangerous goods shall also be included in the approval certificate. In the last (fourth) paragraph of 6.2.3.5, the last sentence is amended to read:
receptacle shall include the usable water capacity, the test pressure and the maximum pressure volume product. This mark shall start with the letters “PVP”, followed by the pVproduct and the units. The pV-product shall include a space in front of the last 3 digits of the
separated by a dot. For harmonised readability and to avoid subsequent manipulation, the mark shall not contain more spaces. An example of
Since 1st Jan 2023, all UK consignors must have an appointed DGSA
Specialist software for creating compliant DG Documentation
The Note at the end is also replaced and Salvage pressure receptacles with a water capacity of not more than 3000 litres may
additional PVP mark until 31 December 2030.
China returned to its proposal at the previous session to specify the location for the lithium battery or sodium ion battery mark, which is not currently stated explicitly. While there had been some support in principle at the last session, the experts had not been confident in taking a decision but China stressed the need for the hazard posed by batteries, especially when packaged with other goods, to be effectively communicated. After discussion
acceptable form of words was agreed –though it was later amended after it was
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agreed to drop the unwieldy term ‘lithium or sodium ion battery mark’ for the simpler ‘battery mark’. The amendment involves a new 5.2.1.9.3:
When both the battery mark and labels in accordance with 5.2.2.2 other than model No. 9A are required, the battery mark shall be located on the same surface as the labels if the package dimensions are adequate.
Spain urged the Sub-committee to adopt the latest revision to ISO 535 Paper and board – Determination of water absorptiveness –Cobb method. This was last updated (to the 2014 edition) in 2021 but the latest revision, the 2023 edition, contains some useful modifications. The Sub-committee agreed, updating the references in 6.1.4.12.1, 6.5.5.4.16, 6.5.5.5.3 and 6.6.4.4.1 accordingly.
Germany felt that the specifications for the performance and frequency of tests in 6.1.5.1.3 are unclear, particularly in respect of which tests are being referred to. This is most obvious in the French and Spanish language versions of the Model Regulations, though the English version could also benefit from improvement, Germany said.
The general feeling of the Sub-committee
was that this paragraph had been intentionally left open, so as to allow the competent authority to determine which tests should be repeated and at what intervals. However, the Sub-committee agreed to resume discussions at the next session on the basis of a revised proposal from Germany.
Russia reported on the latest meeting of the informal working group on fibre-reinforced plastics (FRP) service equipment for portable tanks. The group had responded to comments at the previous session and now made four substantive proposals for both the Model Regulations and the Manual of Tests and Criteria, which included a new 6.9.3 setting out the requirements for the design, construction, inspection and testing of FRP service equipment. These proposals were refined during discussions held alongside the plenary meeting and the Sub-committee adopted them, though keeping them in square brackets for the time being.
The new 6.9.3 begins with a section on definitions, reading:
For the purposes of this section, the definitions in 6.7.2.1 and 6.9.2.1 apply except for definitions related to metal materials for the
construction of the service equipment of portable tanks.
Additionally, the following definitions apply to FRP service equipment.
FRP service equipment means service equipment as defined in 6.7.2.1 made of FRP materials including parts fabricated from other materials, as gate and seal assemblies, metallic parts, e.g. springs, fixings, applicable to both metallic and FRP shells of the portable tanks.
Injection moulding means a process of melting plastic pellets (thermosetting/ thermoplastic polymers) and mixing with reinforcement agents like chopped glass fibres. Then, the mixture is metered into a mould with the help of high-pressure pumps or injection cylinders, which fills and solidifies to produce the final product.
Compression moulding means a process for producing composite parts in a wide range of volumes typically employing a matched metal tool in a heated (normally hydraulic) press to consolidate sheet materials or moulding compounds under pressure.
Reinforced reaction injection moulding (RRIM) means a process of mixing of two or more resins together in the mixing chamber to form a thermosetting polymer under high pressure. Reinforcement agents like glass fibres are added to the mixture. Then, the resin mixture is metered into a mould with the help of highpressure pumps or injection cylinders.
Coupon-sample means an FRP sample fabricated and tested in accordance with national or international standards to determine design allowables.
Inspection-sample means a sample cut out from the FRP service equipment to establish the conformity of the serial FRP device to the prototype.
FRP constituents means reinforcement fibres or particles, thermoset or thermoplastic polymer (matrix), adhesives, and additives.
The new section continues with general design and construction requirements (6.9.3.2), design criteria (6.9.3.3), material testing (6.9.3.4), design approval (6.9.3.5), inspection and testing (6.9.3.6) and marking (6.9.3.7).
Test methods for fire resistance testing of FRP service equipment are set out in a new section 42 of the Manual of Tests and Criteria.
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Further amendments are found in 6.7.2.5.11, where “or fibre reinforced plastic (FRP) in accordance with section 6.9.3” is added after “Ductile materials”; the paragraph under the heading of 6.9.2.5 is amended to refer specifically to FRP tanks, with an additional final sentence: “FRP service equipment in accordance with section 6.9.3 may be used.”
There is also a new 6.9.1.5:
The requirements of section 6.9.3 are applied to FRP service equipment for portable tanks with shells made of metallic or FRP materials intended for the carriage of dangerous goods of Classes or Divisions 1, 3, 5.1, 6.1, 6.2, 8 and 9 by all modes of transport.
In the Manual of Tests and Criteria, an additional sub-paragraph (b) is added to 40.1.1 to indicate that section 42 contains the fire resistance test requirements.
Russia also urged the Sub-committee to adopt a new 6.9.4 to provide provisions for the design, construction, inspection and testing of FRP tanks intended for the transport of
unrefrigerated liquefied gases of Class 2. It contended that, for decades, FRP has been widely used for the production of storage tanks for such gases, including hydrogen, and that there are no technical limitations that would prevent its use in transport applications.
While there was some support for further discussion, most experts felt the proposal was premature, preferring to wait until more experience had been gained in the use of FRP tanks with other cargoes. Russia invited delegations to send data on their experience in this field and will return with a formal proposal at the next session.
The International Union of Railways (UIC) brought an informal document to the Subcommittee to alert it to an issue it had raised at the RID/ADR/ADN Joint Meeting’s autumn 2023 session, concerning the holding time for the carriage of portable tanks with refrigerated liquefied gases. The proposal concerned both tank wagons and tank containers/portable tanks used in combined transport operations
involving rail. The Joint Meeting had adopted some amendments and UIC urged the TDG Sub-committee to follow suit.
The problem that the proposal sought to overcome is that, when tank wagons, tank containers or portable tanks that have carried refrigerated liquid gases and are empty uncleaned, are moved by rail, the pressure relief devices regularly activate. While this does not in itself pose a hazard, it can lead to the assumption that there is an incident and there have been cases where railway operations have been severely affected. The issue primarily concerns UN 1951 Argon and UN 2187 Carbon dioxide. It is not such an issue in road transport since there is a driver on hand to take the necessary measures.
While some experts expressed their support for the idea, others believed the proposed wording needs to be reviewed. UIC volunteered to work on an updated proposal taking into account the comments received and to submit it as an official document for the next session.
The European Industrial Gases Association (EIGA) reported on a problem following the adoption of changes to the use of the terms ‘degree of filling’ and ‘filling ratio’. These changes require, inter alia, changes to the tank plates of existing portable tanks, specifically changing “Degree of filling” to “Maximum allowable mass of gas filled”. In most cases, this will mean producing and fitting a completely new plate, which may prove problematic. EIGA argued that the process of replacing all these tank plates will take some time and asked for a transitional measure.
The Sub-committee understood the problem and adopted the proposed text as a new paragraph at the end of 4.2.6:
Portable tanks manufactured prior to 1 January 2027 which were marked in accordance with the requirements of 6.7.4.15.1 (i) (iv) applicable in the twenty second revised edition of the Model Regulations may continue to be used.
Poland returned with an official document with proposals to confirm decisions made at the previous session regarding the definitions of ‘FRP tank’ and ‘FRP shell’, but which had been left in square brackets to allow for further consideration. Its paper contained 12
REGULATIONS 15 WWW.HCBLIVE.COM
proposed amendments, 11 of which were accepted by the Sub-committee.
In 6.9.2.1, in the definition of FRP shell, ‘or’ is changed to ‘and’, to read: “… but does not include service equipment and external structural equipment...”. The definition of FRP portable tank is amended to read:
FRP portable tank means a portable tank, as defined in 6.7.2.1, with an FRP shell;
In 6.9.2.2.3.14.1 and 6.9.2.5, ‘FRP tanks’ is replaced by ‘FRP portable tanks’; in 6.9.2.8.1, ‘portable FRP tanks’ is replaced by ‘FRP portable tanks’; in 6.9.2.6.4, 6.9.2.8.3 and 6.9.2.9, ‘tank’ is replaced by ‘FRP portable tank’; in 6.9.2.8.4 and 6.9.2.9, ‘shell’ is replaced by ‘FRP shell’; and in 6.9.2.2.3.16.2. A new proposal from Poland to replace ‘tank’ with ‘FRP shell’ in 6.9.7.1.5.1 was not agreed and Poland may come back with a further proposal.
Spain had continued with its efforts to remove all instances where ‘weight’ is used when what is really meant is ‘mass’. Following work on the Model Regulations, which resulted in several changes at the last session, its attention had turned to the latest edition of the Manual of Tests and Criteria, where it found further instances in the English, French and Spanish language versions. There were seven places in the English version where ‘weight’ has been changed to ‘mass’ and ‘weighing’ to ‘with a mass of’. All were adopted by the Sub-committee.
Another official document from Spain, again following up on work at the previous session, sought to correct the terminology used in the stacking test for IBCs and large packagings. Again, the Sub-committee accepted Spain’s proposals, which involve the replacement of ‘stacking test load’ by ‘superimposed stacking test mass’ in 6.5.2.1.1(g), 6.5.2.1.3, 6.5.2.2.2, 6.6.3.1, 6.6.3.2 and 6.6.3.3. In addition, in 6.5.6.6.4, ‘load to be placed on the IBC’ is amended to read ‘mass placed on the IBC surface to create the superimposed test load’ and similar wording is used in 6.6.5.3.3.4 for large packagings.
South Korea highlighted the fact that, while IBCs and large packagings designed to be stacked are identified by the maximum permitted stacking load, there is no indication of the orientation of the packagings when stacked; this could lead to cases where IBCs or large packagings are stacked in a way that creates a higher load than that specified in the test. Its paper sought the inclusion of some text in 7.1.1.9 to ensure that such packagings are always stacked in the correct orientation. The Sub-Committee welcomed the purpose of the document and agreed on the need to clarify the stacking direction of packages. It was noted that dangerous goods safety training and capacity building could also be a possible solution. South Korea will come back at the next session with an official proposal.
GLOBAL HARMONISATION
The Secretariat brought two official proposals that emanated from the Ad hoc Working Group on the Harmonisation of RID/ADR/ADN with the UN Recommendations. These were
promptly agreed. The first involved the addition of ‘or sodium ion cells or batteries’ after ‘lithium cells and batteries’ in 2.0.5.2, packing instruction P006 and large packing instruction LP03. On a similar theme, and as noted above, it was felt that the ‘lithium or sodium battery mark’ was an unnecessarily verbose term for a mark that is used on all packages containing lithium ion, lithium metal and sodium ion batteries. As such, the term ‘battery mark’ is ample. This too was adopted by the Sub-committee.
Similarly, the autumn 2023 session of the RID/ADR/ADN Joint Meeting had made some observations on the wording used in some special provisions (SP 400, 406 and 407); in particular, there are several instances where ‘shall be’ is used, when ‘is’ is sufficient. These too were agreed by the Sub-committee, along with an editorial correction in packing instruction P006.
IMO reported on the outcome of the 39th session of the Editorial & Technical Group of the Sub-committee on Carriage of Cargoes
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SEVERAL YEARS AFTER THE INTRODUCTION OF THE STACKING LOAD MARK, AMENDMENTS ARE STILL BEING MADE TO THE PROVISIONS
and Containers (CCC), which had taken place in early October. This included three items that it was felt needed the attention of the UN experts. Firstly, it was found that there is a difference in the English and French versions of special provision 277; the TDG Subcommittee agreed that the French version is correct and amended the English version to clarify that the 120 ml limited quantity value for aerosols or receptacles containing toxic substances relates only to the exemptions in Chapter 3.4.
Secondly, in 6.2.1.5.2(d), (e) and (f), for the sake of consistency and clarity, CCC proposed changing ‘technical code’ and ‘code’ to ‘recognized technical code’. The Subcommittee also adopted this change. A third proposal, to change the tank special provision for UN 2735, PG II from TP1 to TP2, in line with the guiding principles, was not adopted by the Sub-committee; IMO will return with an official proposal at the next session.
The US submitted a thought-starter paper
on the evolution of transport systems –particularly in light of issues covered by the UN Sustainable Development Goals – and what this means for the Model Regulations. This can be boiled down to five questions:
•What technological advances or changes in shipping practices create compliance challenges with the dangerous goods regulations?
•Have modern methods of product inventory and delivery management created a need to re-examine the current baseline safety standards? If so, how?
•What safety advancements in packaging manufacture or testing can be incorporated into the Model Regulations?
•Are there certain materials or applications of dangerous goods offered in accordance with competent authority approvals or regional/ national standards that could be incorporated into the Model Regulations?
•How can the Sub-Committee continually assess potential gaps in the Model
Regulations to keep pace with changes in manufacture and logistics practices?
A limited informal discussion of these topics was held during the Sub-committee’s session and will continue intersessionally.
It was noted that the International Atomic Energy Agency (IAEA) is planning to finalise a draft revision to its Regulations for the Safe Transport of Radioactive Material (SSR-6) by the end of this year. A proposal to align the Model Regulations with the revised edition will be submitted subsequently.
The European Aerosol Federation (FEA) followed up on discussions at the previous session of issues arising from the work by the UN Sub-committee on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) regarding combinations of physical hazards. This has some implications for aerosols, since the combination of the functional substance – which could be corrosive, oxidising or explosive – and the propellant, which may well be flammable, makes their classification problematic. FEA proposed to clarify the matter by amending special provision 63 so that it aligns with the text of SP 362.
There was some support for FEA’s proposal, though some experts noted that 2.2.2 and 2.2.4 contain similar provisions and there is no need to repeat them. FEA was invited to consider the comments made and, if necessary, to come back with an official proposal for the next session.
The informal working group on combinations of physical hazards had been working on similar issues and, as Germany reported, had developed some texts applicable to aerosols and chemicals under pressure to clarify the limitations of classification. The Sub-committee indicated its preferences but has not at this stage adopted any text; those preferences were passed on to the GHS Sub-committee.
The Sub-committee’s session ended with tributes to Claude Pfauvadel, who had been a member of the French delegation since 1995 but is retiring this year, and to Katherine Rooney, who is soon to retire from her role at ICAO.
The 64th session of the TDG Subcommittee is doe to be held in Geneva from 24 June to 3 July.
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RISKY BUSINESS
RISK MANAGEMENT • US EPA’S PLANNED REVISION OF THE RISK MANAGEMENT PROGRAM HAS DRAWN WIDESPREAD CRITICISM FROM INDUSTRY BODIES
THE US ENVIRONMENTAL Protection Agency (EPA) published a final rule to amend its Risk Management Program (RMP) on 11 March this year; the changes, contained in the Safer Communities by Chemical Accident Prevention (SCCAP) rule, aim to stiffen the protection of vulnerable communities from chemical accidents, especially those living near facilities in industry sectors with high accident rates.
The final rule builds on the proposed SCCAP rule published in August 2022, following which EPA has received what it terms “robust stakeholder input”. It is noticeable that the changes to the RMP take up only 30 pages of a 268-page pre-publication version, with the vast bulk of the material being concerned with background, justification and analyses. The rule is effective as from 10 May 2024 and regulated
entities will have three years to come into compliance.
EPA says that, because major and other serious and concerning RMP accidents continue to occur, the final rule is needed so as to better identify and further regulate risky facilities to prevent accidental releases before they can occur. SCCAP maintains the approach of a rule-based, prevention-focused approach rather than a reactive, compliance-driven approach. It does, however, make several changes to the accident prevention program requirements, as well as enhancements to the emergency response requirements and improvements to the public availability of chemical hazard information, which are quite significant.
The final rule’s emphasis is on protecting communities most at risk of having an
accidental release from a facility in their midst. Under the final rule, facilities in these communities will be required to do more to prevent chemical accidents, including conducting a safer technologies and alternatives analysis (STAA), more thorough incident investigations, and third-party audits. The final rule also includes new prevention provisions that have not been addressed in prior RMP rules, including empowering workers to make safety decisions and report non-compliance.
The Agency is also increasing access to RMP facility information for fenceline communities in commonly spoken languages. EPA believes this final rule promotes transparency and gives more opportunities for the public and workers to be involved in accident prevention and emergency planning.
SCCAP also responds to an executive order from President Biden, EO 13990, that federal agencies review existing regulations and take action to address priorities established by the Biden Administration, which include bolstering resilience to the impacts of climate change and prioritizing ‘environmental justice’. Part of the new SCCAP rule will require regulated facilities to evaluate the risks of natural hazards and climate change, including any associated loss of power.
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INDUSTRY TALKS BACK
Publication of the SCCAP rule has drawn renewed criticism from industry bodies. The American Chemistry Council (ACC), for instance, said that the rule adds to “a surge in misguided regulations” that undermine the ability of chemical manufacturers to create essential products in the US and support the broader economy. “We are very concerned EPA has decided to abandon a collaborative and data-driven process which has helped decrease chemical related incidents by nearly 80 per cent since RMP was adopted,” says Dr Kimberly Wise White, vice-president of regulatory and scientific affairs at ACC. “Instead, the Agency has decided to remove important regulatory safeguards and impose unworkable mandates that could jeopardise the safety of facilities that provide vital contributions to critical sectors, including food production, water purification and energy production.”
Chet Thompson, CEO of the American Fuel & Petrochemical Manufacturers (AFPM), gave a similar opinion, saying: “The safety of employees, community neighbours and the environment is the top priority for every AFPM member company. Sadly, early readouts suggest this administration continues to miss the mark in releasing yet another regulation
more aimed at creating unnecessary red-tape and compliance burdens than improving safety performance. Through this major regulation, EPA is attempting to put even more barriers in the way of US fuel and petrochemical production. This rule is a litany of costs without clear, demonstrable benefits.”
The Society of Chemical Manufacturers & Affiliates (SOCMA) agrees, saying that EPA’s action “will further impede job creation, industry growth, reshoring of manufacturing, and securing the supply chain with a rule that lacks justifiable improvements to prevention of accidental releases”. In particular, the new requirements for STAA and third-party audits will be an especial burden for specialty chemical manufacturers, which are primarily batch manufacturers. SOCMA is also concerned about the new information disclosure requirements, which, it says, ignore security issues and the protection of confidential business information.
DISTRIBUTORS CALL FOR CHANGE
The Alliance for Chemical Distribution (ACD) is similarly aghast at the new provisions. Its president/CEO, Eric R Byer, had this to say: “For years, RMP has been a success story, preventing chemical accidents and improving preparedness, environmental stewardship,
and community partnerships. ACD members not only play an integral role in the US economy, but also uphold the highest standards of safety and security through their certification in our mandatory Responsible Distribution program.
“One of the rule’s most disturbing aspects is its potential to serve as a roadmap for terrorists aiming to weaponise chemical facilities,” Byer continues. “Under this rule, regulated facilities must disclose sensitive information to any individual residing, working, or spending significant time within a six-mile radius. The lack of a ‘need to know’ or vetting requirement for information requests will heighten the risk of sensitive chemical information falling into the wrong hands. This is particularly alarming given the expiration of the Chemical Facility Anti-Terrorism Standards (CFATS) program in July 2023, which has already increased vulnerability of chemical operations to terrorist attacks.
“In addition, the rule will undoubtedly place additional financial strain on ACD members that are already compliant, particularly at a time when many are financially strained. Rather than imposing complex new requirements that will create additional security concerns and confusion for many businesses, EPA should dedicate its efforts to non-compliant chemical facilities, ensuring all facilities understand their safety and environmental regulatory obligations. By implementing this final rule, EPA risks facilities defunding critical and proven mitigation resources to finance these new requirements.
“The bottom line is that this rule is completely unnecessary and counterproductive to ensuring the security of our member company facilities and the surrounding communities at those locations. It is yet another example of this Administration’s misguided actions that will result in the shuttering of America’s small businesses
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REVISIONS TO THE RMP RULE WILL IMPOSE BURDENSOME NEW DUTIES ON A WIDE RANGE OF ENTERPRISES, INCLUDING SMALL COMPANIES
instead of incentivizing their growth and expansion. The Alliance wholeheartedly opposes this final rule and will take the necessary steps to continue to fight it,” Byer concludes.
TOPICS TO CONSIDER
It is, of course, an election year in the US so, while the final rule will enter into force as it stands, there is the possibility that it will be once more diluted, as it was in 2019. EPA published amendments to the RMP rule in 2017 in response to another executive order, EO 13650, but many of these changes were rescinded by a further EPA rule in 2019. Both the 2017 and 2019 rules are awaiting resolution of petitions for judicial review.
Industry associations will have this in mind as they continue to battle against SCCAP’s additional burdens.
Indeed, it does seem perverse that RMP will now require chemical facilities to reveal details of their processes and the chemicals they handle and store, at the same time as CFATS, which aims specifically to keep that sort of information out of the hands of potential malefactors, remains in abeyance. Worryingly, the Department for Homeland Security (DHS), in its response to President Biden’s budget proposals, which seeks a 10 per cent increase in DHS funding compared to last year, makes no mention at all of CFATS.
It is not just CFATS; EPA received a number of comments prior to publication of the final rule pointing out that the information sharing provisions proposed were contrary to the Critical Infrastructure Information Act of 2002 and in conflict with the Maritime Transportation Security Act.
There is another issue within SCCAP that will be of concern to those involved in the transport of hazardous materials, namely a limitation on the time that “transportation containers” –which would include tank trailers, rail tank cars and ISO tank containers – may be disconnected from their motive power (tractor unit, locomotive, etc) without coming into scope of RMP as a stationary source. EPA included this change in its proposals, which it said is merely a case of including a definition for “storage not incident to transportation”, but it has not made it to the final rule.
However, in the intervening period, there have been a few legal cases that have given weight to EPA’s position. Among these was a decision by the Eastern District Court of Washington against Multistar Industries, which ruled that the use of railcars for the storage of trimethylamine in Othello, Washington, involved storage outside the scope of transportation and therefore was subject to EPA’s RMP rule.
Meanwhile, EPA has acknowledged concerns raised by industry about establishing a single timeframe and it is choosing to consider the question more closely before making a change. It will also take into account the need to maintain “the regulatory division of labour” between EPA and DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA). A similar consideration relates to the Occupational Safety and Health Administration (OSHA), whose Process Safety Management
(PSM) requirements also apply to transport containers containing highly hazardous chemicals when they are disconnected from their motive power.
There is some overlap between OSHA’s PSM requirements and those in EPA’s RMP and there were some comments to the effect that the two should remain consistent and have the same timetable for updates. EPA says it has coordinated with OSHA during the rulemaking process to ensure that no conflicting requirements are introduced.
All the documents related to the SCCAP rulemaking can be found on the US government website at www.regulations.gov/document/ EPA-HQ-OLEM-2022-0174-0488. Further information and guidance is provided on the EPA website at www.epa.gov/rmp/risk-managementprogram-safer-communities-chemical-accidentprevention-final-rule.
20 HCB MONTHLY | APRIL 2024
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BITS AND BOBS
USA • PHMSA HAS FINALISED A MISCELLANEOUS RULEMAKING BASED ON PETITIONS FROM INDUSTRY, MAKING SEVERAL TECHNICAL CHANGES AS WELL AS MORE GENERAL AMENDMENTS
THE US PIPELINE and Hazardous Materials Safety Administration
(PHMSA) has published its final rule under docket HM-219D, making a range of amendments to the Hazardous Materials Regulations (HMR) in response to petitions from stakeholders and internal efforts to clarify and update existing provisions. PHMSA says the revisions “maintain or enhance the existing high level of safety under the HMR while providing clarity and appropriate regulatory flexibility in the transport of hazardous materials”.
PHMSA published its plans in a notice of proposed rulemaking (NPRM) in March 2023 (HCB May 2023, page 50) and the final rule appeared almost exactly a year later. While it includes a range of amendments, these are focused primarily on hazard communication issues, packaging (especially for gas
cylinders) and updates to documents incorporated by reference. PHMSA received 14 sets of comments on the NPRM from eight separate entities, three of which were among those that had submitted petitions for changes to HMR.
GAS CYLINDERS
The Compressed Gas Association (CGA) had petitioned for an amendment to §173.302b to implement packaging restrictions for the transport of compressed natural gas (CNG) and methane in UN seamless steel pressure receptacles with a tensile strength greater than 950 MPa. CGA said that higher strength steel pressure receptacles are more susceptible to embrittlement from any contaminants in the CNG, making them more likely to fracture. Currently there are no
specific requirements for the use of UN pressure receptacles in CNG or methane service in HMR.
This issue goes back some way; CGA had submitted a petition in 2015 that was denied by PHMSA on the grounds that it would conflict with existing provisions for DOTspecification (3AX, 3AAX and 3T) cylinders. The new petition from CGA avoided that conflict and it found favour with PHMSA; no adverse comments were received after the NPRM so it is going ahead with the change, which is found in a new §173.302b(f):
(f) Methane, compressed, or natural gas, compressed, UN1971. Methane, compressed, or natural gas, compressed, is authorized in a UN seamless steel pressure receptacle under the following conditions:
(1) For methane, and for natural gas with a methane content of 98.0 percent or greater—
(i) The maximum tensile strength of the UN seamless steel pressure receptacle may not exceed 1100 MPa (159,542 psi); and
(ii) The contents are commercially free of corroding components.
(2) For natural gas with a methane content of less than 98.0 percent—
(i) The maximum tensile strength of the UN seamless steel pressure receptacle may not exceed 950 MPa (137,750 psi);
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(ii) Each discharge end of a UN refillable seamless steel tube must be equipped with an internal drain tube; and
(iii) The moisture content and concentration of the corroding components must conform to the requirements in § 173.301b(a)(2).
FIBA Technologies had petitioned for a revision to the requirements for repairing seamless DOT 3-series specification cylinders and seamless UN pressure receptacles without external threads, and also to authorise such repairs without requiring prior approval from PHMSA. This relates in particular to the machining of new threads, especially on (very) old cylinders that were not originally fitted with a threaded neck.
PHMSA conducted a technical review and determined that the practice as outlined by FIBA represents an improvement in safety and, having received no dissenting comments, adopted a revision to §180.212b(2) so that it now reads:
External rethreading of a DOT 3AX, 3AAX, or 3T specification cylinder or a UN pressure receptacle, and external threading of a seamless DOT 3AX, 3AAX, or 3T specification cylinder or seamless UN pressure receptacle originally
manufactured without external threads; or the internal rethreading of a DOT–3 series cylinder or a seamless UN pressure receptacle when performed by a cylinder manufacturer of these types of cylinders.
The repair work must be performed under the supervision of an independent inspection agency. Upon completion of the rethreading or post-manufacture threading, the threads must be gauged in accordance with Federal Standard H–28 or an equivalent standard containing the same specification limits.
The rethreaded cylinder or UN pressure receptacle must be stamped clearly and legibly with the words ‘‘RETHREAD’’ and a postmanufacture threaded cylinder or UN pressure receptacle must be stamped clearly and legibly with the words ‘‘POST–THREAD’’, on the shoulder, top head, or neck. No DOT specification cylinder or UN pressure receptacle may be rethreaded more than one time without approval of the Associate Administrator.
FIBA Technologies also petitioned for an amendment to §173.302a(c) regarding the special filling limits for DOT specification 3A, 3AX, 3AA, and 3AAX cylinders containing Division 2.1 flammable gases. FIBA argued
that, when DOT Special Permit 6530 was incorporated into HMR to allow the transport in commerce of hydrogen and mixtures of hydrogen with helium, argon, or nitrogen in certain cylinders filled to 10 per cent in excess of their marked service pressure, safety control measures were included in §173.302a(c)(3) rather than in (c), and that the measures can therefore be interpreted wrongly.
PHMSA agreed with this, and also FIBA’s suggestion that such cylinders should be marked with the plus sign (+) after the test data marking, as well as another comment that such cylinders should also be equipped with a pressure relief device in accordance with CGA S-1.1. This latter point involves removing the existing requirement in §173.302a(c)(4) and adding a new §173.302a(c)(6).
PACKAGING AND MARKING
The Council on Safe Transportation of Hazardous Articles (COSTHA) petitioned for an amendment to §173.4b so as to harmonise the de minimis exceptions for Division 6.1, Packing Group I (no inhalation hazard) materials with international regulations, including the International Civil Aviation Organisation (ICAO) Technical Instructions (TIs) and the International Maritime Dangerous Goods (IMDG) Code. PHMSA had already aligned the de minimis quantities for Division 6.1, PG II and III materials.
Reviewing the history, PHMSA discovered that the international regulations had included de minimis quantities for Division 6.1, PG I materials on the basis of a proposal by the US. It also noted that it had previously concluded that making the same change in HMR posed no additional safety hazard. As such, and in the absence of any comments opposing the proposal, it has adopted the requested amendment.
COSTHA had also petitioned for an
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MUCH OF THE TECHNICAL WORK ON GAS CYLINDER STANDARDS IS OF NECESSITY THE WORK OF THE COMPRESSED GAS ASSOCIATION
amendment to §173.185(c)(3) to clarify that lithium button cell batteries installed in equipment are excepted from the marking requirement and not subject to the quantity per package or per consignment limitation. The Council said that the current wording allows an alternative interpretation and noted that several requests for clarification had been received by PHMSA, indicating the level of confusion among the regulated community.
PHMSA recalled that the provision was part of the HM-224F rulemaking, which intended to bring HMR into line with the ICAO TIs and IMDG Code and agreed that the requested amendment would clarify the applicability of the exception in §173.185(c)(3). Again receiving no comments in opposition, it has now revised the introductory language to that paragraph to read:
Lithium battery mark. Each package must display the lithium battery mark except when a package contains only button cell batteries contained in equipment (including circuit boards), or when a consignment contains two packages or fewer where each package contains not more than four lithium cells or two lithium batteries contained in equipment.
CGA had petitioned PHMSA to authorise an alternative description of gas mixtures containing components defined as liquefied gases, to allow a gas mixture with components that meet the definition of liquefied compressed gas in §173.115(e) to be described as a ‘compressed gas’ when the partial pressures of the liquefied gas components of the mixture are intentionally reduced so that liquefaction does not occur at 20°C.
PHMSA had conducted a technical review of the proposal and found that the approach is feasible and may slightly improve safety. It did not, though, agree with CGA that a special provision should be used to allow the ‘compressed gas’ description. PHMSA believes that the most appropriate change is to amend the definition of a non-liquefied compressed gas in §173.115(e), which should make the change clearer for all stakeholders: Liquefied compressed gas. A gas, which when packaged under pressure for transportation is partially liquid at temperatures above -50 °C (-58 °F), is considered to be a liquefied compressed gas. Gas mixtures with
component(s) that are liquefied gases may be described using the hazardous materials description of a compressed gas in the Hazardous Materials Table in § 172.101 of this subchapter when the partial pressure(s) of the liquefied gas component(s) in the mixture are reduced so that the mixture is entirely in the gas phase at 20 °C (68 °F). A liquefied compressed gas is further categorized as follows:
The Sporting Arms and Ammunition Manufacturers’ Institute (SAAMI) had petitioned PHMSA to amend §178.503(a)(6) to allow UN performance-oriented boxes (4A, 4B, 4N, etc) to be marked with the last two digits of the year of testing certification rather than the last two digits of the year of manufacture. In addition, SAAMI proposed to add an additional selective testing variation in §178.601(g) to allow for variation of packagings that include articles containing solid hazardous materials, packed in inner packagings without further testing, subject to certain conditions.
SAAMI’s proposals drew both supportive and opposing comments. PHMSA followed suit: it did not accept the proposal to change the date marking, noting that the minor cost savings this would generate did not justify the disharmony with international regulations that would result. PHMSA did, though, accept SAAMI’s proposal to add a new packaging variation in §178.601(g)(6):
Selective testing of combination packagings for articles containing small arms ammunition: Variation 6.
Variations in inner and intermediate packagings are permitted in packages for articles containing Cartridges, small arms (UN0012); Cartridges for tools, blank (UN0014); Primers, cap type (UN0044); and Cases, cartridge empty with primer (UN0055) packed in inner packages without further testing of the package under the following conditions:
(i) The package has been tested containing only the articles to be transported without intermediate containment;
PHMSA HAS RESPONDED TO INDUSTRY AND AMENDED THE DEFINITION OF LIQUEFIED COMPRESSED GAS
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material manufactured outside the US and classified using the penetrometer test may not be reshipped within the US without first performing the ASTM D 4359 test.
PHMSA conducted a technical review of the penetrometer test and found that it is more empirical in nature than ASTM D 4359 and provides better understanding of the physical properties of the tested material. PHMSA did not receive any comments in opposition to the proposed revision so is revising the definition of ‘liquid’ in §171.8 as proposed.
INCORPORATION BY REFERENCE
(ii) The outer packaging must have passed the stacking test set forth in § 178.606 when empty, i.e., without cushioning or inner or intermediate packagings, with the test mass of identical packages being the mass of the package filled with the articles;
(iii) Only articles tested without intermediate containment may be transported; however, a variety of articles tested in this fashion may be assembled in a package with intermediate containment;
(iv) No articles demonstrate a loss of material in testing; and
(v) The completed package does not exceed the marked maximum gross mass of the package. Evonik petitioned PHMSA to revise §172.514(c) by adding an option for smaller placards for IBCs carrying combustible liquids by adopting the provisions in DOT Special Permit 16295 into HMR. This would allow shippers to transport IBCs containing combustible liquids (NA 1993) bearing a combustible placard sized to be consistent
with the label size specifications in §172.407(c), i.e. 100 mm on each side rather than 250 mm. Evonik said that this would allow more space for proper placarding and marking placement due to the commonly limited space available to display hazard information on the IBC side plates and panels. Evonik pointed to other similar provisions applicable to more hazardous materials than combustibles.
PHMSA felt that the proposal would not change the safety requirements but would provide greater flexibility. It had also taken the proposal another step and sought comments on whether it would be sensible to make the same change for portable tanks; this drew only one comment, which was positive. As a result, PHSMA is now revising §172.514(c)(1) and (4) to allow IBCs and portable tanks containing combustible liquids to be placarded with a combustible placard that meets the label size specifications in §172.407(c).
COSTHA petitioned PHMSA to modify the definition of ‘liquid’ in §171.8 by including the penetrometer test found in ISO 2137:1985, which is prescribed in ADR, and allowed as an alternative to the ASTM D 4359 test in the ICAO Technical Instructions and the IMDG Code. COSTHA pointed out that, at present, a
HMR includes a large number of references to industry standards and these references need to be kept current. Many of the referenced documents relate to gas cylinders and CGA had asked PHMSA to add another, CGA C-20 Requalification Standard for Metallic, DOT and TC 3-Series Gas Cylinders and Tubes Using Ultrasonic Examination (second edition, 2014). CGA also proposed revising §180.205 to reflect the ultrasonic examination (UE) methods authorised by CGA C-20. CGA said that bringing this standard into HMR would eliminate the need for PHMSA to issue special permits and would also harmonised the various UE methods.
PHMSA noted that it had taken part in the development of CGA C-20 and had completed a technical review of the final standard. It felt that referencing the standard would have a positive effect on safety by prescribing appropriate procedures for applying UE as the requalification method for DOT/TC 3-series cylinders and tubes.
PHMSA did not receive any comments opposing the move so is going ahead with adding a reference to the standard in §171.7 and making the requested changes in §180.205. In addition, §180.205(i)(C) is amended to read:
As an alternative to the stamping or labeling as described in this paragraph (j)(2), at the direction of the owner, the requalifier may render the cylinder incapable of holding pressure. If a condemned cylinder contains hazardous materials, the requalifier must stamp the cylinder ‘‘CONDEMNED’’ and affix a readily visible label on the cylinder stating: ‘‘UN REJECTED, RETURNING TO ORIGIN FOR
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A LOT OF INFORMATION NEEDS TO BE SHOWN ON AN IBC AND PHMSA AGREED THAT IT IS SENSIBLE TO ALLOW A SMALLER LABEL
noted that, although HMR does not currently reference CGA C-23, it has been referenced as a safety control in special permits. PHMSA did, though, say that it found CGA’s proposals for §§180.205(d)(5) and 180.207(d)(1)(iii) to be too vague.
PROPER DISPOSITION.’’
The requalifier may only transport the condemned cylinder by private motor vehicle carriage to a facility capable of safely removing the contents of the cylinder.
CGA also petitioned for the incorporation by reference of CGA C-23 Standard for Inspection of DOT/TC 3 series and ISO 11120 Tube Neck Mounting Surfaces (second edition, 2018) in §171.7 and revise §§180.205 and 180.207 to reference its requirements.
CGA C–23 defines a tube as a seamless pressure vessel authorized for transportation only when horizontally mounted on a motor vehicle or in an ISO framework. Tube modules are also commonly known as skid containers, ISO skids, ISO containers, or MEGCs (multiple-element gas containers). PHMSA
In the final rule, PHMSA is adopting the reference to CGA C-23 in §171.7. In addition, it is revising 180.207(d)(1)(ii) to read:
Each seamless steel UN pressure receptacle that is horizontally mounted on a motor vehicle or in a framework and that: is 12 feet or longer; has an outside diameter greater than or equal to 18 inches; and is supported by a neck mounting surface during transportation must be inspected at the time of requalification in accordance with CGA C–23 (IBR, see § 171.7 of this subchapter).
Notwithstanding the periodic inspection, if the seamless steel UN pressure receptacle shows visible corrosion, as outlined in Section 4.2 of CGA C–23, around the neck or under the flange/ sleeve, then it must be removed and examined in accordance with Section 6 of CGA C–23 prior to returning to service.
CGA petitioned for the inclusion of the new
CGA C-27 Standard Procedure to Derate the Service Pressure of DOT 3-Series Seamless Steel Tubes (first edition, 2019). PHMSA issued a guidance document on the subject in 2013 and determined that the CGA standard offers essentially the same instructions. As such, there was no opposition to including a reference to the CGA document in §171.7, with a new §180.212(a)(4) to give instruction on derating cylinders:
DOT 3-series seamless steel tubes with an outside diameter greater than 9⅝ in (244.5 mm) may be processed by a repair facility for derating the marked service pressure in accordance with CGA C–27 (IBR, see § 171.7 of this subchapter). Some other CGA documents have been updated and PHMSA has moved to reference the more recent edition in HMR. This applies to:
• CGA C-7 Guide to Classification and Labeling of Compressed Gases, 11th edition (2020)
• CGA C-29 Standard for Design Requirements for Tube Trailers and Tube Modules, first edition (2019), which replaces CGA TB-25 Design Considerations for Tube Trailers
• CGA V-9 Standard for Compressed Gas Cylinder Valves, eighth edition (2019)
The Institute of Makers of Explosives (IME) petitioned PHMSA to update its reference to IME SLP-23 Recommendations for the Transportation of Explosives, Division 1.5; Ammonium Nitrate Emulsions, Division 5.1; and Combustible Liquids in Bulk Packagings. HMR currently incorporates the 2011 edition of SLP-23 but the 2021 edition aligns more easily with HMR, IME said. It also features two specific substantive changes, viz the deletion of the Vented Pipe Test (VPT); and allowing operators to continually monitor driver qualifications and training instead of conducting an annual audit. In addition, IME sought the adoption into HMR of DOT Special Permit 8723, which authorises the transport of UN 0332, 3375 and 3139 in IM 101 and 102 portable tanks; IME argued that this should have been done when the 2011 edition of SLP-23 was incorporated but it was overlooked.
PHMSA agreed with the proposal to reference the 2021 edition of SLP-23; it did not, though, agree with the deletion of the
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PHMSA HAS UPDATED REFERENCES TO STANDARDS FOR THE TRANSPORT OF EXPLOSIVES AFTER WORK BY INDUSTRY
VPT, noting that, while the UN Sub-committee of Experts on the Transport of Dangerous Goods has discussed the matter, those discussions are continuing. If the Subcommittee deletes the VPT then PHMSA may reconsider. PHMSA also agreed with IME’s proposal regarding the annual audit.
There is also an issue regarding the carriage of these substances in portable tanks and in IBCs. A DOT Special Permit authorises the use of UN T11 portable tanks for the carriage of UN 0331, 3375 and 3139 and there is another special provision that authorises the transport of blasting materials and ammonium nitrate emulsions (ANE) in certain IBCs. IME noted that there are no IBC packaging codes for NA 0331 or UN 0331 and 0332 in column (7) of the Hazardous Materials Table and, therefore, their transport in IBCs is currently prohibited.
IME intends to insert provisions in SLP-23 to allow portable tanks and IBCs to be used
and it also felt that it was not PHMSA’s intention to exclude them. However, PHSMA – while encouraging IME to submit a petition for rulemaking once it has further updated SLP-23 – could not make any change at this point, as it had not been part of the NPRM. PHMSA did, though, update the reference in §171.7(r)(2); it revised special provision 148 to clearly state that the VPT requirements in the 2011 edition of the IME standard will still apply; it added a new special provision TP48 in §172.102(c)(8) to authorise the use of IM 101 and 102 portable tanks for ANEs (UN 0332, 3375 or 3139) when transported under SLP–23 (2021); and revised §173.251 to state that the section is not applicable to UN 3375 when transported in IM 101 or 102 portable tanks in accordance with SLP-23 (2021).
IME also petitioned PHMSA to update its reference to IME SLP-22 Recommendations for the Safe Transportation of Detonators in a Vehicle with Certain Other Explosive Materials.
HMR currently references the 2007 edition but IME issued an update in 2019, which includes technical corrections, practical improvements, and deletion of outdated practices. PHMSA had already conducted a technical review of the updated edition and was happy to update the reference in §171.7(r)(1).
OTHER MATTERS
The NPRM under docket HM-219D included a proposal to phase out the authorisation of non-refillable cylinders (mainly DOT 39 cylinders) for the transport of hydrofluorocarbon gases (HFCs), to fit in with the planned phaseout of the use of HFCs by the US Environmental Protection Agency (EPA) to implement some provisions of the American Innovation and Manufacturing (AIM) Act of 2020.
PHMSA received several comments that its proposal went beyond the Administration’s authority; in addition, the US Court of Appeals of the District of Columbia ruled in June 2023 that EPA’s phasedown rule for HFCs included two provisions that were outside EPA’s statutory authority. Following this decision, PHMSA is no longer tackling the issue in this rulemaking.
PHMSA had also proposed amending the conditions necessary for the emergency processing of special permit requests, as explained in §107.117. This section provides a way for the Associate Administrator to issue special permits to address an imminent safety issue, threat to national security or to prevent significant economic loss. PHMSA felt the need to add another criterion to this list to allow the emergency issuance of a special permit in support of certain essential governmental functions, both for US and foreign governments. It received no comments opposing the idea and, as a result, has now split §107.117(a)(2) into two paragraphs – (a) (2) and (a)(3) – and added a new (a)(4):
Emergency processing is necessary in support of an essential governmental (domestic or foreign) function that could not be satisfied if the application were processed on a routine basis.
The final rule was published in the Federal Register on 4 March and became effective on 3 April; compliance is required by 4 March 2025.
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INTENSIVE CARE
RESPONSIBLE CARE • FOR EUROPE’S CHEMICAL LOGISTICS SECTOR, ECTA PROVIDES THE DOORWAY TO RESPONSIBLE CARE COMPLIANCE. IT HAS JUST UPDATED ITS RESPONSIBLE CARE CHARTER
IN 2008, THE European Chemical Transport Association (ECTA) signed an agreement with the European Chemical Industry Council (Cefic) to develop a Responsible Care programme for ECTA members. As part of that agreement, transport companies looking to join the ECTA Responsible Care programme were required to sign a letter to demonstrate their commitment to the Core Principles of Responsible Care.
In the years since, those nine basic principles have not changed. However, the world has moved on and in 2019 ECTA decided to refine some parts of the programme, which resulted in the ECTA Responsible Care 2025 programme. A further update has now been developed, ECTA Responsible Care 2030, with four specific areas being subject to redefinition or made more specific. The limitation of waste: In addition to the focus on prevention of plastic pellet loss illustrated through ECTA’s support for Operation Clean Sweep, its members realise
the importance of the circular economy and encourage the use of alternative fuels derived from waste streams and encourage the use of recycled materials.
The limitation of emissions: ECTA will continue to align with the targets set within the EU through the Green Deal and Fit for 55 programmes. It supports and encourages standardised emission reporting in line with ISO14083 and the GLEC Framework and believes in a far-sighted road map for emission reduction which includes:
• facilitating the switch from road to intermodal journeys
• new engine and fuel technologies, and
• supporting infrastructure required to promote widespread adoption of these technologies.
Over the coming years, many of ECTA’s members will need to meet the requirements of the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS).
ECTA will strive to support and inform the members of their duties under these new directives.
The limitation of injury incidents: In order to continue to drive incident rates down, ECTA will seek closer collaboration with Cefic to influence the loading and unloading plants to keep driver and operator safety at the forefront of their operations. In addition, ECTA will continue to encourage its members and their supply chain partners to promote behavioural based safety initiatives. Equality, diversity and inclusion: As a new focus area under Responsible Care, ECTA will create awareness and include commitments to Equality, Diversity & Inclusion in support of UN social development goals. More specifically, ECTA will support a ‘Women in Logistics’ initiative to strive to create an environment and culture in chemical logistics that recognises the value of gender equality.
TOOLS TO HELP
ECTA now invites all of its stakeholders to join in its efforts to work towards improvements and to ensure that the environmental, social and economic values of ECTA’s Responsible Care 2030 programme are of significance in helping to achieve the challenging sustainability targets that have been set. Meanwhile, ECTA is continuing to provide critical information to its members on sustainability issues through its Zero Emissions Knowledge Platform, as part ~ of its Responsible Care Programme. The latest additions to the platform, which has its own website at https://knowledgeplatform. ecta.com, cover topics such as Scope 3 emissions calculation, hydrogen as a fuel for heavy goods vehicles, and the prospects of developing a global hydrogen supply network.
ECTA also organises webinars under the Knowledge Platform umbrella; the next such event is scheduled to take place on 14 May, discussing progress and challenges with the transition to zero emissions vehicles. ECTA also organises an annual Responsible Care training workshop in Brussels (and online), which this year is scheduled to take place on 19 September. ecta.com
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MANUAL TRANSMISSION
ERG • NO FIREFIGHTER IN NORTH AMERICA WOULD GO TO A HAZMAT SHOUT WITHOUT IT. THE 2024 EDITION OF THE EMERGENCY RESPONSE GUIDEBOOK IS ABOUT TO LAND
THE EMERGENCY RESPONSE Guidebook
(ERG) is the must-have for all first responders in the US, Canada and Mexico. Updated every four years, ERG provides them with the information they need in the initial response phase to an incident involving the transport of hazardous materials. The US Department of Transportation (DOT) says its goal is to have a copy of ERG in every public emergency service vehicle nationwide – to date more than 16 million free copies have been distributed to emergency responders in the US alone, and it is also available as a free smartphone app.
Updating ERG is quite a task, involving the joint expertise of the US Pipeline and
Hazardous Materials Safety Administration (PHMSA), Transport Canada and Mexico’s Secretaría de Comunicaciones y Transportes (SCT), and ensuring it is available in English, French and Spanish. The 2024 editions are now being printed and should be available for distribution this month.
SO, WHAT’S NEW?
PHMSA has provided a brief summary of the major changes in the 2024 edition. To a large extent, these derive from changes that have appeared in recent revisions to the UN Model Regulations and the international and national regulations that take their lead from the UN,
which include the US Hazardous Materials Regulations (HMR), Canada’s Transportation of Dangerous Goods Regulations (TDGR), and Mexico’s various relevant Normas (NOMs).
For instance, 11 new UN numbers appear in the latest ERG (UN 3550 to 3560) and eight have been deleted as obsolete. In addition, though, the assignment of 19 UN numbers to appropriate guides (in the orange pages) have changed – experienced users of ERG will need to take note, since the appropriate method of response has altered, in some cases significantly.
The first section of ERG – the white pages – includes some revisions and additions. Aside from the necessary updates to track regulatory changes, the road tanker and rail car identification charts have been expanded and there is a new table to help in deciding whether evacuation or shelter-in-place is the better option. A new liquid spill control methods section has been added, which provides guidance on the types and uses of absorbent materials. Not surprisingly, there is a new section on fires involving lithium batteries and electric vehicles, while the advice regarding chemical and biological warfare agents has been widely revised and expanded.
General first aid recommendations have been separated from the individual guides, which now only include material-specific first aid information. There have also been some changes to several of the guides, many including additional response guidance or safety information.
In the green pages towards the end of the book, chemical warfare agents have been removed from table 1 and are now dealt with in the section on the criminal or terrorist use of chemical, biological and radiological agents. Also in the green pages, recommended distances have been revised in tables 1 and 3.
ERG 2024 is also available in electronic format in all three languages and for both iOS and Android devices; the printed edition will include QR codes to go directly to the app and these can also be found in PHMSA’s document with the summary of changes, which can be found at www.phmsa.dot.gov/training/hazmat/ erg/erg2024-summary-changes.
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SAFETY 29
OPEN THE BOX
MARITIME • WSC HAS PICKED NCB TO PROVIDE ITS PLANNED CARGO SAFETY PROGRAM, WHICH AIMS TO IDENTIFY AND REMOVE MISDECLARED AND UNDECLARED DANGEROUS GOODS
CHOOSE THE BEST
Regular HCB readers will be not in the least surprised that NCB has been selected as the independent provider of the Cargo Safety Program digital platform, six months after the plan was announces. NCB is a non-profit organisation with decades of experience in container inspection and, through its Hazcheck software, is already involved in the detection, inspection and validation of dangerous goods in maritime cargo.
The WSC Cargo Safety Program solution will be an evolution of that platform, building on Hazcheck Detect, a proven cargo screening tool currently processing more than 10 million bookings per month. The system emphasises the importance of standardisation and a unified approach to cargo screening and inspection, including a feedback loop for inspection results, ensuring that safety procedures are consistent and comprehensive.
THE LAST DECADE has seen an increase in incidents involving the transport of dangerous goods by sea, with a worrying number involving casualties and total losses. According to insurer Allianz, there have been over 64 reported fires on containerships alone over the past five years. Allianz comments: “The cause of many cargo fires can be attributed to mis-declared dangerous goods, such as chemicals, batteries and charcoal. Failure to properly declare, document and pack hazardous cargo can result in containers stowed incorrectly or hampering of firefighting efforts.”
The World Shipping Council (WSC), which represents the world’s container shipping lines, shares the increasing concern about this development, which it is aiming to address through a new Cargo Safety Program. While some of its members have already put in place screening systems to interrogate bookings and look for non-compliant shipments, the nature of the liner shipping business is such that mis-declared and undeclared dangerous goods can end up on any ship at any time.
WSC’s Cargo Safety Program will rely on a digital solution provided and operated by an independent entity; it will consist of a common screening tool, a verified shipper database, and a database of approved container inspection companies. The core functionality of the system will be to screen booking information against a comprehensive keyword library and risk algorithm. High-risk bookings will be flagged for further investigation and/or inspection, and lessons learned through experience will be used to continuously improve the screening tool.
The emphasis is on identifying and correcting worrying conditions before containers with dangerous cargoes are introduced into the supply chain. WSC expects that this common safety approach will significantly mitigate the risks associated with non-declared or improperly declared, labelled or packed dangerous goods across the supply chain. At the same time, the system will streamline the transport of compliant dangerous goods in line with national and international regulations.
“WSC and NCB have a shared commitment to the safety of life and cargo at sea,” explains John Butler, president/CEO of WSC. “With NCB’s considerable expertise and experience, the Cargo Safety Program is a substantial new tool for making workplaces safer for ship crews, transport workers, and communities, as well as enhancing operational efficiency for shippers.
“A common industry approach to cargo safety will create a safer working environment not only for ship crews, but for everyone involved in inland transport or working in ports and terminals, as well as for the communities around us,” Butler adds. “For shippers, it will make ocean transport more efficient and dependable, by stopping dangerous shipments that can disrupt the supply chain.”
“As an organisation founded with the purpose of preventing maritime disasters through the enhancement of safety, we are honoured to be selected to deliver this solution and are excited to witness the collaborative benefits of a global, standardized approach to cargo screening and inspections. This is truly a transformational step for the industry,” says Ian Lennard, NCB president/CEO.
natcargo.org
www.worldshipping.org
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30
FIGHTING FIRES WITH ALCOHOL
METHANOL • ONE FACTOR MITIGATING AGAINST THE ADOPTION OF NEW FUELS FOR SHIP PROPULSION IS SAFETY ONBOARD. EXISTING FIRE SAFETY MEASURES MAY NOT COPE
A NEW FIRE safety study by global survival technology solutions provider Survitec reveals that existing fire-fighting methods used to extinguish machinery space spray and pool fires on conventionally fuelled vessels are inadequate when dealing with methanolbased fires. Survitec carried out extensive comparative fire tests on dual-fuel marine engines using diesel and methanol, amid growing interest in methanol as an alternative marine fuel.
“Our tests confirm that traditional water mist fire suppression mechanisms do not perform as expected on methanol pool fires and methanol spray fires. A completely different approach is required if these ships are to remain safe,” says Michal Sadzynski, product manager, Water Mist Systems, at Survitec.
Methanol (CH3OH) burns in a completely
different way than hydrocarbon fuels and has a much lower flashpoint - 12°C (54°F). However, while there are established fire safety regulations and testing standards for diesel, clear test protocols for alcohol-based fuels such as methanol and ethanol have yet to be developed.
“We believe this is a high-risk situation that needs immediate action,” Sadzynski stresses. “Methanol fires are far more aggressive than fires involving traditional hydrocarbon fuels. Methanol fires have different physicochemical properties and so they cannot be extinguished as easily or with the same approach.”
TAKE ANOTHER LOOK
The Survitec tests found that while water mist systems are highly effective in absorbing heat and displacing oxygen on diesel fires, they do not produce the same results on methanol
fires. “We had to completely rethink nozzle placement, spacing and other factors to make water mist suppression effective on methanol. For instance, the range for nozzle installation height is much lower than that needed to put out a diesel fire,” Sadzynski says.
This indicates that if existing vessels are retrofitted to run on methanol, their fixed fire-fighting arrangement would need to be completely overhauled and redesigned. For bilge areas, statutory rules formulated in IMO MSC.1/Circ.1621 establish a requirement for an approved alcohol-resistant foam system for ships running on methanol. For the first time, a fixed, low-expansion foam system is mandatory under the rules when it comes to protecting machinery space bilges.
“Our tests demonstrate that standard discharge devices do not properly extinguish methanol pool fires in the confined bilge space. It is crucial to deliver properly expanded foam on the methanol pool fire and this is not an easy task within such a narrow space where throw length is limited,” explains Maciej Niescioruk, product manager, Foam Systems, at Survitec.
“MSC.1/Circ.1621 provides us with a starting guideline but it is very general and therefore open to interpretation. Moreover, methanol compliance for Local Application Firefighting (LAFF) systems is not yet covered. As an industry, we need to come together and develop comprehensive and robust fire test standards and safety rules tailored to methanol’s unique properties,” Niescioruk adds.
Orders for methanol-fuelled newbuilds increased by 9 per cent in the last 12 months, faster than those for LNG-fuelled ships. Analysts suggest the methanol-fuelled fleet will account for 20m gt by 2028. “We are seeing a significant uptake in orders for methanolfuelled vessels, with 2023 being the breakout year for this alternative marine fuel. With more methanol-powered ships being built every year, the industry must act now to prevent dangerous gaps in fire safety,” says Niescioruk.
“We encourage all stakeholders to come together to address methanol’s unique fire risks and create clear standards, new testing protocols and updated safety rules for methanol.”
www.survitecgroup.com
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KEEP IT CLEAN
MARINE SALVAGE • LAST YEAR SAW A FURTHER DECLINE IN THE NUMBER OF POLLUTION PREVENTION SERVICES BY SALVORS – BUT THE THREAT OF MARINE POLLUTION STILL EXISTS
MARITIME ACCIDENTS HAVE been big news over the past couple of years, perhaps more so than at any time since the bad old days of tanker accidents in the 1970s and 1980s. But these days, those accidents tend to involve containerships closing waterways or crashing into bridges, rather than thousands of tonnes of oil washing up on the shore.
But such events do still happen, though as the International Salvage Union (ISU) reveals in its annual prevention survey, the downward trend is continuing. Last year, ISU members provided 173 services to vessels at risk of causing a marine pollution incident, down from 186 in 2022. The total quantity of potential pollutants also fell, from 2.49m tonnes to 1.92m tonnes, with most of that fall accounted for by declines in the volume of dry bulk pollutants and containers. In contrast, the volume of most liquid bulk cargo increased, in the case of refined products quite considerably – from under 145,000 tonnes in 2022 to 255,000 tonnes.
ISU says the figures demonstrate the vital
role played by professional salvors in protecting the marine environment. ISU president John Witte says: “More than ever, ESG requirements are at the top of the agenda for all industries and of course for shipping. The focus on emissions and climate change must be maintained but we must not lose sight of the importance of simply protecting the environment. It affects those providing services to shipping as much as the owners: the insurers and financiers as we see with the adoption of the Poseidon Principles.
“Sustaining a viable professional salvage industry ready to respond to all kinds of incidents around the world is vital and that is recognised by insurers and owners but it needs to be properly funded,” Witte adds.
EMERGING THREATS
The number of containers involved was lower than in 2022 but, after bulk cargo, still represents the most significant category. ISU members provided services to vessels carrying 30,000 TEU, amounting to an
estimated 400,000 tonnes of cargo. This compares with 187,000 tonnes in the case of crude oil. ISU points out that containers may carry a wide variety of dangerous goods, including plastics pellets, which represent one of the biggest threats to the marine environment.
“Containers continue to be difficult to deal with – offloading, storing and perhaps backloading,” Witte points out. “But the traditional threat from oils remains and there were also several cases of car carriers and ro-ro fires and the carriage of electric vehicles (EVs) is an increasing concern. Salvors often do not know if there are EVs or batteries on board or the quantity.”
Cargoes of refined oil products and chemicals increased significantly in the 2023 numbers. An increased number of the services in the survey did not record the quantity of bunkers or the cargo type meaning the reported numbers likely represent a more modest total than the reality – ISU reports bunker fuel salvage falling from 108,000 tonnes in 2022 to 81,000 tonnes last year. ISU is transparent about the fact that not all these potential pollutants were at immediate risk of going into the sea. Some cases will have had limited danger, but others will have carried a real risk of causing substantial environmental damage. In an era of zero tolerance of any pollution, even the smaller cases represent a significant concern.
www.marine-salvage.com
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NEWS BULLETIN
SAFETY
CYLINDERS IN TRANSPORT
The British Compressed Gases Association (BCGA) has published a new Code of Practice 50, The Carriage of Gas Cylinders on Vehicles, developed in partnership with the UK Department for Transport. This new Code is a complete re-write of BCGA’s former Guidance Note 27, which was one of the most commonly accessed documents within the association’s extensive library of safety material.
The new Code includes details on legal and safety requirements, threshold quantity calculations, compliance, where required, with ADR, and information on roadside inspections. Information on gas-fuelled vehicles and fuel labels, personal safety and guidance on the action to take in the event of an incident are also featured.
Jake Lake, BCGA’s technical manager, says: “Gas cylinders are commonly used and many thousands are transported every day without incident, but to ensure that they are safe for transport there is specific legislation in place, as well as supporting guidance. Code of Practice 50 references the appropriate legislation and sets out best practice for their carriage.”
The Code of Practice can be downloaded from the BCGA website at https://bcga.co.uk/ publications/cp50-the-carriage-of-gas-cylinderson-vehicles/.
QUESTIONS OF TRAINING
The US Pipeline and Hazardous Materials Safety Administration (PHMSA) has published a third list of Frequently Asked Questions (FAQs), based on historical letters of interpretation in response to specific stakeholders. This latest list covers training requirements, and offers the regulated community some guidance on how to comply with the relevant provisions of the Hazardous Materials Regulations (HMR).
The list includes 19 FAQs, from the very basis – such as, who is a ‘hazmat employee’ – to
the more arcane, such as: who is responsible for training a subcontractor’s employees? Answers to these questions and more can be found at www.phmsa.dot.gov/about-phmsa/frequentlyasked-questions-based-letters-interpretation, along with the first two sets of FAQs.
In a separate notice, PHMSA has issued a safety advisory on the classification of Monkeypox virus. The notice shares new advice from the Centers for Disease Control and Prevention (CDC) regarding diagnostic samples and clinical waste containing Monkeypox virus (MPXV).
The advice clarifies that samples and clinical waste should be designated as Category B infectious substances except when they contain or are contaminated with cultures of Clade I MPXV.
The Safety Advisory can be downloaded from the PHMSA website at www.phmsa.dot. gov/transporting-infectious-substances/safetyadvisory-notice-classification-mpxv-diagnosticsamples.
SCREEN THE NURSES
The US Federal Motor Carrier Safety Administration (FMCSA), in conjunction with
PHMSA, has issued a Safety Advisory to alert industry to the potential for catastrophic failure of certain nurse tanks manufactured by American Welding and Tank (AWT) at its facility in Fremont, Ohio between 1 January 2007 and 31 December 2011.
The alert follows the catastrophic failure of one such nurse tank containing anhydrous ammonia in a farm co-op lot in August 2023, which resulted in the release of all product and shot the tank shell some 100 metres. No injuries were reported but that was simply good fortune – FMCSA says the event was indicative of continuing problems with AWT nurse tanks that have been in service for more than a decade.
The Hazardous Materials Regulations do not require periodic inspection and testing of nurse tanks that have attached and legible ASME identification plates and that meet all other requirements. In the Safety Advisory, FMCSA and PHMSA are strongly recommending that owners of AWT nurse tanks covered by the alert conduct voluntary period visual inspections and thickness and pressure testing. If that is not possible, either radiographic or ultrasonic testing should be carried out.
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WE DO DECLARE
BUSINESS • IF EUROPE IS TO BE COMPETITIVE IN A GLOBAL WORLD, INDUSTRY NEEDS THE SUPPORT OF LEGISLATORS. A MULTI-SECTOR DECLARATION HAS SET OUT ITS EXPECTATIONS
INDUSTRY IN EUROPE is under pressure.
North America is still benefiting from low energy costs, Asia continues to develop, the Middle East is investing heavily, but Europe faces weak demand, labour shortages and an increasing burden of environmental legislation. And, while industry in Europe is facing up to those demands for increased sustainability and overall environmental performance, there are signs that it is beginning to flex its muscles.
So it was then that in February this year, 73 leaders from nearly 20 industrial sectors in Europe gathered at the BASF site in Antwerp to present their thoughts on the way forward.
If industry is going to be fit to meet the EU’s Green Deal, they said, there needs to be a ‘European Industrial Deal’ to match. The ‘Antwerp Declaration’ for this industrial
strategy was presented to Alexander de Croo, prime minister of Belgium, and Ursula von der Leyen, president of the European Commission.
The Antwerp Declaration underlines the commitment of industry to Europe and its transformation but outlines the urgent needs of industry to make Europe competitive, resilient and sustainable in the face of dire economic conditions. The Declaration says, in part:
To meet climate neutrality by 2050 and the recently communicated 2040 target, Europe’s electricity production will need to multiply, and industry investments will need to be a factor six higher than the previous decade. This enormous challenge comes just as both large companies and SMEs face the most severe economic downturn in a decade, demand is falling,
production costs increase and investments move to other regions.
A US economy that benefits from the financial support from the Inflation Reduction Act (IRA) and its ease of accessibility, a Chinese overcapacity and increasing exports to Europe all increase the pressure for the European industry even more. Our companies face this challenge every day. Sites are being closed, production halted, people let go. Europe needs a business case, urgently.
MAKE THE CASE
It is not that legislators are unaware of industry’s plight nor sympathetic to their complaints. Indeed, Alexander de Croo said only last September, at the UN General Assembly in New York: “We need our industry for their innovation capacity to come up with tomorrow’s climate solutions. That is why Europe should not only be a continent of industrial innovation, but should remain a continent of industrial production.” Earlier last year, de Croo also said: “The question in front of us is: how do we continue to grow our European industry? The answer is: with a European Industrial Deal at the same level of a European Green Deal. Not in opposition to each other but to reinforce each other.”
The Antwerp Declaration goes further:
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An Open Strategic Autonomy for a competitive and resilient EU is crucial for the transition of Europe in an ever changing geopolitical landscape. It can however only be achieved if also basic and energy intensive industries remain and invest in Europe. Without a targeted industrial policy, Europe risks becoming dependent even on basic goods and chemicals. Europe cannot afford this to happen.
As host of the event, BASF’s Martin Brudermüller was equally forthright, saying: “Basic industries in Europe are grappling with historical challenges: demand is declining, investments in the continent are stalling, production has dropped significantly, and sites are threatened. We want to drive the transformation of our companies. For this, we urgently need decisive action to create the conditions for a stronger business case in Europe. ‘The Antwerp Declaration’ outlines a pathway ahead. By placing the European Industrial Deal at the forefront of Europe’s strategic agenda, the EU would pave the way for a resilient, competitive, and sustainable Europe. This is the only way to show the rest of the world that the Green Deal works for all.”
The Antwerp Declaration calls for the European Industrial Deal to be put at the core of the new European Strategic Agenda for 2024-2029. This would involve a comprehensive action plan to elevate competitiveness as strategic priority and create the conditions for a stronger business case in Europe. The action plan needs to include actions to eliminate regulatory incoherence, conflicting objectives, unnecessary complexity in legislation and over reporting. It asks for an Omnibus proposal to take corrective measures on all relevant existing EU regulations as the first piece of legislation to be presented in the next EU institutional cycle.
ON THE RIGHT PATH
It should be noted that there is nothing in the Antwerp Declaration that seeks to rein back on the EU’s current focus on sustainability and the circular economy, nor to change the fundamental aims of the EU. Indeed, in part it askes for the improvement of the European Single Market and a move away from the fragmentation being experienced by
divergent implementation of European directives. The Antwerp Declaration also calls for an EU Energy Strategy to prioritise new projects for the cost-effective production of low-carbon, renewable and nuclear energies, with an open market within the EU and strong partnerships with other countries that are rich in renewable resources.
The Antwerp Declaration has so far attracted more than 750 signatories, including over 540 companies, nearly 175 trade associations and labour unions, and individuals. With the chemical industry well represented among its supporters, the Antwerp Declaration has also garnered the support of chemical logistics specialists, including Bertschi Group, whose CEO Jan Arnet says: “The European Industrial Deal represents a crucial necessity for collaboration and innovation in addressing the pressing challenges of our time. By uniting behind this shared vision, we support the urgent need for clarity, predictability, and confidence in Europe, its industrial policy, and a secure and sustainable future for generations to come.”
“As a logistics company deeply committed to sustainability, we recognise that prioritising investment in rail infrastructure and utilising
alternative energy sources significantly reduce carbon emissions and contribute to a greener future for Europe. To enable the success of the European Green Deal, a European Industrial Deal on same level needs to be adopted,” adds Hans-Jörg Bertschi, chairman of Bertschi Group.
“I join my fellow business leaders in endorsing the Declaration and calling for a stronger industrial policy framework – one that reflects the role we can play as enablers of Europe’s climate ambitions and future growth,” says Bas Verkooijen, CEO of bulk liquids storage terminal operator Advario, which itself is investing heavily in the energy transition. “In advancing Europe’s position as a sustainable, green economy globally, the moment is now to pair Europe’s ambitious, forward-thinking green policies with an equally bold enterprising policy framework for Europe’s industrial sectors. Clarity of Europe’s industrial policy ambitions helps us transform our sector, innovate technologies, systems and processes, and creates a clear roadmap for investments in job creation and infrastructure.”
The full text of the Antwerp Declaration, including its ten key calls to action, can be found at https://antwerp-declaration.eu/.
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DRAGONS’ DEN
CHINA • SO IMPORTANT IS CHINA NOW TO WORLD TRADE THAT IT IS VITAL TO KNOW WHAT IS GOING ON THERE. SUTTONS’ KARL HUDSON GIVES HIS EXPERT VIEW ON CHINA IN 2024
CHINA’S CHEMICAL MANUFACTURING industry is now the largest in the world, accounting for some 43 per cent of global production capacity; by the end of this decade – just six years away – that figure is likely to have moved up to 50 per cent. Many companies from Europe, such as BASF, continue to invest significantly in China, betting on growth in the middle classes of roughly 200m people to drive demand as well as bolster the local economy. There is also a strong element of regionalisation going on as the days of easy and accessible global free trade seem to be behind us for the moment.
“Capacity in China is the main challenge now,” says Karl Hudson, regional director for north Asia at Suttons International. “Traditionally the construction industry has accounted for 30 per cent of GDP; this is scheduled to drop to less than 20 per cent, which has a big impact on the steel and cement
industries and the associated construction companies who are big users of chemicals. “Consumer sentiment is also weak in China as people tend to save money rather than spend it; the policy of ‘zero Covid’ is also in the back of people’s minds, which means many are still cautious about spending,” Hudson adds.
While China’s economy continues to grow, it is growing more slowly than before, with predicted growth of around 5 per cent per annum, compared to the figures around 8 per cent that have been common. This indicates that China is moving from being a fastgrowing developing economy to a developed economy. But in some ways China remains a long way behind the curve; Hudson says that he sees the local chemical transport business being similar to that in Europe some 20 to 25 years ago. “The market needs more professionalism and more innovative
approaches that add value to customers’ supply chains, rather than a purely pricedriven approach,” he says.
THE YEAR AHEAD
In the near term, 2024 will be a year of consolidation, acquisitions, and mergers to buy scale and reduce overcapacity, both in the chemical industry itself and among its logistics service providers. “During 2024, there will continue to be significant margin pressure and supply chain disruption caused by the expanding conflict in the Middle East,” Hudson says. “I predict the weaker companies in the ISO tank market will start to run short of cash, forcing them to look for buyers or partners to keep them sustainable. I also predict that 2024 will be the year that one of the shipping lines will purchase an ISO tank company.
“We will continue to see the shift to Asia as manufacturing costs here are cheaper than in Europe, and it is possible a trade war between China and Europe could occur, particularly over the electric vehicle (EV) market. I see the above as an opportunity if we can be agile and demonstrate to our customers that we are here for the long term. We may have to adjust our thinking too with an increased focus on the Intra-Asia market plus the growing links between China and the Global South.”
A key area for Suttons in China is the growth in the domestic tank truck market; this has encouraged the company to invest in equipment and acquire the necessary licences to operate domestically, establishing Suttons Tankers China last year. “At the strategic level, we recognised at the end of 2022 that we needed more focus on the domestic China market as growth in this sector is not dependent on the number of imported tanks we have coming to China,” Hudson explains. “Having our own dangerous goods company offers us the ability to offer a broader service to our customers, plus our high QSHE standards can be applied to our own fleet, reassuring many of our existing clients and potential customers that we are the trucking company of choice.
“We have also started working with tactical partners so that we can offer our service in related but different markets such as the road tanker market, where we have recently
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secured business with one of the world’s premier manufacturers of glycols.”
WHERE TO NOW?
“In the current marketplace, many of our customers are under severe pressure to reduce costs, which is reflected in the tender pricing we have seen recently,” Hudson says. “In this type of market, we must be on top of our game all the time to remind our key contacts of how good our service is and why they choose Suttons.
“In a commoditised marketplace such as ours, it’s essential that we remain able to differentiate ourselves while at the same time support our customers during market downturns. At Suttons we are still investing in China, where many western multinational companies have reduced their commitment. China is and will remain the factory of the world. Our goal is to broaden our services and penetrate deeper into our customers’ supply chains. Relationships at every level are the key to achieving this.” www.suttonsgroup.com
TANKS & LOGISTICS 37
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TANKS & LOGISTICS
DEN HARTOGH BUYS H&S
Den Hartogh has acquired H&S Group, a leading European transport provider in the liquid foodstuffs sector. H&S will become the fifth business unit within Den Hartogh, alongside its Liquid, Gas, Global and Dry Bulk units. The deal, which remains subject to regulatory clearance, does not include the H&S cleaning and filling operation in Barneveld, the Netherlands.
“The merger of H&S Group and Den Hartogh is an excellent opportunity to combine and fully utilise our strengths, expand our smart logistics solutions, and further develop our reach,” says Ubbo Hempenius, owner of H&S Group. “I am convinced, and so are our CEO Stefan Heintjes and our Advisory Board, that this is the right step forward for H&S. It ensures the continuity and independence of our company. We are creating a sustainable future for our teams, working together to set new standards in the world of logistics. Above all, it ensures that our customers benefit to the fullest from a unique and comprehensive global service package.”
Pieter den Hartogh, group managing director of Royal Den Hartogh Logistics, adds: “Expanding into a fifth business unit for liquid foodstuff is a strategic choice and on top of that being able to do this in partnership with H&S, a family-owned business with so many intersections in terms of history, values and ambition, makes me incredibly proud. We’re not just merging activities; we’re combining our stories, our dreams and our people. The H&S team, with their expertise, vast knowledge, experience and ambition, is a valuable and welcome addition to the Den Hartogh family.”
Den Hartogh has also announced a partnership with Daelim, which will combine Den Hartogh’s global reach and expertise in tank container operations with the specialised knowledge and market presence of Daelim’s
tank container division. The primary focus of this collaboration is to enhance customer experience through the provision of more efficient, innovative, and sustainable logistic solutions, Den Hartogh says. www.denhartogh.com
VTG IN THE POCKET
VTG has introduced the first pocket rail wagons designed for the Iberian gauge and plans to deploy 200 of the T4000 wagons in Spain to improve accessibility to combined transport services and promote the modal shift of freight from road to rail. “These wagons signify a turning point in Spain’s intermodal transport and will significantly impact the efficiency and sustainability of our transportation system,” says Carlos Omaña, operations manager of VTG in Spain.
The T4000 wagons are adapted from the T3000 pocket wagon already successful in European standard gauge operations. In addition, through the roadrailLink (r2L) technology developed in collaboration with
Vega International, non-craneable semi-trailers can be loaded safely into the pocket wagons. www.vtg.com
AGRO FOR H.ESSERS
H Essers is expanding its operation in Romania, building a new 10,000-m2 warehouse for the storage of crop protection and other agricultural products for Agricover at its existing Seveso site in Bolintin Deal, just west of Bucharest. The new facility will enhance Agricover’s logistics position and builds on a collaboration that started last year with storage and handling activities. The two companies have signed a seven-year agreement on the contract.
The facility is due to be functional by August 2024, when Agricover Distribution will start centralising its logistics operations at the new warehouse, which will be the largest of its kind in Romania. The new warehouse will also be the first in Romania to be CO2-neutral. “The new warehouse features solar panels to provide renewable energy. It also has heat pumps, which will be working instead of the conventional gas
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heating system for most of the time,” says Jeroen Fabry, business unit manager at H Essers. www.essers.com
GRE EXPANDS TELEMATICS
GATX Rail Europe (GRE) has announced a partnership with digitalisation expert kasasi, expanding its telematics offering for its leasing customers. One of the key highlights of this expansion is the introduction of the Basic Telematics Package as a standard part of GATX’s lease contract, offered to customers at no additional cost, giving easy access to fleet data and allowing direct interfaces with existing systems and for strategic information exchange.
“Customers benefit from an enriched experience as all GATX railcars are equipped with telematics devices, providing them with extensive data for improved transport decisionmaking,” says Elisabeth Jilli, head of sales and service at GRE. Julian Madsen, strategy and sales development manager, adds: “The strategic cooperation with kasasi is a means to empower our customers with telematics data-based planning. We are grateful to have found a trusted strategic partner in kasasi.” www.gatx.eu
TRUE FOR LIQUIDS
TrueTMS, a Florida-based provider of transport management systems, has launched a
dedicated service for road tanker fleets, TrueLiquid, which it describes as “an affordable, modern, cloud-based TMS designed to increase safety, efficiency, and profitability”. TrueLiquid aims to fill a critical gap in the industry with a custom platform tailored to the needs of liquid hauliers.
“Our team recognised a significant void in the industry and set out to build a custom solution that solves the distinct challenges tanker fleets face,” says George Thellman, director of business development and strategic relations at TrueTMS. “While TrueLiquid is still evolving, we’re excited to begin rolling out this revolutionary platform and have big plans for its future.”
TrueLiquid includes interactive trailer diagrams that help with accurate load planning, a customer portal to automate routine communications, and an all-inclusive fleet management package to operate tankers alongside other vehicles on a single platform. Additionally, TrueLiquid expedites the flow of data and documents to track demurrage and other charges and streamline accounting and compliance tasks. truetms.com
RINCHEM’S BIG SURPRISE
Rinchem has opened a custom-built warehouse in Surprise, Arizona (below) to strategically
support the booming semiconductor industry in the Phoenix Metro Area. The new warehouse covers some 11,500 m2 (123,500 ft2) and offers 16,000 pallet positions, including temperaturecontrolled storage. It also has an outside storage yard with capacity for 432 tank containers.
“This new facility represents a significant investment in our Arizona operations and is our second chemical warehouse in the Phoenix metro area,” says Chris Easter, CEO of Rinchem. “We’re proud to partner with a leading player in the semiconductor industry to ensure their critical supply chain runs smoothly. We’re confident it will play a crucial role in supporting the growth of the local semiconductor industry and contributing to the region’s economic prosperity.”
www.rinchem.com
GOLD FOR STOLT
Stolt Tank Containers (STC) has been awarded a gold rating for sustainability by EcoVadis, placing it among the top 3 per cent of supply chain companies. The award improves on the silver rating achieved in 2022, with advances in all EcoVadis sustainability categories: environment, ethics, labour and human rights, and sustainable procurement. The largest improvement was in labour and human rights, highlighting STC’s strong ethical and responsible business practices.
“Sustainability is at the heart of STC and I’m proud of what we’ve achieved,” says STC president Hans Augusteijn. “We’ve made great strides in improving sustainability across our operations and this latest achievement validates that we’re on the right track.” Ilja Siebert, global manager of sustainability and SHEQ, adds: “The improvements in the labour and human rights category came from our ability to clearly demonstrate our strong safety standards, our efforts to reduce gender inequalities within our workforce, and our focus on supporting our employees’ welfare. We are committed to ensuring safety for people and the environment and to achieving our goals in an ethical manner that supports the success of our employees.”
www.stolttankcontainers.com
TANKS & LOGISTICS 39
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SECOND BEST
RESULTS • MARKETS SETTLED DOWN LAST YEAR AFTER THE TUBULENCE OF 2022 BUT BUSINESS CONDITIONS SUFFERED. BRENNTAG DID WELL TO MAINTAIN ITS SALES AND PROFITABILITY
BRENNTAG ACHIEVED ITS second-best performance in its history last year, behind only the exceptional year of 2022. Overall sales were down 13.5 per cent at €16.8bn and operating gross profit dropped by 6.4 per cent to €4.04bn, with pre-tax profit falling from €1.23bn to €1.00bn. The company says that the fourth quarter of the year showed a return to growth, following the realignment of markets in the earlier part of the year.
Christian Kohlpaintner, CEO of Brenntag, says: “2023 was again dominated by a multitude of macroeconomic challenges and geopolitical tensions. Those weighed on the overall economic development and affected business activities across various sectors and markets, and especially the chemical industry. Despite this environment, Brenntag has realised the second-best performance in our company’s history. This is due to the inherent strength and resilience of our business model with its global reach and broad portfolio of products and services.”
Global market dynamics in 2023 were characterised by a number of cumulating, influencing factors and continued uncertainties. Ongoing inflationary trends in most markets, high energy costs in Europe, which impacted some of the company’s focus industries, and prolonged destocking based on falling prices affected the business. The war in Ukraine and the Middle East conflict are adding to the geopolitical uncertainties and led to new tensions in global supply chains. In this environment, the 2023 results of both Brenntag divisions were below the record year of 2022 but in line with the expectations, the company says.
DIVISION BELL
Brenntag Specialties delivered results broadly in line with the expectations, reporting operating gross profit of €1.48bn (down 8.2 per cent) and operating EBITA of €550.8m, a decline of 21.5 per cent compared to 2022. The division recorded lower results in all segments
year on year, primarily due to declining demand in all regions. There was a positive trend in the focus industries Pharma and Water Treatment but this could not fully offset the subdued demand in other focus industries such as Nutrition, Personal Care and Lubricants, who performed strongly in 2022.
Brenntag Essentials showed more resilience, as expected. The North America segment achieved a particularly positive result, partly compensating for a decline in the other segments. Apart from EMEA, the Brenntag Essentials segments also increased sales volumes in the second half of 2023. The division’s operating gross profit remained nearly stable compared to the previous year at €2.53bn, down by just 0.7 per cent; operating EBITA reached €848.9m, down 4.7 per cent compared to 2022.
Last year also saw Brenntag drive its ‘Strategy to Win’, revealed in November 2022, which involves differential strategies for the two divisions, along with a consistent sustainability agenda, value-creating M&A activities and the transformation into a dataand technology-driven company. “With this important step in its ambitious transformation, the company is laying the foundation for accelerated growth in the future,” Brenntag says.
“Through decisive and focused measures along a clear transformation plan, we are further sharpening the profiles of Brenntag Essentials and Brenntag Specialties and are developing two distinct, high-performing divisions with full business autonomy and independence,” Kohlpaintner adds. “With differentiated steering along global market requirements and specific customer and supplier needs we enhance their value proposition and accelerate their growth.”
Looking to 2024, Brenntag expects that the recovery in volumes experienced throughout 2023 will continue, though the overall geopolitical, macroeconomic, and operational conditions are expected remain challenging in 2024, with uncertainty about growth expectations for the global economy. As such, Brenntag is forecasting operating EBITA for 2024 in the range of €1.23bn to €1.43bn. corporate.brenntag.com
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ROUND THE CORNER
SURVEY • ITHE LATEST QUARTERLY SURVEY FROM THE CHEMICAL BUSINESS ASSOCIATION IDENTIFIES SOME PROMISING SIGNS. CAN THE MOMENTUM BE KEPT GOING?
DURING MUCH OF the past year, the quarterly business confidence survey carried out by the UK Chemical Business Association (CBA) has shown an almost totally downbeat assessment of business conditions and prospects. But there are signs that a corner has perhaps been turned.
The most recent survey, which shows results from the final quarter of 2023, portrays a supply chain that is gradually strengthening, with 29 per cent of respondents reporting improvements in their order books over the previous three months, compared with only 5 per cent in the third quarter survey. These positive developments continue when considering sales, with 21 per cent of
respondents reporting improvements, in comparison with only 9 per cent for the previous quarterly survey.
Similarly, the survey also identifies a growing optimism and confidence within the chemical supply chain for the near term, with 38 per cent of respondents anticipating an improvement in upcoming sales over the next three months, compared to only 5 per cent at the conclusion of the third quarter. The trend continues, with 17 per cent of respondents expecting future sales margins to improve – a huge improvement when considering that three months earlier no respondents expected any improvement over the coming months. Despite an increase in optimism when it
comes to sales, orderbooks and sales margins, employment figures largely remain the same, while some respondents indicating that margins will worsen. The latest results are consistent with the previous quarter, with only 15 per cent of respondents anticipating higher employment figures over the coming three months.
LOOK ON THE BRIGHT SIDE
The survey also highlights, however, that there is little evidence companies are anticipating a reduction in employment levels in the near term and, in line with the Association’s wider activities and goals, 27 per cent of respondents expect to provide increased training opportunities for their teams over the coming three months.
Despite the third quarter figures reporting that the global ocean freight container shortage was an issue for only 5 per cent of respondents, the latest survey does show that the number has risen markedly to 29 per cent. This, combined with the continuation of escalating shipping costs – 79 per cent of respondents reported it as an issue – shows there are obstacles facing industry as a whole, particularly when it comes to import and export operations.
Tim Doggett, CBA’s CEO, has this to say about the latest survey: “Following what seemed to be a general downturn and cooling in the market throughout 2023, but particularly in Q3, the latest supply chain survey does suggest a degree of increased optimism, which will hopefully continue throughout 2024. However, one significant aspect that has changed is a huge increase in the reporting of logistics issues, which is not surprising given the ongoing and very concerning situation in the Red Sea and the resulting rerouting of vessels.
“The survey remains of vital importance to our members,” Doggett adds. “It provides a clear indication of potential and ongoing issues confronting the chemical supply chain, chemical industry and industry as a whole. It shows us where best to focus our attention, not to mention the knowledge and support of the numerous dedicated partners, organisations and initiatives with which we collaborate.” www.chemical.org.uk
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NEWS BULLETIN
IMCD PRESSES ON
IMCD has agreed to acquire specialty distributor ResChem Technologies and ResChem Trust in Australia and New Zealand. ResChem, which was founded in 2007, specialises in resins, additives and pigments for use in inks, coatings, adhesives and construction applications, representing leading global suppliers that are complementary to IMCD’s existing portfolio. ResChem is based in Sydney with 15 employees and last year generated revenues of some A$25m.
“We see steady growth in the coatings industry in Australia and New Zealand with the advancement of innovative and sustainable solutions,” says Frank Schneider, IMCD’s global business group director, Coatings & Construction. “With the joining of ResChem, we can leverage their complementary portfolio and technical capabilities to further develop our footprint in the local markets.”
The acquisition is expected to close in the second quarter, subject to customary conditions.
Meanwhile, IMCD has reported gross profit for the full year 2023 of €1.12bn, up 2 per cent on the 2022 figure on a constant currency basis; operating EBITA shrank by 7 per cent to €515m and net profit dropped 7 per cent to €292m.
Commenting on the results, incoming CEO Valerie Diele-Braun says: “Following a year of exceptional growth, 2023 was a year characterised by challenging market conditions and reduced demand. Despite these challenges, IMCD continued to be resilient and delivered healthy cash flows whilst progressing strongly on our omnichannel digital solutions, geographic expansion and M&A.”
The EMEA operating segment reported a slight decline in revenue and EBITA but conditions were worse in the Americas, where lower demand and adverse currency movements contributed to a 20 per cent fall in operating
EBITA, despite an improvements in gross profit margin and the contribution of acquired businesses. The Asia-Pacific segment continued to show growth, largely as a result of a series of acquisitions in 2022 and 2023, although there was also a significant negative impact from currently movements.
Looking ahead, IMCD says that geopolitical and macroeconomic conditions remain challenging, and that customer demand shows increased volatility. Nevertheless, it also sees “interesting opportunities” to increase its global footprint and expand its product portfolio both organically and by acquisitions. www.imcdgroup.com
AZELIS AGAINST THE TREND
Azelis bucked the downward trend last year, posting a 1.0 per cent increase in revenues to €4.15bn and a 2.1 per cent increase in adjusted EBITA to €466.3m. Resilient performance in the Life Sciences sector offset weakness in Industrial Chemicals, the company reports.
“Our achievements illustrate the expertise and dedication of our teams as valued partners to our
customers and principals, and as we execute our long-term strategy of becoming the reference solutions provider in our industry,” says newly appointed CEO Anna Bertona. “Over the last three years, we have outperformed the midterm guidance set during the IPO, delivering 23 per cent average revenue growth and 90 bps average adjusted EBITA margin expansion per year. We continue to execute our strategy, expanding our footprint and strengthening our capabilities to ensure that we are well-positioned to accelerate growth in our existing markets and benefit from emerging opportunities across our businesses.”
The company says that, despite persistent global political and economic uncertainty, it remains steadfast in its focus on controlling costs, cash conversion and driving growth. “We expect to return to organic growth during 2024, although the timing of the recovery remains uncertain,” the company states. It is also planning to provide an update on its strategy in September during its annual ‘investor laboratory’ event. www.azelis.com
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CHEMICAL DISTRIBUTION
BM BUYS IN ITALY
Bodo Möller Chemie has acquired a 50.1 per cent interest in distribution company Losi Group, a solutions provider for bonding composite materials and surface technologies for the aerospace industry, defence sector, motorsport and the high-tech automotive industry. Founded in 1988 and based in the Italian city of Casalpusterlengo, 50 km south-east of Milan, the Losi Group advises and supplies over 250 clients in more than 50 countries worldwide and boasts a complex warehouse infrastructure with superior cooling technology.
For Bodo Möller Chemie, this takeover is expected to play a crucial role in achieving its growth targets and reinforcing its global partnership with Henkel. “This strategic move is a significant milestone for us, opening up new avenues in the aerospace market, with a specific focus on Henkel and Airtech products and top-tier systems for aerospace applications such as Virtek and Aeroform,” states Frank Haug, chairman of the Bodo Möller Chemie Group. bm-chemie.com
HELM ADDS GREEN ACID
Helm has announced a partnership with Again, which refers to itself as the first carbonnegative chemical manufacturer and uses bacteria to ferment captured CO2 into useful chemicals. A new 10-year contract will feed 50,000 tonnes of acetic acid, produced by Again, into the Helm distribution network.
“At Helm, we are highly committed to promoting sustainability and incorporating products from low carbon emitting technologies into our operations,” says Andreas Woschek, executive vice-president, chemicals at Helm. “The long-term partnership between Again and Helm will introduce the innovative technology of Again via Helm’s supply chain expertise and market know how to the chemical markets.”
“Our partnership with Helm is a very exciting milestone,” adds Max Kufner, co-founder of Again. “With Again’s technology and Helm’s long standing position in the global
chemical industry, we can work together to bring our CO2-made products to global markets. Most importantly, this agreement showcases a clear market demand in the market for what we do, which means we’ll be able to capture even more carbon to convert into useful products well into the future.”
www.helmag.com
UNIVAR INTO THE VALLEY
Univar Solutions has acquired Valley Solvents & Chemicals and certain affiliates. Valley Solvents is a long-established distributor of solvents and inorganics and provider of waste management services in the Texas and Gulf Coast region. The acquisition expands Univar’s local chemical distribution network and valued-added services across its Chemical Distribution division, while strengthening environmental services capabilities for its ChemCare business.
“We are committed to increasing our solvents and inorganics footprint to help our suppliers and customers grow their businesses,” says Univar president/CEO David Jukes. “The acquisition of Valley Solvents allows us to strengthen our North America Chemical Distribution division and enhance our environmental services capabilities in a growing market. With the integration of Valley Solvents’
operations, we believe we are well positioned to capitalise on opportunities with their strong local packaged business as well as in energy and industrial markets that have proven resilient throughout market cycles.”
www.univarsolutions.com
TELKO EXPANDS LUBES BUSINESS
Telko has expanded its lubricants distribution business in western Europe with the acquisition from Petrus SA of shareholdings in Optimal Tribotechnik, Optimal Netherlands, Optimal France and Greenfluid. The acquired businesses are leading distributors of premium industrial specialty and high-performance lubricants, metalworking fluids and other general industrial lubricants in France and the Benelux countries.
“We are excited to take a significant step in our accelerated acquisition-driven growth strategy,” says Mikko Pasanen, CEO of Telko. “The transaction strengthens the weight of the lubricants business in Telko’s business portfolio and opens new markets for us in France and Benelux, creating a platform for further growth in Western Europe.”
Telko’s lubricants business achieved turnover of €50.5m last year; the purchased companies have annual combined net sales of some €18m. www.telko.com
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GRAB AND GO
CARBON CAPTURE • IMO WANTS AN EMISSIONS-FREE SHIPPING INDUSTRY BY 2050. NEW ENERGIES WILL BE NEEDED BUT, IN THE MEANTIME, ONBOARD CARBON CAPTURE WOULD HELP
FOUR YEARS AGO , the International Maritime Organisation (IMO) introduced tough new restrictions on sulfur oxide emissions from ships. It was expected that the change would cause massive problems – existing ships would have to run on more expensive ultra-low sulfur fuel oil (if enough were available) or retrofit exhaust gas scrubbers – again an expensive job. In the end, however, the shipping industry managed the change well enough.
But the ‘IMO 2020’ rule, as it became known, was just one step on a long road towards reducing emissions from shipping activities and, although IMO has not yet mandated the measure, industry is anticipating tighter emissions limits for carbon dioxide. A number of engine manufacturers and vessel owners have been
looking at how this might be addressed and the idea of onboard carbon capture has also attracted the attention of some external players with innovative ideas.
Norway-based gas ship owner Solvang was early to the party, collaborating with Wärtsilä – which as well as being a major maritime engine builder is also heavily involved in onboard scrubbing technology – and the research institute Sintef. In 2021, the partners began onshore testing at Wärtsilä’s facility in Moss, Norway, with the aim of proving that the amine cleaning technology could reduce carbon dioxide in the exhaust gas from the main engine by 70 per cent, and demonstrating that the entire value chain for handling captured CO2, including liquefaction and storage, was feasible.
In September 2023, Solvang and Wärtsilä
were confident enough to plan the installation of a carbon capture unit onboard the 21,300-m3 LPG carrier Clipper Eris and to run it for two years as a pilot project. At the time, Solvang said that, if the system worked as hoped, it would be installed on five newbuildings that it had already ordered for delivery in 2026 and 2027.
FROM PLAN TO YARD
All this comes at a cost but Solvang is fortunate to be headquartered in a country where managing the energy transition is being taken very seriously. The government-owned company Enova last year provided NKr 709m ($66.5m) of grants to support a range of projects investigating a path towards emission-free maritime transport, including the Solvang/Wärtsilä project.
Explaining the funding, Nils Kristian Nakstad, CEO of Enova, said: “We want a faster phase-in of zero-emission technology in maritime transport. This applies to both technologies for the use of hydrogen-based energy carriers and special innovative electrification concepts for vessels. Enova supports those who are leading the way and now we want to increase and speed up the development and use of new and innovative technology that enables emission-free maritime transport.”
One benefit of exhaust gas scrubbing over other technologies for reducing emissions is that it allows vessel operators to continue to use the same fuels, meaning other expensive retrofits to the engine are not needed and that ships can continue to bunker fuels at the same points in their trading pattern. “Carbon capture combined with existing cleaning technology is a significant shortcut to the decarbonisation of the world’s deep-sea fleet, and stands out as one of the more promising solutions for the ships of the future,” says Edvin Endresen, CEO of Solvang.
In February this year, Solvang appointed Seatrium (formerly Sembcorp Marine, following its merger with Keppel Offshore & Marine) to install the 7 MW carbon capture and storage system aboard Clipper Eris Solvang has worked with Seatrium before – it handled the installation of exhaust gas scrubbers on four of its very large gas carriers
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(VLGCs) ahead of the IMO 2020 rule – and has a strong record in decarbonisation retrofit work.
“At Seatrium, we are committed to advancing environmental sustainability through the development of industry-leading solutions and the seamless execution of our projects,” says Alvin Gan, executive vicepresident of Seatrium Repairs and Upgrades. “Our collaboration with Solvang on Clipper Eris will further boost our strong track record in the areas of maritime decarbonisation upgrades and retrofits which are expected to continue to grow in the coming years.”
The work is due to begin in the third quarter of this year.
LOOPING THE LOOP
Another owner looking to examine the potential of onboard carbon capture is Lomar Shipping, whose in-house corporate venture unit, lomarlabs, has successfully completed sea trials on its 3,200-TEU containership Sounion Trader using a prototype system produced by climate tech start-up Seabound. The collaboration began in April 2023, with the modular system installed on deck, aft of the ship’s exhaust funnel.
The Seabound system is based on a secondgeneration carbon capture technology, calcium looping, which can transform captured CO2 into solid calcium carbonate pebbles that are safe, inert and non-toxic and can be easily stored onboard. After discharge, the CO2 can be extracted for further use or sequestration, leaving calcium oxide behind to be re-used. The technology was developed in the belief that merely adapting existing carbon capture systems to fit on a ship is not really feasible – space and energy demands are a major issue and there is also the need to discharge pure CO2 once in port. Finding the solution in calcium looping was a major step – and it also has the advantage of capturing sulfur oxide emissions at the same time.
The prototype carbon capture unit was installed at the Sefine Shipyard in Turkey during a special survey on the ship. Seabound received approval to operate the system from ABS and Lloyd’s Register also conducted a detailed risk assessment. Seabound personnel accompanied the ship for two months, conducting carbon capture trials and
getting hands-on experience in operating the system at sea.
By the end of the sea trials, Seabound had managed to increase the carbon capture rate to 78 per cent, equivalent to around 1 tonne per day of captured CO2, and sulfur capture effectiveness in excess of 90 per cent. “Our pilot project demonstrates that capturing carbon emissions directly from ships is not only possible but also highly effective,” says Alisha Fredriksson, co-founder and CEO of Seabound. “This breakthrough puts us on track to achieve our ambitious goal of capturing carbon onboard 1,000 ships by 2030, making a significant impact on the global effort to curb climate change.”
Lomarlabs was also impressed, with its managing director, Stylianos Papageorgiou, saying: “Seabound’s technology presents an attractive and viable solution for reducing carbon emissions on existing ships as well as new, with a system that is simpler to install, operate and maintain than others we have seen. We are excited to join Seabound’s mission and believe this technology could be
instrumental in driving a cleaner future for maritime transport.”
London-based Seabound, founded in 2021, was supported in the project by a £1.2m grant from the UK government and the backing of Hapag-Lloyd, which had chartered Lomar’s vessel. Seabound has meanwhile taken back the learnings from the trial aboard Sounion Trader and plans to scale up the system to capture 50 tonnes of CO2 per day. It is aiming to deliver the first commercial systems next year.
“To pioneering shipowners who want to lead the industry’s transition: you can reduce emissions from your existing fleet today and no longer need to wait for clean fuels,” says Fredriksson. “We’re just getting started to accelerate maritime decarbonisation and hope you’ll join us in this journey.”
solvangship.no
www.enova.no
www.lomarshipping.com
www.seabound.co
www.seatrium.com
www.wartsila.com
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NEWS BULLETIN
TANKER SHIPPING
MOL CLOSES FAIRFIELD DEAL
MOL Chemical Tankers (MOLCT) has completed the acquisition of Fairfield Chemical Carriers for some $400m via a share transfer agreement. MOL Group says it expects growth in the chemical tanker sector and intends to invest in the field. Following completion of the deal, MOL Chemical Tankers will integrate its fleet of 81 multi-segregated stainless steel chemical tankers with the 36 Fairfield ships, making it one of the largest specialised chemical tanker operations in the world.
Akira Sasa, CEO of MOL Chemical Tankers, says: “With the integration of Fairfield, the MOLCT Group has expanded its business base and can now offer a wider range of services to its customers. Together, both MOLCT and FCC will strive to offer our customers superior service in all aspects.” www.molchemtankers.com
NEW COATS FOR ODFJELL SHIPS
Odfjell Tankers has decided to recoat another three of its existing ships with MarineLINE
coating from Advanced Polymer Coatings (APC). The new coating will replace the original zinc coatings, continuing a process that began in the Odfjell fleet in 2019. The work will be carried out over the next three months at the Chengxi Shipyard in Jiangyin City, beginning with Bow Elm (46,100 dwt, 2011) and followed by Bow Trajectory and Bow Trident (both 49,600 dwt, 2014). APC has already partly recoated Bow Elm and Bow Trajectory; the work on Bow Trident will be a full re-coat.
“Although some shipowners use zinc-lined carriers for methanol service, this strategy eliminates versatility in their operation, resulting in lost profits if the ship returns without any backhaul cargo after making its delivery. It really doesn’t add up commercially for them any longer,” says Stephen Jarvie, global customer care manager for MarineLINE at APC. “Zinc coatings also have high absorption characteristics, which can cause some cargo retention and lead to purity issues in subsequent cargoes, limiting backhauling and
service. Owners and operators looking to maximise their operations can see the benefits of MarineLINE and the versatility to carry a greater range of cargoes that its use allows.”
www.adv-polymer.com
www.odfjell.com
EURONAV INTO BITUMEN
Crude oil tanker specialist Euronav has placed an order for two dual-fuel bitumen tankers at China Merchants Jinling Shipyard, for delivery in fourth quarter 2026. The 17,000-dwt units will go on ten-year timecharters on delivery. They will be equipped with methanol-capable engines, with the option of converting to run on ammonia in the future.
“With the new orders for two state-of-the-art and green newbuilding bitumen tankers, we continue to execute our strategy of diversification and decarbonisation of our fleet,” says Alexander Saverys, CEO of Euronav. “In recent months, we have secured a total of 55 years of timecharter cover thanks to the great support of top-class companies. This proves that our customers are ready to partner up with Euronav and CMB.TECH to develop future-proof solutions for the shipping industry. We will continue to develop innovative low carbon solutions for our customers and will accelerate our investments in the maritime energy transition. Decarbonise today, navigate tomorrow!”
www.euronav.com
SC FINALISES ORDER
SC Shipping has taken delivery of the fourth and final ship in a series of 7,200-dwt chemical tankers built by Wuchang Shipbuilding. The new tanker, Xia Huai, like its sisterships, features duplex stainless steel tanks and is designed for worldwide operations. The first three ships in the series have now completed more than 100 voyages between them without problem.
www.sc-shipping.com
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NEW TANKERS FOR SEATRANS
Seatrans has taken delivery of two newbuildings from Kitanihon Shipbuilding. Trans Sea and Trans Fjord, which were launched late last year, are 12,500-dwt stainless steel chemical tankers with 18 segregations, equipped with thermal oil heating systems and fitted to carry propylene oxide. This flexible cargo tank arrangements makes them perfect for the parcel trade between Northern Europe and the Mediterranean, Seatrans says.
“Aligning with our commitment to the environment and safety, the chemical tankers are built to the highest environmental, fuel-efficiency and safety standards, complying with IMO NOx Tier 3 and Sox emission requirements and following the Energy Efficiency Design Index (EEDI) Phase 3 compliance level,” the company states.
Seatrans now has 11 chemical tankers in its liquids fleet.
seatrans.no
UNI-TANKERS NOW IN MARBS
Uni-Tankers, a Denmark-headquartered operator of chemical tankers, has opened its
first office in Spain, to help strengthen its relationships with customers in the western Mediterranean. The company says Spain is a “vital hub for maritime trade and innovation” and having a location on the ground will help it tap into new opportunities.
“This expansion reflects our dedication to the continued growth of Uni-Tankers and our aspiration to play a pivotal role in the evolving dynamics of the tanker industry,” says Per Ekmann, CEO. “The Spanish/West Med region holds immense potential, and we are eager to contribute to its development.”
Mads Jessen has been appointed to lead the new team. He says: “After more than 40 years in the tanker industry, both as a broker and as an owner’s representative, I am pleased to have this opportunity to set up a Spanish commercial base for Uni-Tankers here in Marbella. I am equally pleased to bring with me Oscar Fabra and José Miguel Samaniego to handle chartering and operations from the new office, and we are confident that this will be a successful venture.”
uni-tankers.com
MORE FOR TERNTANK
Terntank has extended its newbuildings programme with a repeat order for a 15,000dwt dual-fuel oil/chemical tanker, with an option on a further ship, at China Merchants Jinling. Like the three already ordered, the latest newbuildings, due for delivery in 2027, will be equipped with wind-assisted propulsion and be capable of running on marine gasoil, biofuels or methanol. They will also be fitted with a hybrid battery system and be able to use shore power when in port.
“These vessels represent a significant step forward in reducing greenhouse gas emissions and air pollutants, aligning with the company’s long-standing commitment to environmental responsibility,” Terntank says. The 14-segregation design is also optimised for the carriage of bio feedstocks as well as finished products, helping to support Terntank’s customers’ own sustainability goals. terntank.com
EXMAR UP AGAIN
Exmar has reported revenues of $487.3m for the full year 2023, up from $155.6m a year earlier, though EBITDA dropped from $341.6m in 2022 to $80.4m. Exmar’s 2022 figures were distorted by disposals in the floating LNG business. For 2023, Exmar delivered a net profit of $72.0m.
Exmar’s gas shipping business saw revenues rise by 1.7 per cent year-on-year to $143.8m, with EBITDA slightly ahead at $82.3m; the operating result dropped from $42.7m to $34.3m, largely as a result of increased interest payments and impairment reversals.
All sectors of the LPG tanker market performed well during 2023 and Exmar has responded by ordering more newbuildings: two 46,000-m3 LPG/ammonia carriers were ordered during 2023, doubling the contract, and a further two were added to the list last month; in addition, Exmar will charter in four newbuildings, bringing its effective orderbook to ten ships. exmar.be
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CARRIER OPPORTUNITIES
LOHC • EXOLUM IS AIMING TO BECOME THE FIRST STORAGE TERMINAL OPERATOR TO HANDLE LIQUID ORGANIC HYDROGEN CARRIERS, WITH A PROJECT DUE FOR COMPLETION THIS YEAR
EXOLUM’S IMMINGHAM TERMINAL on the east coast of the UK is set to become the first facility in the world to receive and store hydrogen in the form of a liquid organic hydrogen carrier (LOHC), following the award of a government grant of some £0.5m to Exolum and its project partners.
LOHCs, which can be used to absorb hydrogen at locations where green hydrogen can be generated and release the same hydrogen at the point of us, with the dehydrogenated LOHC then being returned to the starting point, have been technically proven in terms of the processing. Exolum and its partners will now demonstrate the only step in the LOHC supply chain that is yet to be technically proven: its transport and storage.
The project will involved the repurposing of tankage and pipelines at the twin terminals at Immingham, with work scheduled for
completion by the end of this year; the demonstration phase will involve the storage and transport of 400 m3 of LOHC, carrying some 20,000 kg of hydrogen, between the Immingham East and Immingham West sites via a 1.5-km pipeline connection. Laboratory testing will take place to confirm that the LOHC quality is maintained.
Exolum says the project will give it valuable information and insights into using its infrastructure for the transport and storage of LOHCs, a major step forward in the development and research of new storage and distribution technologies for new energy carriers, as well as a natural extension of its service offering. “At Exolum we are constantly working to accelerate the energy transition through the development of new logistics solutions for the energy carriers of the future,” says Felix Gomez, technology and
innovation lead at Exolum. “This project is a clear example of this and highlights the high potential of using existing energy infrastructure for new energy carriers.”
PARTNERING IN PROCESSING
Exolum’s infrastructure can already store and distribute multiple liquid products, so this offering is scalable and adaptable to support growth in market demand. The viability of this project will support the first hydrogen projects in the UK, making the crucial service of large-scale hydrogen storage and distribution available ahead of alternative options.
In addition to Exolum, as transport and storage infrastructure partner, the project involves Axiom, a British award-winning, multi-discipline engineering consultancy business that will design and manage the laboratory testing.
Exolum is firmly committed to the development of projects related to green hydrogen and its derivatives for both industrial use and mobility. In its home country of Spain, the company has completed construction of the first integrated green hydrogen production and dispatch plant for mobility in the Community of Madrid. It is also building a green hydrogen production plant and refuelling station at its Riverside terminal, located in Stockton-on-Tees (UK), as part of the Tees Valley Hydrogen Vehicle Ecosystem project. Similarly, the company has recently acquired a 50 per cent interest in the world’s leading ammonia and NGL storage facility in Houston, US, which is currently developing one of the world’s most advanced low-carbon ammonia production and export projects.
Likewise, and in collaboration with other companies and research centres, Exolum is participating in other projects that aim to promote the development of new energy vectors by taking advantage of existing infrastructures, researching storage and distribution technologies for hydrogen of renewable origin in LOHCs, such as the Regenera and GreenH2Pipes consortiums, and HSL Technologies, a French start-up focused on the development for the creation of simple, efficient, innovative and economical methods for transporting and storing hydrogen. exolum.com
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48 STORAGE TERMINALS
The UK’s leading event for the bulk storage and energy infrastructure sector
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Building Society Arena, Coventry, UK Discover the event: www.tankstorage.org.uk/conference-exhibition
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ENTERPRISE OPENS DISTRIBUTION NETWORK
Enterprise Products Partners has put the first phase of its Texas Western (TW) Products System into service, with the start of truck loading operations at its new Permian terminal in Gaines County, Texas (below). The terminal has some 900,000 bbl of storage capacity for gasoline and diesel, and truck loading capacity of 10,000 bpd. Enterprise expects that the rest of the system, which includes terminals in New Mexico and Colorado, to be in service later in the first half of this year.
“Once completed, the TW Products System will provide supply reliability and diversity to the historically underserved gasoline and diesel markets in the south-west United States,” says AJ ‘Jim’ Teague, co-CEO of Enterprise’s general partner. “By repurposing segments of our integrated Gulf Coast midstream network, which features access to the largest refining complex in the US, representing more than 4.5m bpd of capacity, the TW Products System will provide retailers access to alternative sources of refined products, which should result in lower fuel prices for consumers in West Texas, New Mexico, Colorado and Utah.” www.enterpriseproducts.com
MORE TANKS FOR LBC
LBC Tank Terminal is to expand its Rotterdam terminal, adding 98,000 m3 of new tankage to take overall capacity to 280,000 m3 by first quarter 2026. This will be the third phase of development of the site, which has already seen new berths, loading bays and tankage added. “As we move into the next phase, I am excited about the opportunities ahead of us,” says Erik Kleine, general manager, Europe at LBC. “The commitment and hard work of our team has been the driving force behind our journey thus far, and I take immense pride in our achievements. LBC Rotterdam’s growth is a testament to the collective success of dedicated team players enthusiastic about our role in shaping a more sustainable future, and I look forward to the continued progress on this important path.”
www.lbctt.com
LUCKY 13 AT OTH
Odfjell Terminals US has completed the new Bay 13 at its Houston site, adding nine new tanks with a combined capacity of 32,400 m3 to increase the site’s overall capacity by 9 per cent to more than 410,000 m3. The new tank bay includes a combination of stainless steel and
carbon steel tanks, designed for the storage of specialty chemicals. Each tank has been engineered with positive pressure systems and full automation, underscoring Odfjell Terminals’ dedication to minimising emissions and environmental impact.
“As we continue to invest in our assets, we are proud to have developed a new tank bay that will set the standard for our business with state of the art automation and controls with enhanced operating flexibility that prioritises both environmental sustainability and operational efficiency,” says John Blanchard, CEO of Odfjell Terminals US.
www.odfjell.com
OT TO QUIT INDONESIA
Oiltanking has agreed to sell its Indonesian terminal, PT Oiltanking Karimun, to Novus Middle East, with the deal expected to close in the second quarter. The planned sale fits with Oiltanking’s strategic transformation strategy, ‘Project Accelerate’. “Throughout our assessment we took all perspectives into account and concluded that that it is best for our Indonesian business and employees as well as our shareholders to transition PT Oiltanking Karimun to a new owner,” says Bas Verkooijen, CEO of Oiltanking.
In the coming mandatory waiting period, the new owners will be onboarded to ensure the continued safe and reliable operation of the terminal, and that local employees are given sufficient support as they navigate the change of new ownership.
www.oiltanking.com
RUBIS TO SELL TERMINAL INTEREST
Rubis has begun negotiations to sell its 55 per cent shareholding in Rubis Terminal to its joint venture partner I Squared Capital. The joint venture was set up in 2020 to implement a strategy of product diversification and
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TERMINALS
STORAGE
geographic expansion, creating significant value for the company.
By taking full control, I Squared will seek to leverage its financial capability to further accelerate the growth and diversification of Rubis Terminal alongside the existing management team. For Rubis, the sale would “crystalise the value generated” and align with its strategy of focusing on renewable energy production.
Rubis anticipates a sale price of €375m, payable over three years, which implies an 11x multiple on 2023 EBITDA. The estimated capital gain of €75m would be returned to shareholders through an exceptional dividend after closing, which – subject to the usual conditions and approvals – is expected to be by mid-year 2024. www.rubis.fr
VOPAK, AIR LIQUIDE PAIR UP IN SINGAPORE
Air Liquide and Vopak have signed an MoU to collaborate on the development and operation of infrastructure for ammonia import, cracking and hydrogen distribution in Singapore. The two companies will study and explore the joint development of low carbon ammonia supply chains in Singapore, including the potential
development of ammonia cracking facilities, associated ammonia storage and handling infrastructure at Vopak’s Banyan terminal, and the distribution of low-carbon hydrogen through a hydrogen pipeline network.
The collaboration aims to support Singapore’s National Hydrogen Strategy, focusing on driving advanced hydrogen technologies with high commercial readiness to establish low-carbon hydrogen supply chains.
“Hydrogen and ammonia have the potential to significantly contribute to Singapore’s transition towards a low-carbon economy,” says Rob Boudestijn, president of Vopak Singapore. “As Singapore gears up for receiving and handling ammonia for power generation and bunkering, cracking of ammonia into hydrogen presents an additional application to help the industry shift to lower carbon feedstock. We are excited about collaborating with Air Liquide to accelerate the adoption and commercialisation of industrial ammonia cracking in Singapore.” www.vopak.com
INTER STEMS THE STINK
Inter Terminals Sweden has put a carbon filter unit into service at its facility in Malmö, reducing the emission of vapours from the handling and storage of bitumen at the site.
“This is an investment that we have chosen to make together with our customers in order to prevent and reduce the risk of any odour in the immediate area around Inter Terminals’ terminal in Malmö that may arise in connection with the handling of bitumen,” says Jonas Taserud, technical manager at Inter Terminals Sweden.
Another project for the company involves expansion of its aviation fuel facility in the Port of Gävle by converting tanks from conventional fossil heating oil storage to a blending and storage facility for Sustainable Aviation Fuel (SAF), in collaboration with the Scandinavian airline SAS, which has an ambitious target for SAF use by 2030.
“Our demand for SAF is significant, but there is a need for investments throughout the entire value chain to enable us to transition to more sustainable flights,” says Ann-Sofie Hörlin, had of sustainability at SAS. “That’s why it’s important for us to partner up and have a proactive approach to ensure a sufficient and efficient SAF value chain. SAS use of SAF today is low in comparison to our future demand and needs to increase significantly as the usages of SAF directly correlates with lower flight emissions.”
Inter Terminals Sweden has also been certified according to ISCC (Sustainability and Carbon Certification) for all four of its terminals. The certification will, the company says, allow it to cooperate with other ISCCcertified companies and will also make it easier for its customer looking to store renewable fuels at its facilities. “To further strengthen our knowledge about the evolving renewables businesses and structures, we are performing an analysis on potential related future demand,” says Cecilia Lönnroth, commercial manager. “The result will be used to plan for a successive adaptation of our infrastructure and operating permits. This in combination with the recently received ISCC certification, makes us well-equipped to support our existing and new customers with excellent renewables logistics and storage services now and in the future.” interterminals.com
STORAGE TERMINALS 51
WWW.HCBLIVE.COM
COMING SOON
PREVIEW • CHEMUK IS JUST AROUND THE CORNER. WHAT CAN VISITORS EXPECT FROM THIS INCREASINGLY COMPREHENSIVE EVENT?
AS A RELATIVELY new entrant to the UK industrial event listings, ChemUK has quickly built up a big fanbase among both exhibitors and visitors. And this year’s event, taking place once again at the NEC in Birmingham, looks likely to be bigger than ever. Visitors will have to work hard to see everything in the space of two days – 15 and 16 May – as the exhibition hall is packed with stands heaving with products and services to enhance operations in all parts of the chemicals business.
As before, the exhibition area is split between the chemical process and plant engineering zone on the one side and the chemical industries supply chain – which is perhaps of most interest to HCB readers – on the other, with the ChemLab laboratory and innovation zone sandwiched in between.
ChemUK has become adopted by chemical distributors and suppliers as the place to be and be seen – the exhibitor list reads like a who’s who of chemical distribution - but the supply chain area will also include some well known names from the logistics side, including DHL Supply Chain, Navigator Terminals, Schäfer Container Systems and UL Solutions. Some names might be less familiar – such as Pont Packaging, part of Pont Europe, which will be at ChemUK for the first time to show off its wide range of small sustainable packagings for the chemicals and pharma sectors.
Equally at home at the NEC will be some old friends of HCB, especially in the packaging sector, such as Air Sea Containers, Fibre Drums Ltd, AST Plastic Containers, Recontainers, Ucon Container Systems, ITP
Packaging, Schoeller Allibert and Hoyer, which will be promoting its IBC rental services. Labelling is featured too, with Labeline International, Hibiscus and Logopak International due to appear at the show. Peter East Associates, one of the UK’s leading providers of training services in the dangerous goods sphere, is also listed. In the transport sector, exhibitors include Brian Yeardley Continental, Clarke Transport, Dachser, Hoyer, ITAL Logistics and Rhenus Logistics. Among safety technology providers at the Birmingham event will be Protego, Pyroban, Ricardo and Advanced 3D Laser Solutions. Perhaps exemplifying how important the ChemUK show has become in recent years, it has attracted Chemtrec, the US-based public service phone centre for emergency responders.
SIT DOWN AND LISTEN
But ChemUK is more than just a showcase for product and service suppliers. There is also an extensive and high-level conference programme, featuring speakers from some of the main business associations in the chemicals sector as well as leading figures in industry. Confirmed keynote speakers include Tim Doggett, CEO of the Chemical Business Association (CBA); Yvonne Baker OBE, CEO of the Institute of Chemical Engineers (IChemE)
HCB MONTHLY | APRIL 2024
52
and its president Nigel Hirst; Professor Gill Reid, president of the Royal Society of Chemistry; Alan d’Ambrogio, regional chair of the Institution of Mechanical Engineers (IMechE); and Ian Cranshaw, head of international trade and regional affairs at the Chemical Industries Association (CIA).
Other keynote speakers include Thomas Birk, managing director of BASF plc, who will speak on the need for a consistent approach to circularity in the chemical industry; Vivi Hollertt, chief sustainability and communications officer at Nouryon, who will look at how the chemical industry can support a greener and cleaner future; and Jenni McDonnell, MBE, thermal energy KT manager at Innovate UK Business, who will address support for industry on the road to net zero.
Visitors looking for a chance to stock up on new information and lively debate (or perhaps just a chance to rest their aching feet) will also be interested in the panel sessions. Of particular interest to HCB readers will be an examination of how well-equipped (or not) chemical supply chain participants are for the digitally enabled age, led by CBA’s Tim Doggett and with panellists from the Road Haulage Association (RHA), the Stort Group and the Chemical Weapons Convention UK National Authority. Anyone involved in the chemical industry in the UK will also be keen to learn the latest about UK REACH and BASF plc has lined up an interesting session, led by its regulatory affairs manager Neil Hollis and with participation from government, industry and non-governmental organisations. On the second day, Caroline Raine, formerly with the National Chemical Emergency Centre, will lead a challenging discussion on the growing divergence between GB and EU regulations.
BASF plc is a strong supporter of the ChemUK event and is also hosting a second panel session on the first day, led by senior sustainability manager Tony Heslop, looking at how companies are dealing with Scope 3 emissions. Panellists for this intriguing session will come from Croda Europe, Univar Solutions and Synthomer. Heslop is also listed to appear as a panellist on a session on achieving and demonstrating sustainability, hosted by CBA.
Also of interest to HCB readers will be a
two-day ‘mini-conference’ hosted by the UK and Ireland Spill Association, which will take a close look at the new hazards posed by lithium ion batteries. The Association is also holding a two-day ‘open house clinic’ at its stand in the exhibition hall
ALL ABOUT CHEMISTRY
There are too many speakers lined up for the conference areas to list here. But to pick out a few that will be of most relevance to the HCB audience, Jamie Killerby, managing director of Hibiscus, will speak about ‘navigating the changing tide of chemical labelling’, including a clarification of the latest CLP label changes; and Matthew Farthing, principal consultant at WSP, will run through the latest ADR changes and the regulatory challenges they bring. His colleague Neal Barker is due to talk about the evolving investor and consumer landscape with regards to climate change, sustainability and ESG is impacting the chemical industry.
On a more operational level, there are some intriguing papers lined up, including one from Joshua Hayes, business development
manager at the ACI Group, on the use of digital technology to address bottlenecks in raw material supplies; Vincent Hale, head of sales at BTC Europe, is due to speak on the use of digital systems to improve customer experience; and Mark Spence, chair of the British Association of Dangerous Goods Professionals (BADGP), and Gill Pagliuca, representing the Chemical Hazards Communication Society (CHCS), will discuss hazard communication.
Chemtrec is not travelling to Birmingham merely to show off its services; Chris Scott, its crisis and emergency management manager, will appear on the podium with John Blackmore, head of bioresource operations at United Utilities, talking about the use of process hazard analysis in emergency planning to enhance safety, reduce errors and support readiness.
It is hoped that this brief article has whetted the appetite of readers to see more in person. Even better, the entire event is free to attend, so sign up now – full details can be found at www. chemicalukexpo.com.
WWW.HCBLIVE.COM BACK PAGES 53
CONFERENCE DIARY
APRIL
UKIFDA Expo 2024
APRIL 10-11, LIVERPOOL
Annual exhibition and conference for the fuel distribution sector in the UK and Ireland https://ukifda.org/ukifda-events/
CVSA Workshop
APRIL 14-18, LOUISVILLE
Meeting for industry, regulators and enforcers to improve commercial vehicle safety www.cvsa.org/events/cvsa-workshop/
LogiPharma
APRIL 16-18, LYON
Conference on the end-to-end pharmaceutical supply chain logipharmaeu.wbresearch.com
AFPM Security Conference
APRIL 18-19, NEW ORLEANS
Conference on security at fuel refining and petrochemical plants
www.afpm.org/events/SC24
Cryogenic Storage Tanks
APRIL 18-19, MUNICH
Third technical conference on liquefied gas storage
www.tuvsud.com/de-de/store/akademie/tagungenkongresse/gewaesser-und-explosionsschutzflachbodentanks/1611005
COSTHA 2024
APRIL 21-24, FORT MYERS
Annual forum and expo of the Council on Safe Transportation of Hazardous Articles www.costha.com
Flame
APRIL 23-25, AMSTERDAM
30th annual conference on natural gas and LNG in Europe
https://informaconnect.com/flame-conference/
International Chemical & Product Tanker Conference
APRIL 23-24, LONDON
Conference on tanker markets and trade
https://www.rivieramm.com/events/internationalchemical-and-product-tanker-conference-2024
Asia Pacific LNG & Energy Summit
APRIL 23-25, SINGAPORE
13th annual meeting for the LNG, gas and hydrogen value chain
www.asiaenergysummit.com/
CV Show
APRIL 23-25, BIRMINGHAM
Annual commercial vehicle exhibition
https://cvshow.com/
MAY
NTTC Annual Conference
MAY 4-7, LAS VEGAS
Annual meeting of the National Tank Truck Carriers
https://tanktruck.org/Public/Public/Events/AnnualConference/2024/AC-2024.aspx
ILTA
MAY 6-8, HOUSTON
43rd annual operating conference and trade show of the International Liquid Terminals Association
https://ilta2024.ilta.org/
Argus Clean Ammonia Asia
MAY 7-9, TOKYO
Inaugural regional event to discuss opportunities in new fuels
www.argusmedia.com/en/conferences-eventslisting/clean-ammonia-asia
IOSC 2024
MAY 13-16, NEW ORLEANS
Triennial International Oil Spill Conference iosc.org
GPCA Plastics Conference
MAY 13-14, DUBAI
13th GPCA conference on the polymers sector and recycling
https://gpca.org.ae/conferences/plastics/
Argus Green Marine Fuels Conference
MAY 14-16, AMSTERDAM Forum to discuss the path to decarbonising marine fuels
www.argusmedia.com/en/conferences-eventslisting/green-marine-fuels
UNITI Expo
MAY 14-16, STUTTGART
European convention for the retail petroleum sector
www.uniti-expo.de
Bulk Tanker Day
MAY 15, BRISBANE
15th annual road tanker event hosted by the National Bulk Tanker Association
www.nbta.com.au/Bulk-Tanker-Day
ChemUK 2024
MAY 15-16, BIRMINGHAM
Supply chain expo and conference for the UK chemical industry
www.chemicalukexpo.com/
GPCA Supply Chain Conference
MAY 15-16, DUBAI
15th annual meeting of logistics professionals in the Gulf Petrochemicals and Chemicals Association
https://gpca.org.ae/conferences/scc/
Hazmat 2024
MAY 22-23, STRATFORD-UPON-AVON
NCEC’s annual conference for those involved in hazmat response, incident management and crisis management
www.ricardo.com/en/news-and-insights/eventsand-webinars/hazmat-2024
HCB MONTHLY | APRIL 2024 54 CONFERENCES
ROAD/RAIL/AIR INCIDENTS
2/3/24 Lower Saucon, freight train ethanol, Nine cars, including two tank cars with residues of ethanol and butane, derailed, some falling into Lehigh Fire Pennsylvania, US butane River; tank cars were not breached and no sign of spill; NTSB investigating Engineer’g
4/3/24 Istanbul, road tanker - Fuel tanker exploded while parked in recreational facility in Atasehir district; one person killed, three injured; Famagusta Turkey reports say explosion happened during welding work, leading to fire; cause under investigation Gazette
8/3/24 Bismarck, truck ammonium Truck carrying ammonium nitrate overturned at intersection in St Francois County; crash caused diesel leak Fox Missouri, US nitrate from fuel tank but cargo did not spill; cleanup under way as truck was righted
9/3/24 Pasay City, road tanker coconut
Road tanker heading for Sucat with cargo of coconut oil crashed into pillar of overpass, resulting in spill of Manila Philippines oil cargo; several motorcyclists were injured after skidding on oil; fire crews applied sand Standard
10/3/24 Raisen, road tanker LPG
Gas tanker fell into gorge after driver lost control on Bhopal-Jabalpur Highway; tanker caught fire, which PTI MP, India spread to nearby huts, killing cattle; driver, cleaner both died in the fire
13/3/24 Sakleshpura, road tanker LPG
Gas tanker overturned on Bengaluru-Mangaluru NH 75, causing leak of LPG; highway closed as a Deccan Karnataka, India precaution; driver lost control on curve, police said; several cars were stranded by road closure Herald
17/3/24 Gerashk, Helmand, road tanker fuel
Bus driver lost control after hitting motorcycle on Kandahar-Herat highway, crashed into oncoming fuel Al Afghanistan tanker; at least 21 killed after fire broke out on bus, another 38 injured, many seriously Jazeera
20/3/24 Auburn, truck batteries
Tractor-trailer overturned on off-ramp from I-290, spilling part of load of batteries (type unspecified) and NBC Massachusetts, US causing leak of electrolyte to road; significant road closures during cleanup; no injuries reported
MARINE/INLAND WATERWAY INCIDENTS
MISCELLANEOUS INCIDENTS
11/3/24
oil refinery gasoline
Fire broke out in distillation unit at ExxonMobil’s refinery, which supplies the Paris region; three workers Reuters Seine-Mar, France injured; plant’s fire brigade extinguished blaze; operator said local air quality was not affected
12/3/24 Portage, pharmaceutical methylene
More than 1,000 gal methylene chloride spilled within Pfizer’s Kalamazoo plant, some of which reached WWMT Michigan, US plant chloride sewage system; authorities issued ‘No Contact Advisory’ for stretch of Kalamazoo River
23/3/24 Jaipur, chemical chemicals
Six workers died, two more injured when fire broke out in chemical factory in Bassi district after boiler Hindustan Rajasthan, India plant explosion; owner absconded; fire crews investigating why fire extinguisher system did not function Times
WWW.HCBLIVE.COM INCIDENT LOG 55
Date Location Vehicle Type Substance Details Source
INCIDENT LOG
Date Location Vessel Substance Details Source 10/3/24 Port Sikka, Hafnia Seine alkylate Product tanker (76,600 dwt, 2008), with cargo of alkylate for Reliance Industries in the US, collided with FleetMon Gujarat, India part of SBM at BPCL crude oil import facility; no spill reported but oil imports affected by damage 15/3/24 off Hodeidah, Mado - VLGC (84,000 m3, 2015), from Singapore for Saudi Arabia, presumably in ballast, was attacked by two Reuters Yemen Houthi missiles; both missed the ship, exploding nearby, with no injuries to crew 20/3/24 off Gabon Becuna crude oil Fire broke out on Perenco oil production platform at offshore Simba field, cause not yet clear; five workers Splash killed, two more injured, one missing; all crew moved off the platform and fire extinguished 247 20/3/24 Sea of Japan Keoyoung acrylic acid Chemical tanker (1,170 dwt, 1996), with 980 t acrylic acid, capsized in heavy seas while anchored 68 km Splash Sun south of Tongyeong Island; eight crew killed, two missing, only one rescued; no sign of pollution yet 247
Date Location Plant type Substance Details Source 25/2/24 Kaushambi, firecracker fireworks At least four people died, six injured by explosion at firecracker factory in Bharwari; fire also reported but NDTV UP, India factory clear if that was result of or cause of explosion; plant was properly licensed; police investigating 4/3/24 Clinton township, factory butane Fire broke out in industrial facility with more than 100,000 vape pens; fire spread to butane tanks, some of WXYZ Michigan, US which exploded; one person killed, one injured by flying debris; cause under investigation 10/3/24 Tehran, house fireworks At least one killed, 11 injured by fireworks blast near Grand Bazaar; residential building where homemade Xinhua Iran fireworks were stored ahead of Iranian New Year celebrations collapsed; other homes damaged
Liuhe, factory unknown
broke out,
Crisis24
11/3/24
Fire
initially in electronics store before spreading to factory, where explosion took place; nearby
Hubei, China residents evacuated; no details available about nature of factory or cause of explosion
Port-Jérôme,
NOT OTHERWISE SPECIFIED
RIGHT PLACE, WRONG TIME
Our lead story this month comes from Utah, where six people were injured in a funeral home in Salt Lake City last month after a fight broke out. One person is believed to have been shot, three others were stabbed and two had unidentifiable injuries. Witnesses called 911 and reported a car leaving the area at high speed – police found the car a few blocks away with two people who both had minor injuries. They also found a gun in the car but it is not clear if this was used in the melee.
Police said there was an ‘event’ going on in the funeral home at the time of the fight –presumably it was a funeral going on, unless there is a specialist channel on TikTok that we are not aware of. However, police were clearly at a loss to explain things and none of the witnesses seemed eager to help. “At this point, we have not been able to determine the motive for this nor have we been able to determine how many people were considered suspects or victims,” said a baffled Brent Weisberg, spokesman for the Salt Lake City Police Department. The fact that the Department’s Violent Crime and Robbery Squad and Gang Unit were assisting might give some pointers to the cops’ train of thought.
Police were keen to stress that the incident posed no further threat to the public. Police Chief Mike Brown said: “This type of incident is extraordinarily rare for our city.” (He might have added that a punch-up at a funeral home is pretty rare in any city.) “I know our detectives are working quickly to determine the motive for this incident but I am relieved t
know that, based on the preliminary investigation, this was not a random attack.”
Here’s our position: imagine you are the owner of a funeral home and are looking to drum up more business; maybe organising a gang fight on the premises could be a good way of generating a few more bodies.
LO-FI LO-FLY
More from America’s still rather wild west, this time from Arizona, where one person was killed and another badly hurt when an “experimental, homemade aircraft” crashed last month near the Gila Bend Municipal Airport, some 110 km south-west of Phoenix. It occurs to us that the words “experimental” and “homemade” do not belong anywhere near “aircraft”, at least if you are keen to see the sun come up tomorrow. Even the owner of a company that sells such do-it-yourself aircraft kits described them as being basically a “motorcycle with wings”.
The Sheriff’s department said it was not known if the ‘aircraft’ crashed during take-off or landing, though our money is on landing (or “controlled flight into terrain” as the authorities have it). Anyway, the feds are now on the case, with NTSB and FAA both buzzing around. We await the outcome of their investigation with interest.
Certainly, we hope the investigation will be more fruitful than that into the derailment of the Amtrak Sunset Limited train in nearby Palo Verde in 1995. Despite the offer of a $310,000 reward for information about the people responsible for sabotaging the track, the case is still unsolved, nearly 30 years on.
HCB MONTHLY | APRIL 2024 56 BACK PAGE
ADVERTISERS INDEX Chemical Watch News and Insight 07 ChemUK IFC COSTHA 02 Enhesa 21, 37, IBC Fort Vale OBC Freight Merchandising Services 21 Labeline 11, 13, 15 Tank Storage Association 49
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