HCB Magazine January 2022

M O N T H LY J A N U A R Y

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SPEED CLEAN ELECTRIFICATION OFFERS A SUSTAINABLE FUTURE WAREHOUSING RISKS EXPLORED TERMINALS IN TRANSITION ALIGNING RID/ADR/ADN

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UP FRONT 01

EDITOR’S LETTER

THIRTY YEARS AGO this year, the 1992 Rio Earth Summit

the rubric of ‘sustainability’. That is not because HCB itself has

represented the world’s first serious attempt to begin the fight

turned ‘green’, rather that we have reflected the direction that

against climate change. It saw that, if action were to be successful,

industry is taking; new projects must always take sustainability

it would have to be globally coordinated, since no country or region

and decarbonisation into account and there are more and

would want to place itself at a competitive disadvantage by taking

more examples of existing successful supply chains being

a stricter stand on emissions regulations. Along the way, it

re-engineered to reduce their environmental footprint.

also laid the groundwork for the development of GHS – which,

Brand-new supply chains are also already beginning to

despite its name, was for many years neither global in scope nor

emerge. Northern Europe is short of the renewable energy

harmonised in nature – as well as REACH and similar chemical

it will need to meet EU targets for decarbonisation and so

registration systems now in place in various countries.

is looking at ways of having renewable energy delivered to

At that time, there was still no firm consensus among the

its door. This will likely involve ‘green’ hydrogen and ammonia

scientific community over the extent to which observable climate

(and perhaps methanol too) being shipped halfway around the

change effects were anthropogenic in nature. There was also

world from regions with plenty of spare solar, wind and hydro

a great deal of political disagreement over the reality of climate

generating power, using vessels that are, ideally, powered

change and, if it did exist, how best to tackle it. Thirty years on,

by the same fuels.

there are still leaders who are not fully aligned with mainstream

This might sound like a big step but it is merely a mirror

thought or who pay lip service to the targets set and measures

of what northern Europe is already doing, importing vast

imposed by subsequent conferences, while at the same time

quantities of crude oil, hydrocarbon gases and refined

continuing to pursue economic and industrial strategies that

products to meet its need for energy. The 2050 deadline for

will make those targets impossible to meet – the continuing use

Europe to become carbon-neutral is now only 28 years away,

of coal in power generation or the ongoing destruction of rain

so over that period we can expect to see a gradual shift away

forests being perhaps the most egregious examples.

from trade in traditional hydrocarbons towards the import

But in the business world, the message has now been received and many industries are looking seriously at their environmental

of green energy.

Terminal operators, port authorities and shipowners have

impact. Indeed, as was stressed during last year’s EPCA Annual

spotted this inevitable trend and are taking steps to be in the

Meeting, the question is no longer ‘why?’ but ‘how?’ – and,

right place to deliver what industry wants. Readers can expect

perhaps subject to most debate, ‘when?’.

to be hearing a whole lot more about this during 2022 –

Over the past two years, HCB’s coverage of the dangerous goods logistics industry has featured more and more items that fall under

and beyond.

Peter Mackay

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UP FRONT 03

CONTENTS VOLUME 43

•

NUMBER 01

UP FRONT

News bulletin – tanks and logistics 24

Letter from the Editor 01

Ignition key NTSB spots issues with secondhand cars 46

30 Years Ago 04

DIGITISATION

Quick and clean

Learning by Training 05

Away with the paper

Ultrasonic testing the Cygnus way

ECTA makes progress with digital tools STORAGE TERMINALS

Fly by wire

The place to be

Lufthansa adopts IBS systems

Tarragona aims for hub status

06

Class in Gulf New terminals in USCG

28

REGULATIONS Devil in the detail

29

09

News bulletin – storage terminals 12

Cefic asks for regulatory clarity

Dip your toes Promoting online training with DGOT

10

Bringing RID/ADR/ADN into line

50

Help with reading COURSES & CONFERENCES

Underfloor eating EI examines liner integrity

News bulletin – safety 49

08

New chains for old Stanlow Terminals open for biofuels

26

Asking questions OCIMF puts SIRE on tablets

48

No trousers 30

Prime mover Canada goes for CBTA

58

A lot of talk at MEPC

60

The year ahead 32

What to expect from the regulators

62

Conference diary 34 TANKS & LOGISTICS

BACK PAGE

Trying times Ups and downs of tank containers

SAFETY 14

Cutting edge Perolo invests in tooling

16

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

38

NCEC gives Ouray the full hand

40

Fixing a hole 20

Down in the hole Danes planning for CCUS

35 years of Exis Technologies One in three

18

Power up Wibax gets electrified

Incident Log 36 In the know

A place to stay Sahreej’s depot strategy

Not otherwise specified 64

Industry plugs warehousing safety gap

What’s new in chemical tankers 42

EV at sea 22

The hazards of electric vehicles

Publishing Assistant Francesca Cotton Senior Designer Harrison Tanner Chief Operating Officer Stuart Foxon Chief Commercial Officer Richard Butterworth

NEXT MONTH Industrial packaging manufacturing Labelling and compliance

44

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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. ©2022 CW Research Ltd. All rights reserved

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30 YEARS AGO A LOOK BACK AT JANUARY 1992

THE NEW YEAR started with promise, as it so often does – until it goes pear-shaped. China began opening up to the international market and George Bush and Boris Yeltsin met at Camp David to announce the end of the Cold War. On the flipside, the break-up of Yugoslavia let to massive destruction and widespread fighting – the break-up of Czechoslovakia went rather more peacefully. The first text message (SMS) was sent, which may be good or bad, depending on your view of things.

Meanwhile, the environment was emerging as a major global political issue and giving the world something else to worry about.

The World Meteorological Organisation reported an unprecedented level of ozone depletion in the polar regions, something that the world has since then successfully managed to rectify. In May 1992 the UN Framework Convention on Climate Change was adopted; the following month the first Earth Summit was held in Rio de Janeiro, which among other things ended up giving us GHS. Even the pages of HCB had begun to take environmental considerations more seriously, the January 1992 number featuring an article about the perceived problems of recycling used plastics drums.

That was becoming more of an issue since, following the very difficult economic conditions experienced around the world in 1991, shippers

involvement in the lifecycle of their drums, which meant forging new relationships with users, disposers and recyclers. That they have done so in the decades since then is testament to the way in which industrial packaging manufacturers – even those working in the dangerous goods sphere – have been willing to invest time and money to establish global networks for the collection, re-use and remanufacture (or recycling, if that is not possible) of their plastics products – not just drums but also the inner bottles of composite IBCs. This was an early example of what we are now spending time searching for: the circular economy.

There were similar pressures growing at the other end of the supply chain, with HCB’s regular overview of the bulk liquids storage sector noting that initiatives to clean up the environment and reduce the potential for future pollution were gaining momentum. That had already led to many terminal operators sectioning off large portions of their investment budgets to meet current and anticipated future regulatory demands. The January 1992 edition reported that, overall, planned investment for the year revolved less around new tank construction than on compliance with environmental legislations.

There were some in the industry that felt they were being unfairly targeted, their position in the supply chain meaning that they were

had been looking to reduce their costs by moving to plastics drums as opposed to metal packagings. But that had made users start to wonder what to do with these drums once they had been used.

As we reported in the January 1992 issue, growing pressure to reduce the amount of discarded waste and to re-use and recycle plastics products were forcing manufacturers to reconsider their

being landed with responsibilities not only under those regulations aimed at fixed facilities but also those dealing with transport operations. Furthermore, after a period of slim margins, many smaller operators reported they were going to find it difficult to find the cash for compliance. The sector was about to face some serious consolidation.

HCB MONTHLY | JANUARY 2022

UP FRONT 05

LEARNING BY TRAINING

by Arend van Campen

IS IT GOOD OR BAD TO POLLUTE THE ENVIRONMENT?

A WHILE BACK I was copied into an ongoing email exchange about degassing i.e. ventilating chemical vapours such as benzene from inland tank barges into the environment. A barge captain wrote an open letter to everyone concerned: authorities, freight forwarders, charterers, tanker owners, terminal operators, municipalities and the Dutch Ministry of the Environment. I translated some parts with emphasis on the issue at hand to tell you how frustrated this skipper had become about the disinterest at all levels to stop this environmental catastrophe, which at the time of writing, lingers on: Dear interested person!

I’ve had it....! Do you recognise that feeling? The injustice that is regularly done to people. Injustice, which is done to the inhabitants of Groningen for financial reasons, but also the injustice done to the ship’s crew by not informing them what they are transporting. Nonsense spread by politicians, executives and other people in charge, of which the citizens are once again the victims. Nonsense that the emission of very harmful and environmentally hazardous substances has no demonstrable negative effects on our Natura 2000 areas, as the Minister has said. Nonsense that the increasing drafting of safety rules and procedures will reduce

So I looked at this matter, thought about it and responded: As a business ethicist and trainer in the HSEQ - Human Factors and Behaviour Based Safety area, I often use Immanuel Kant’s ‘Categorical Imperative’: ‘Would you want to live in a world where everyone would allow this act (degassing)?’ If not, then stop doing it.

This is about human behaviour. If you do decide, under pressure from a steady job and income, to pollute the environment (and thus yourself), is that good or bad, right or wrong? By using rhetorical questioning techniques, we can make an ethical decision together as an industry, which will be positive interdependent (benefit for all) instead of negative interdependent (benefit for some, but at the expense of environment, health, life expectancy etc).

Sectors that fail to effectively implement information processes and internal control systems are likely to face an information deficit at some point, resulting in deteriorating performance. Understanding how information deficits lead to entropy or disorder is critical to running an effective and safe industry. It means that the information (everyone knows) about the fact that the environment is polluted is real. What I can advise is to use this information (as e.g. offered by the skipper) to

the number of incidents, without ever tackling the structural cause of the problems. Incompetence, due to a lack of pragmatism on the part of officials, as a result of which, for example, the granting of permits for closed degassing installations has stagnated for years, and as a result of which the environment is harmed completely unnecessarily year after year. Incompetence, by not enforcing something, because the enforcer apparently does not know the law. The list is endless.

make the corrections from within the sector itself, so that the system (inland tanker shipping) can continue without causing harm to people and the environment any longer.

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.

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The president of Port Tarragona, Josep M Cruset i Domènech, opened the event by remarking that the global pandemic has led to some difficult times in the sector but has brought home to the public the importance of the logistics function in delivering energy, food and consumer goods. Furthermore, periods of change are often full of opportunity and Tarragona has continued to invest in capacity and maintaining continuity, seeing a significant increase in traffic in 2021.

Tarragona now handles more than half of the chemicals and liquefied gases imported into Spain and, with plans for greater connectivity – not least the planned arrival of the Mediterranean rail corridor in 2023 – there is more to come.

FOR SOME YEARS now, Port Tarragona has expressed its intent to develop a bulk liquids chemical hub for the western Mediterranean, leveraging its advantages in terms of the

this past 18 and 19 November. The aim is to bring together various interests involved in one way or another with the transport and storage of liquid chemicals in bulk, to discuss

WHERE THE TRADE GOES Port Tarragona has been doing some research into the position of the port and the region as a whole in terms of bulk liquid traffic. Local boy Jordi Anglès Jové, commercial coordinator at Port Tarragona, presented some interesting figures, showing that the main western Mediterranean ports handled a total of 365m tonnes of liquid bulk in 2019, of which 48 per cent was crude oil. Chemicals accounted for just 4 per cent, indicating that there may be room for growth, he said.

Perhaps more alarmingly, Anglès said, the region’s ports are highly dependent on hydrocarbons, which account for some 82 per cent of liquids throughput. Ports need to be aware of the oil companies’ strategic plans to meet carbon reduction targets in 2030 and 2050, as well as those of ship operators, especially for ports with a focus on bunkering.

Port Tarragona has now moved onto a second phase of research for its internal use, looking at the relationship between current port traffic levels in the region and the location of the main centres of chemical and petrochemical production. Most such chemical parks are located close to ports,

existing infrastructure for chemical production and storage, its deepwater location and its links to the hinterland within Spain. To help pursue that ambition, Port Tarragona has been organising a ‘Med Hub Day’ each November and the fifth such ‘day’ (actually, two half days) took place in a hybrid format

what needs to be done and what common challenges the sector faces. Coming at this point in the Covid pandemic, this fifth Med Hub Day had plenty to talk about, not least the impending impact of decarbonisation and the implementation of the EU’s ‘Fit for 55’ carbon reduction targets.

highlighting the crucial role of logistics.

However, Anglès noted, Spanish ports differ from others in the region in having a greater diversity of products and terminals, and a more local vision. And within the Spanish market, Tarragona seems best placed to take advantage of emerging trends and

THE PLACE TO BE CHEMICAL HUB • TARRAGONA’S AMBITIONS FOR GROWTH WERE EXPLORED AT THE RECENT MED HUB DAY, WHICH LOOKED AT THE FACILITIES THAT WILL NEED TO BE IN PLACE TO SERVE INDUSTRY IN THE FUTURE

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STORAGE TERMINALS 07

opportunities, with its first-class chemical infrastructure and growing tank capacity.

During a subsequent discussion with her counterpart from the Port of Rotterdam, Ronald Backers, Genoveva Climent Dewit, commercial director of Port Tarragona, explained the key ingredients in that recipe for success: the port has introduced some tax reductions to attract business but, in the overall chemical supply chain, those are insignificant. It is more important, she said, to have all the facilities available, good depth of water and rail access, guaranteeing no delays to vessels calling at the port and moving goods through quickly.

TERMINALS TALK Port authorities can do a lot to promote traffic but, ultimately, it is up to bulk liquids terminal operators to invest in the tank capacity and ancillary services that shippers and traders are looking for. A panel with representatives from three terminal operators in Tarragona – Tepsa, Vopak Terquimsa and EuroEnergo – discussed recent and future developments.

Tepsa, now owned by Rubis Terminal, has recently finalised its second phase expansion and was due to start work on a third phase in December, reported terminal manager Leandro Crespo Ariza, who is also corporate operations manager. By the end of the work, which is due to be completed by early 2023, Tepsa will have some 100,000 m3 of tank capacity in Tarragona. Tepsa has seen a 40 per cent increase in vessel calls since 2019, with a lot of new demand for chemical storage

as traders and agents are redesigning their logistics chains. In particular, Crespo said, the cost of ocean freight is making shipments in tanks less attractive.

Other changes are being felt in the biofuels sector, with different raw materials emerging.

Terminals have to be adaptable, Crespo said: it’s a new scenario and represents a significant change. “I recognise that,” added Josep Forcadell, commercial and business development director at Vopak Terquimsa.

“We are in an era of change. It is clear that the entire industry is reshaping towards a more sustainable future.”

Forcadell’s point was that, as logistics providers, storage terminals need to be prepared to reinvent themselves, using existing infrastructure wherever possible to handle emerging and alternative fuels.

Meanwhile, as the Covid pandemic has shown, the chemicals sector is very resilient. It is an essential industry, Forcadell said, and it has a promising future.

Perhaps less well positioned to meet this future is EuroEnergo, whose business development deputy director Anastasiya Mosgovoy explained that, in the past few years, the terminal had moved away from truck and rail loading towards the handling of larger vessels, helped by the port’s investment in berth capacity. But the market is changing and it is now looking more locally; shippers are moving smaller parcels, which calls for more collaboration. It also points to a need for smaller tanks, including specialised tanks for difficult products and for wastes, which will

also require additional permitting.

Hydrocarbons will not disappear overnight, Mosgovoy said, but it seems likely that EuroEnergo’s switch to larger volumes came at an inopportune time.

A PLACE FOR PORTS How can the port authority help terminals in practical terms to deal with the transition?

According to Forcadell, infrastructure is essential but it is also crucial to make land available; Port Tarragona has done this through its harbour work and Terquimsa is now set to expand its capacity. The availability of ship services is also crucial: the better that ships can be handled, the more traffic will come. Hinterland transport is also very important but also, in a dynamic market, it is essential to have as much flexibility as possible.

Crespo agreed with Forcadell, noting also that agility in customs clearance can also help. Looking ahead, though, Crespo said that agents and traders are going to be asking for ‘green’ ports, offering shore power, new types of bunker fuel and so on. “We need to start talking about that,” he said. Forcadell also remarked that connecting the different players in the chain is becoming more important and that digitised networks for the sharing of information will be key. “We need to take a big leap if we are not going to become obsolete,” he said, and Crespo noted that the use of digitised systems is becoming commonplace in the ARA ports. “We need to adopt that to be competitive,” he added.

The logistics sector in Tarragona is clearly aware that things are changing and that they face a very different – and largely still uncertain – future. Port Tarragona is also aware and is doing what it can. But if it is to achieve its ambition to really develop a major chemical hub for the western Mediterranean, it has to find a way to offer the level of hinterland connectivity enjoyed by its cousins in the Hamburg-Le Havre range – and that means getting the Euro-gauge rail link. That should be on its way by the time this year’s Hub Med Day comes around; HCB will keep readers informed and report back. www.porttarragona.cat www.chemmedcluster.com

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and Eastern Seaboard ports. The positive impact on Louisiana’s economy will be immense.”

The first phase of construction is scheduled to be completed in mid-2022; on completion of the second phase, the terminal will offer some 10m bbl (1.59 m3) of tank storage capacity.

VOPAK MODA HOUSTON, the 50/50 joint venture between Royal Vopak and Moda Midstream, has been fully commissioned, coming onstream in December. The new facility, the first greenfield terminal to be built in the Port of Houston in more than a decade, is designed to be the premier terminalling hub on the US Gulf Coast for hydrogen and low-carbon ammonia and will leverage the deepwater capabilities of the Port of Houston to accommodate very large gas carriers (VLGCs) as well as inland barges.

Meanwhile, further east, construction work

These two new terminals provide quite different illustrations of the global fuels market, with Vopak Moda looking to a decarbonised future while NOLA looks back to a hydrocarbon-based economy. For now, at least, there seems to be room for both.

The one thing they have in common is that they seek to benefit from their ability to handle large vessels, to provide economies of scale to their customers.

For instance, Christian Amedee, COO of NOLA Oil Terminal, says: “Crude oil and clean petroleum products such as gasoline, diesel

ROOM FOR MORE Vopak Moda, meanwhile, has been designed as the only ammonia terminal in Houston with deepwater access. It is located close to the Deer Park refining and petrochemical hub, with pipeline links to the petrochemical complex to deliver ammonia, hydrogen and nitrogen to the terminal.

“We are thrilled to bring the Vopak Moda Houston terminal into full service together with our partner Royal Vopak, our customers and other stakeholders,” says Moda Midstream CEO and founder Jonathan Z Ackerman. “In today’s world, supply chains must be resilient and sustainable. With the ability to safely and reliably transport ammonia and other pressurised gases for our current and future customers, Vopak Moda Houston is a vital link in the new energy transition supply chain.

“We are in active discussions with customers to provide logistics solutions for low-carbon products, including storage and handling of green and blue ammonia, hydrogen and low-carbon bunkering,” Ackerman adds.

For Vopak, the development fits into its strategy of focusing on assets that will optimise the supply chains for new fuels, including ammonia. “We are excited with this successful cooperation with Moda,” says Chris Robblee, president of Vopak Americas.

“Our expertise and our presence in the main industrial clusters makes us well-equipped to actively contribute to the development of new supply chains for the energy and feedstocks of the future.”

has started on the NOLA Oil Terminal, sited on the Mississippi River in Plaquemines Parish, Louisiana. The $930m project will serve oceangoing tankers up to Suezmax site, as well as inland tank barges, handling crude oil and refined products. It will also offer blending, storage and transhipment services.

and jet fuel are significant trade products for Louisiana, but we aren’t able to take advantage of the larger vessels. That changes today. This terminal will be the first in the area to be able to accommodate vessels which currently are too large and deep to dock in the Mississippi River or in most Gulf of Mexico

Vopak Moda Houston has two 15,000-tonne ammonia tanks and five smaller pressurized bullet tanks with a combined capacity of 14,285 bbl (2,270 m3). It also has space for expansion at its waterfront and its remote rail loop. www.modamidstream.com nolaoil.com

CLASS IN GULF CONSTRUCTION • YOU WAIT AGES FOR A NEW TERMINAL IN THE US GULF THEN TWO COME ALONG AT ONCE. THESE NEW FACILITIES ILLUSTRATE TWO DIVERGENT ASPECTS OF THE FUELS MARKET ENVIRONMENTAL IMPACTS

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STORAGE TERMINALS 09

NEW CHAINS FOR OLD BIOFUELS • STANLOW TERMINALS HAS ANNOUNCED PLANS TO PROVIDE PART OF THE LOGISTICS INFRASTRUCTURE NEEDED IF THE UK IS TO ACHIEVE ITS ENERGY TRANSITION STANLOW TERMINALS is to invest over the next three years to transform its terminal and logistics complex in north-west England into one of the country’s main bulk liquid storage and energy infrastructure hubs for the net-zero future. It plans to develop a 300,000-m3 facility at its Stanlow Manufacturing Complex at Ellesmere Port on the Manchester Ship Canal and nearby Tranmere deepwater terminal in the Port of Liverpool to allow its customers to store, blend and distribute biofuels as drop-in alternatives to existing hydrocarbon-based fuels for the road, aviation and maritime transport sectors.

Stanlow Terminals already provides biofuels storage through dedicated supply and delivery infrastructure. This newly announced, customer-led investment will support the

growth of initiatives such as sustainable aviation fuel (SAF), linked to Fulcrum’s Northpoint project, and sustainable hydrotreated vegetable oil (HVO); it will also include waste-based feedstock import facilities, and blending and capacity expansion for existing bio-ethanol and bio-methanol.

The market for energy from renewable sources in the UK is expanding rapidly, driven by legislative obligations to encourage lower carbon fuels.

Additional storage investment opportunities for low-carbon energy products such as e-fuels, bio-LPG, bio-methane, hydrogen and ammonia are all progressing through feasibility studies. “These investments reflects the growing demand from partners and customers who are seeking storage facilities

and expertise in future fuels handling, as businesses across the economy look to decarbonise and operate in a more sustainable way,” the company states.

PARTNERING IN NET ZERO Earlier this year, Stanlow Terminals joined forces with parent company Essar and Fulcrum BioEnergy to develop a storage facility at Stanlow for SAF manufactured from non-recyclable household waste. The project will support the aviation industry’s continued reduction of carbon emissions and will support the UK drive towards becoming a net-zero economy. Stanlow Terminals is also supporting the UK’s hydrogen economy and the HyNet North West project by developing storage and distribution facilities that will be required for the future to provide a multimodal hydrogen and carbon dioxide transport hub.

“These key investments, and continued growth of our strategic relationships with customers, means Stanlow Terminals is firmly on track to becoming the largest sustainable storage and logistics hub in the UK,” says Prashant Ruia, non-executive chairman of Essar. “The government has set out a clear plan for decarbonising the economy and we are committed to playing our part in helping to achieve that.”

Michael Gaynon, CEO of Stanlow Terminals, adds: “The energy industry is changing. As the world comes together to develop innovative ways of generating sustainable energy, the supporting storage and transportation infrastructure needs to evolve. We’re primed to lead the national charge and create the UK’s first sustainable energy hub. Utilising our strong geographical position, and experience in the energy sector, we are providing solutions based on the ability to safely handle energy products to meet the needs of society’s net-zero goal.”

Between its two sites, Stanlow Terminals currently offers some 3.0m m3 of bulk liquids storage capacity in more than 200 tanks; the Stanlow complex has a range of pipeline, rail and road links to consumers, including Manchester airport and Essar’s nearby refinery, while the Tranmere terminal can handle tankers of up to 170,000 dwt. www.stanlowterminals.co.uk

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UNDERFLOOR EATING TANK REPAIRS • NEIL CHALMERS OF IKM CONSULTING EXAMINES THE ENERGY INSTITUTE’S UPCOMING RESEARCH REPORT ON ASSURING LINER INTEGRITY DURING STORAGE TANK FLOOR WORK SECONDARY CONTAINMENT UNDERNEATH aboveground storage tanks (ASTs) is an established requirement in the bulk storage of petroleum, petroleum products and other fuels. In Europe, most sites operating such storage are regulated by the EU’s ‘Seveso III’ Directive, enacted in Great Britain as part of the Control of Major Accident Hazards (COMAH) Regulations. Smaller, sub-COMAH sites in the UK, and similar facilities elsewhere, are subject to national provisions under oil storage regulations. In all cases, the principle of containment integrity applies.

One important element of under-tank containment is the increasing use of

under-tank liners, which provide a secondary barrier and thereby limit the outflow of liquid from the tank should the primary barrier fail as a result of a leak in the AST’s floor. While guidance has been published covering options for improving the integrity of AST tank floors by the use of under-tank liners, there is a lack of knowledge and experience regarding the potential for damage to under-tank liners during the repair of tank floors that have failed an inspection.

The Energy Institute’s (EI) Containment Systems Working Group (CSWG) has now developed a new technical publication based on industry research, The assurance

of liner integrity during tank floor works on above ground storage tanks holding petroleum, petroleum product or other fuels. This defines good practice procedures to preserve the integrity of under-tank liners when remedial floor repairs are required, which otherwise would most likely damage the liner, and for the reinstatement or repair of an existing liner that has been inadvertently damaged.

SCOPE OF WORK The original remit of the collaborative technical development project was to gather information based on real world industry experience of AST tank floor repairs where an under-tank liner was present, and to develop a guidance note. An industry questionnaire was issued to EI member companies and other relevant organisations (operators, suppliers and installers) to gather data on the types of tanks in use, the presence of under-tank liners, and the types of liners respondents had experience with. The questionnaire collected information on foundation types – flexible or rigid – and the specification and thicknesses of granular layers used in their construction.

Further questions gathered information on inspection frequency of under-tank liners and whether consideration was given to heat transfer effects from the cutting or welding of tank floorplates above newly installed liners, and whether liners had been retrofitted or installed as part of the original construction process.

One of the key questions asked whether repairs had been carried out on AST floors fitted with under-tank liners to date. It emerged that there had been very limited repair work carried out by the respondents at the time of the questionnaire. This was attributed to most respondents not having an inspection regime for liners, and that many liners had only been installed over the past 10 to 15 years and potential defects had not yet become apparent. Given this finding, the title of the publication was switched from guidance (reflecting mature knowledge) to a research report, given the limited experience to date.

However, the research report still provides useful information to operators, installers,

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STORAGE TERMINALS 11

designers and suppliers when considering the integrity of under-tank liners.

ANALYSING THE RISKS Following the results of the questionnaire, CSWG commissioned a parallel study using finite element analysis (FEA) to assess the heat-induced risks to under-tank liners from construction (placement of hot bitsand), welding and operational heat. This element forms an appendix to the research report.

It considered a number of liner materials to establish thermal performance, including: concrete-filled geotextile, fibreglass (GFRP), pre-hydrated geosynthetic clay (GCL), high-density polyethylene (HDPE) and polyvinyl chloride (PVC).

Each liner material was characterised using manufacturer and publicly available data to use within the modelling process. Assumed base construction details were created using typical minimum thicknesses of bitsand, sand and hardcore. FEA heat transfer analysis was undertaken on a number of composite base types, based on three scenarios: construction of tank foundations and floor, welding repair to floor plate, and operation of a heated tank.

It was found that, during the construction stage (application of hot bitumen sand), the liners (GCL, HDPE, PVC) that had two layers on top of them were not affected from the applied temperature of 120°C. In the case of the other liners (concrete filled geotextile, GFRP) and HDPE (1 layer above), where the bitumen mixture was applied directly on top of them, the resulting temperature ranges indicated that the integrity of these liners may be affected.

Consequently, the addition of two layers above the liners was found to be beneficial in mitigating heat transfer to the liners.

The heat from the applied welding temperature (1,000°C) was not found to affect the liners.

In the operational stage, as expected, pre-hydrated geosynthetic clay, HDPE (with two layers) and PVC material exhibited the

 ANY WORK ON A TANK FLOOR, PARTICULARLY IF IT INVOLVES HOT WORK, HAS THE POTENTIAL TO IMPACT ANY LINER INSTALLED UNDER THE FLOOR TO MEET CONTAINMENT PROVISIONS

lowest increase in temperature compared to the concrete-filled geotextile, GFRP and HDPE liner with one layer above it.

The research report provides additional detail about the vulnerability of liners to heat induced impact and the risk reduction provided by composite protection layers.

OUTCOMES AND RECOMMENDATIONS The research report provides a commentary on liner types, building on information previously detailed in a guidance document.

It also summarises the potential causes of damage to under-tank liners, with the aim of highlighting potential hazards to be considered when planning floor repair tasks.

These hazards are categorised into inherent properties of the liner, installation defects, chemical, heat, climatic, mechanical and physical hazards.

An assessment of risks to the liner from

Provided along with this matrix is a risk assessment template with definitions for likelihood and consequence to aid preparation of a site-specific risk assessment. These tools are beneficial to those planning repair works on tank floors and liners.

The research report also discusses possible protection measures for liners, such as mitigations for the various hazards to reduce risks. It also provides guidance on repairing under-tank liners, including investigation of the cause, and consideration of repair options, cost benefit analysis, operational hazards including gases and trapped liquids, and validation. Finally, the research report provides a summary of ‘lessons learned’ that considers investigation and root cause analysis of the defect, leading to potential modification of site practices and standards, and wider industry sharing.

The research report is expected to be published

tank works proposes that all parties have a thorough understanding of the risks to the liner prior to works beginning. The research report introduces a work risk matrix identifying the potential risks from a comprehensive list of typical repair and maintenance tasks carried out on tanks.

by the end of March 2022; once published, it will be available at https://publishing.energyinst.org/ topics/petroleum-product-storage-anddistribution/research-report-the-assurance-ofliner-integrity-during-tank-floor-works-onabove-ground-storage-tanks-holdingpetroleum,-petroleum-product-or-other-fuels.

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NEWS BULLETIN

STORAGE TERMINALS

ODFJELL GIVES OK TO HOUSTON EXPANSION

Odfjell has taken the decision to proceed with the planned expansion of Odfjell Terminals Houston (OTH)(right), with construction work on the new Bay 13 due to start in the first quarter. Bay 13 will comprise nine tanks, with a mixture of stainless and carbon steel, will a combined capacity of 32,400 m3. On completion, the new bay will increase capacity at OTH by some 9 per cent to 413,400 m3.

Odfjell says the expansion project is “consistent with OTH’s strategy of positioning itself for healthy demand for storage capacity in the specialty/petrochemical industry in the US Gulf Coast region,” where it has been operating at or near full capacity for several years. The new tanks will allow OTH to relocate and consolidate products of existing customers and optimise the use of its current storage capacity for new customers and products. Odfjell says bulk chemical exports from the US Gulf are expected to increase by 2.3m tonnes by 2024, leading to a rise in storage demand. The development of Bay 13 will, it says, assist in supporting industry growth for existing and new customers.

The tank bay will be highly automated, requiring less manual intervention, and will benefit from the ongoing Digital Transformation Program, which includes an advanced ERP system and automated control systems. It is scheduled to be operational by the end of 2023. www.odfjell.com BITUMEN BY RAIL FROM CANADA

US Development Group (USD) and Gibson Energy have put their new diluent recovery unit into full operation and begun shipping DRUbit

by Rail™. This provides a way to move heavy Canadian crude oil (bitumen) by rail to the US Gulf Coast at a cost that is competitive with pipeline. The DRUbit is loaded at Gibson’s Hardisty terminal in Alberta and is currently

HCB MONTHLY | JANUARY 2022

being shipped to ConocoPhillips’ Port Arthur Terminal in Texas, where the diluent is removed and returned to Hardisty by train, with the support of CP and Kansas City Southern.

“We were pleased to see the Hardisty Energy Terminal fully operational in line with budgeted capital cost,” says Steve Spaulding, Gibson’s president/CEO. “We consider DRUs to be a cost-effective, scalable, environmentally attractive long-term egress solution for the basin, and we remain in commercial discussions for potential additional phases at the Hardisty Energy Terminal.” www.gibsonenergy.com HYDROGEN FOR BELGIUM

The Port of Antwerp and the Port of Zeebrugge have signed a memorandum of understanding (MOU) with Chile’s Ministry of Energy with the aim of setting up a flow of renewable hydrogen from Chile to western Europe. A feasibility study had previously confirmed that importing renewable energy is achievable both from a technical and economic point of view.

“Importing renewable energy is essential if

we are to achieve a carbon-neutral society by the year 2050,” says the Port of Antwerp.

“Generating solar and wind energy in Belgium alone will not be sufficient. That is why we will be importing wind and sun from countries where both are available in abundance. When importing energy, hydrogen molecules are used as a storage medium for transportation purposes.”

This collaboration will eliminate the last barriers and gaps in the run-up to the effective start-up of green production, the establishment of the logistics chain between the continents and the logistics in the Belgian seaports and their hinterland, the Port of Antwerp says.

Chile has set ambitious targets to leverage its abundant renewable energy sources to become a carbon-neutral country by 2050 and to be producing the cheapest green hydrogen by 2030.

Speaking at the signing of the MOU this past November, Chile’s energy minister Juan Carlos Jobet said: “This is excellent news to continue consolidating Chile’s leadership in the development of this new industry. Our potential in clean energy will allow us to be the cheapest producers of green hydrogen in

STORAGE TERMINALS 13

the world, with which we will be able to satisfy our demand, but also help other countries to advance with their climate goals.” www.portofantwerp.com CHEMOIL CHANGES HANDS

Chemoil, which operates two bulk liquids storage terminals in southern California, has been acquired by a group of investment funds and renamed Olympus Terminals. The two sites are widely used for ship bunkering but also serve the greater Los Angeles area with a range of refined products, including road fuels, biofuels and other renewable energies.

The 520,000-bbl (83,700-m3) Long Beach marine terminal largely handles bunker fuels and is equipped with a marine vapour destruction unit that can handle a 10,000 b/h loading rate. The larger Carson terminal (1.29m bbl, 205,000 m3) has 22 storage tanks, multiple loading and unloading racks, an on-site truck scale and in-line biofuel blending. The two sites are connected to each other and to local refineries by an extensive pipeline network.

“We are excited to partner with these investors as we continue to serve the greater Los Angeles area,” says Vince Godfrey, CEO of Olympus Terminals. “With our strong ability to create and deliver the fuel required to meet today’s rigorous environmental standards, we are well positioned for growth.” www.olympusterminals.com NO TURKEY FOR RUBIS

Rubis Terminal Infra has agreed to sell its Turkish assets to Transpet Petrolcülük ve Enerji, subject to certain conditions and regulatory approvals. The 650,000-m3 Rubis Petrol terminal near Dörtyol, in south-eastern Turkey, handles refined products, including output from Iraq that arrives by pipeline, and has a 2.3-km jetty capable of accommodating Suezmax tankers. www.rubis-terminal.com CROWLEY GETS TO WORK IN OZ

Crowley Solutions has appointed Saunders International to provide EPC and management

services for the construction of several new storage tanks at its site in Darwin in Australia’s Northern Territory. The planned work follows the award in September of a major contract from the US Defense Logistics Agency for the storage of aviation turbine fuel and jet fuel at the terminal and the agreement with Saunders is seen as a vital components in delivering on that contract.

“We are pleased to be entering into this agreement with such a highly reputed firm as Saunders International to provide professional management and tank construction services,” says Sean Thomas, vice-president of Crowley Solutions, the company’s government services business unit. “We value their proven industry expertise in Australia and look forward to working with them to deliver Crowley’s energy solutions.”

Sydney-based Saunders has an extensive track record in the delivery of major tank construction projects, including those for military use. In the past 18 months alone, it has built tanks for the RAAF base in Darwin and is currently completing two tanks for the Australian Navy. www.crowley.com FINDS PROMPT TALLGRASS RETHINK

Tallgrass Energy has begun a comprehensive reappraisal of plans for the proposed Plaquemines Liquids Terminal, a joint development with Drexel Hamilton Infrastructure partners in concert with the Plaquemines Port & Harbor Terminal District in Louisiana. The move follows the discovery of a cemetery and potential artifacts during cultural survey work. The development footprint has been reduced to protect those areas.

While Tallgrass says that commercial activity on the rest of the site can spur job growth and has the support of local communities, it is now evaluating a range of opportunities other than the construction of an oil terminal. www.tallgrass.com

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of containerised liquid freight rose from 24 per cent in 2011 to 33 per cent in 2020; the share taken by drums and intermediate bulk containers (IBCs) fell over the same period from 70 per cent to 49 per cent. The use of flexitanks also increased sharply but, Leigh-Pemberton said, that is unlikely to continue, especially since the agreement at the COP26 meeting in Glasgow to urge a shift to the non-consumption of plastics rather than their recycling. ITCO has already done a lot to highlight the issue with flexitanks, noting that each ‘big bag’ is equivalent to some 7,000 plastics shopping bags, and Leigh-Pemberton said the message is getting through to shippers, many of them keen to promote their own sustainability credentials.

THE PAST TWO YEARS have witnessed unprecedented conditions in the ocean freight market. How has this trading environment impacted the tank container sector? Despite appearances, it has not all been bad news,

of liquid chemicals, despite some reports that shippers were moving towards bulk consignments in order to avoid high rates demanded by liner operators and increasing congestion at many leading container ports.

WHAT HAVE YOU DONE LATELY All sectors of the international liquid supply chains were affected by the arrival of the Covid-19 pandemic and its consequent impact on production and consumption levels.

However, Leigh-Pemberton said, by late 2020 there was a surge in demand for tank containers as shippers were looking increasingly towards multi-sourcing as a way to protect themselves against volatility and uncertainty of supply.

However, that rise in demand for tanks was not necessarily good for operators, who derive a significant slice of their revenues from demurrage, when receivers keep hold of the tanks for storage. That picked up again in mid-2021, with a move away from just-in-time inventory management to higher stockholdings, again as a move to protect operational continuity.

The past 12 months has also seen an intensification in the consolidation in the tank container industry, both among operators and, more especially, leasing companies. Trifleet Leasing was acquired by GATX Corp; Den Hartogh acquired MUTO; and Suttons took on the international operations of VTG Tanktainer.

as a recent webinar hosted by TT Club heard.

William Leigh-Pemberton of Bertschi, chair of the Operators Division at the International Tank Container Organisation (ITCO), explained that the sector benefited from the flexibility that the tank container concept offers in terms of both the movement and the storage

Leigh-Pemberton reported that, despite those rising freight costs, more liquids cargoes have been moving in containerised transport, either in freight containers or tank containers, continuing a long-term trend.

He quoted figures from Drewry Shipping Consultants that the share of tanks in terms

As Leigh-Pemberton put it, such deals are like buses: “You wait ages for a big deal then three come along at once.”

These trends have combined to generate a “great re-think” in the business, LeighPemberton said. Logistics service providers (LSPs) are now being recognised as an

TRYING TIMES MARKET • TANK CONTAINERS ARE IN GOOD SUPPLY AND DEMAND IS STRONG BUT EXTERNAL FACTORS ARE COMPROMISING THE SECTOR’S PROFITABILITY, ITCO REPORTS

HCB MONTHLY | JANUARY 2022

TANKS & LOGISTICS 15

indispensable and valued partner in the supply chain and shippers are increasingly willing to pay more for that service. Reliable and safe transport is now seen as being vital by shippers, who in the past had rather taken it for granted. “There is now a genuine recognition that LSPs are an integral part of the business,” he added, suggesting that the supply chain function may soon be appearing at board level in the shape of a chief supply chain officer.

SHOCK TO THE SYSTEM Leigh-Pemberton also looked closely at the “ocean freight shock” of 2021. This was caused by a combination of factors, not least the Covid pandemic and the impact that hygiene restrictions placed on supply chains, but also the closure of the Suez Canal as a result of the grounding of the new containership Ever Given, and a consumer demand boom, mainly in the US but also

 TANK CONTAINER OPERATORS ARE PRESSING FOR MORE INVESTMENT IN HIGH-QUALITY TANK CLEANING AND REPAIR FACILITIES IN ORDER TO REMOVE ONE OBSTACLE TO SEAMLESS AND EFFICIENT GLOBAL MOVEMENTS OF PRODUCT

in Europe, that pulled in a massive volume of products from China and elsewhere in Asia.

That led to ships being tied up as ports did not have the capacity to handle the additional volumes and ongoing driver shortages meant that inland connections could not cope.

This came at a time when there were very few new ships entering the container fleet, an issue that has been evident since 2016 when the major liner operators responded to the bankruptcy of Hanjin Shipping by slowing their own fleet growth. During 2021 there was also a shift of vessels onto key trades, including some being repositioned onto trans-Pacific operations, causing shortages elsewhere. Tank container operators rely on liner shipping companies to move their tanks but space has become severely constrained and, as a result, costs have risen sharply.

A WAY FORWARD Leigh-Pemberton warned that this situation does not look likely to ease in the near term.

There is little new capacity scheduled to join the global containership fleet until 2023, while demand for space remains strong.

Worse still, it is already evident that the lines are prioritising their own containers, reserving all space in 2020 for ‘company

owned containers’ (COCs), creating even more uncertainty for third-party or ‘shipper-owned containers’ (SOCs) and meaning there are “almost zero tender offers” for SOCs. Elsewhere, the success of the tank container concept has delivered consistent growth in the global tank fleet for many years but the provision of tank cleaning and repair depot capacity – crucial to the seamless and efficient flow of tanks around the world – has not kept pace, especially in Asia, where many existing depots have been forced to close because they cannot meet increasingly stringent environmental conditions. Similarly, there is a growing lack of haulage capacity and those vehicle operators specialising in tank container transport have been unable to expand capacity quickly, with long lead times for new trucks and serious problems with driver recruitment.

To overcome the difficulties it faces, the tank container industry must stress the importance of partnerships between cargo owners and LSPs, Leigh-Pemberton stressed.

Current trading conditions offer the prospect of being able to leave the old “cost-down” and short-termism behind and move towards an era of collaboration to create safe and secure supply chains. www.itco.org

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16 TANKS & LOGISTICS

CUTTING EDGE EQUIPMENT • PEROLO CONTINUES TO INVEST IN NEW MACHINERY TO OPTIMISE PRODUCTION PERFORMANCE AT ITS MANUFACTURING FACILITIES IN EUROPE AND CHINA IN THIS WORLD that we live in, even the smallest disruption can have global consequences – as we all unfortunately have seen during the Covid pandemic. Covid caused the markets to plummet before skyrocketing to unseen levels again. It also caused global supply chains to be massively disrupted, creating congestions in ports and shortages of components and materials in virtually all industries, including the tank container industry.

As a result of this disruption and volatility, companies have had to become more reactive and agile than ever. To tackle this demand for flexibility and versatility, tank equipment specialist BIP Perolo has continued to invest in new equipment that will make its production process more efficient.

In 2021, a brand new facility was built outside Bordeaux, France for the installation of a state-of-the-art laser cutting machine.

This new 10 kW machine – of European design – is now fully operational and is ten times faster than the previous laser machine. It can handle extra-large dimensions and can cut metal sheets measuring up to 4 m x 2 m, and up to 30 mm thick. This gives Perolo a cutting-edge advantage to laser cut some components as flanges that previously were too thick to be cut with a laser. The finish of the new machine is also very neat, reducing the need for further finishing operations such as deburring.

In addition, at Perolo’s headquarters in Blaye, a new vertical lathe is being installed.

 PEROLO’S NEW LASER-CUTTING MACHINE IN FRANCE IS TEN TIMES FASTER THAN THE PREVIOUS EQUIPMENT

HCB MONTHLY | JANUARY 2022

This latest version will allow for more machining functionalities and even better performance.

PART OF THE SOLUTION At the same time, Perolo’s subsidiary in Rudong, China has benefitted from further investments over the past year. A new latest technology welding robot was installed, making the production of manlids more efficient and with a consistent quality.

Furthermore, the Rudong facility has been equipped with a brand-new CNC machine to tackle the ever rising demand for equipment for newbuild tank containers.

As we move into 2022, what lies ahead for BIP Perolo? To start with, the company has been picked by the regional authorities in Nouvelle

Aquitaine for its highly selective programme Usine du future – or ‘Factory of the Future’.

This programme provides support by the local government to promote the modernisation of the industrial production sector and improve competitiveness through innovation and technological development. Experts in their field will accompany Perolo to see where and how the production model can be improved and what strategy should be implemented for a smart factory. This way BIP Perolo will not only modernise its production set-up, but will also be able to guarantee a steady production whatever the next challenge it faces.

These latest developments represent a continuation of the company’s direction since it was first established in 1919; its Blaye facility, now fully modernised, covers some 6,000 m2 of factory space. Perolo is now a division of the BIP Group, which has subsidiaries in Belgium the UK, Poland, Singapore and China, as well as a network of representatives around the world. Aside from its ranges of valves and fittings for tank containers, road tankers, rail tank cars and intermediate bulk containers (IBCs), it also provides heavy duty valves for static applications in the refining and petrochemical sector, electronic grounding devices and fuel equipment for low-pressure applications. www.perolo.com

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Indeed, in 2021 Sahreej achieved a record in cleaning 10,000 tanks in a single year, while also hitting records for the number of tanks received, repaired, leak tested and statutory tested. At the same time, the time taken to clean each tank was further reduced, falling to an average of just three days per tank across all its sites.

SINCE ITS FORMATION in September 2015, Saudi Arabian tank depot operator Kanoo Tank Services (Sahreej) has set itself the target of continuous improvement in three

local logistics, real estate and commercial specialist YBA Kanoo, to provide a critical link in international tank container supply chains.

Tank operators rely on a global network of

SETTING STANDARDS Fundamental to Sahreej’s operation is adherence to HSE standards. Since its foundation, HSE manager Faris Shali has pursued a plan to continually grow the company’s certifications and to improve staff skills. ISO 9001:2015 was gained in early 2018, followed by its first Gulf SQAS tank cleaning assessment in September 2019, in which Sahreej achieved a score of 89 per cent; this was improved in a subsequent audit to 98 per cent.

Following up on those certifications, and as part of the plan to cover all areas of safety and environmental concerns, Sahreej was awarded ISO 14001:2015 environmental management certification in July 2020 and ISO 45001:2018 occupational health and safety certification in August 2020.

Throughout this time, Shali has overseen staff development, partly through the use of the Intelex system-based Health and Safety platform that identifies key skill sets for every function. Each month a dedicated training programme of theory and practical training is completed with the specific aim of improving skills directly related to each job function. This is complemented by weekly toolbox meetings covering areas that have been identified through the Interlex ‘Near Miss’ reporting format.

In addition, first aid, resuscitation, confined space rescue and working at hight sessions are regularly run. Staff are also trained by outside bodies in specific areas, for instance in tank container handling, and Sahreej places

areas: health, safety and environmental (HSE) performance and training; developing its facilities; and growing its scope of operations and level of customer service.

Sahreej was established by Stolt Tank Containers, the largest tank container operator in the world, as a joint venture with

cleaning and repair depots in order to keep their tanks in work and, increasingly, they expect the same level of quality and service wherever they are in the world. Sahreej has, therefore, continued to develop its facilities in Saudi Arabia in response to local market developments.

a strong emphasis on its ‘Train the Trainer’ programme. One area that is gaining increasing importance is Behavioural Based Systems, which are already leading to a safer work environment.

It also helps if Sahreej’s customers are aware of what goes on in its depots and,

A PLACE TO STAY DEPOTS • TANK CONTAINERS TRANSPORT GOODS AROUND THE WORLD AND THEIR OPERATORS NEED DEPOT SERVICES WHEREVER THEY ARE. SAHREEJ IS WORKING HARD TO PROVIDE JUST THAT

HCB MONTHLY | JANUARY 2022

TANKS & LOGISTICS 19

outside of its own staff training, it conducts on-site ‘ISO tank familiarisation’ sessions, which allow its customers – and their clients in turn – to get a fuller appreciation of the tank container. These sessions always include an internal tank inspection, to get users up close with the crucial aspects of the tank. Sahreej also conducts training sessions at the loading and discharge sites in Saudi Arabia, with a particular emphasis on the correct opening and closing of manlids and the correct tightening and use of gaskets when nitrogen padding and other pressures are involved.

Sahreej is an active participant in the International Tank Container Organisation (ITCO) – its general manager Mike Tunstall is a board member and vice-chair of the tank service providers division – and it makes use of ITCO’s e-learning courses for all its key staff. Sahreej has also participated in recent ITCO webinars on confined space entry and working at height.

BUILD BACK BETTER When Sahreej was first formed, the infrastructure it inherited did not meet the

 SAHREEJ HAS WORKED HARD TO BRING ITS THREE DEPOTS IN SAUDI ARABIA UP TO INTERNATIONAL STANDARDS, AS TANK OPERATORS HAVE COME TO EXPECT

standards of the international tank container market nor those that Stolt Tank Containers expected and required. In response, plans were immediately put in place to develop the three depots in Jubail, Dammam and Jeddah.

Those plans again included a strong emphasis on HSE aspects but also on improving operational efficiency and expanding the suite of services offered to clients and the volume of tanks that can be handled.

The work included the greenfield construction of the 100,000-m2 ‘Jubail Mega Depot’ in the Jubail Royal Commission Logistics Area, work on which started in April 2017 with the facility becoming operational in September 2019. A complete renovation of the Dammam depot started in May 2017 and was commissioned in February 2019.

All operations are now completed under cover, with full walkways and working at height precautions and equipment. In the repair areas, rotators are used to ensure all work is carried out in the most ergonomic way and to avoid working at height wherever possible.

The pre-existing Groninger cleaning station at Jubail was disassembled and relocated to the Jeddah depot, where it was put into service in February 2021. This site, which occupies 10,000 m2, has also been redeveloped to offer safe working at height

and covered working areas. Inspection areas are now in place and the cleaning, heating and storage capacities have all been increased.

Initially, Sahreej only carried out basic repairs but its technical manager, Sarfaraz Selani, has now fully developed its capabilities; Sahreej can now carry out repairs to the frame, cladding, steam tubes and shell, including pitting repairs and shell inserts, at each of its three depots. All work is carried out by qualified welders working to approved Welding Procedure Specification (WPS) and Procedure Qualification Record (PQR) documentation. Sahreej is also able to carry out tank modifications to suit end users’ plant requirements.

PEOPLE AT THE CORE The third element of Sahreej’s plan involves customer service, which it sees as key to its success. Vincent Elic, the primary contact, works closely with both customers and the operations team to ensure that all customer requirements are completed and completed on time. As new projects and customers have come along, Elic is now assisted by Jayson Laya, who has responsibility for special projects.

Attention to customer service has obviously helped Sahreej achieve the record tank throughput figures in recorded in 2021, but it has also expanded its range of services. As well as those mentioned earlier, it can also carry out specialist cleaning for isocyanate and latex tanks, cross-loading, on- and off-hire inspections, road tanker and intermediate bulk container (IBC) cleaning and tank leasing. It is also offering emergency response assistance.

Tunstall believes that the success of Sahreej is down to having an excellent team that is empowered and encouraged to train and develop, together with the desire to find more services to cater for the needs of the tank container industry. Fully supported by its joint-venture partners, Sahreej is looking forward to higher volumes and adding more services to support tank operators and the Saudi Arabian oil and gas sector in general via the increased use of sustainable ISO tanks. www.sahreej.com

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TANKS & LOGISTICS

POWER UP ELECTRIFICATION • WIBAX IS PUSHING THE BOUNDARIES OF CURRENT TECHNOLOGY WITH ITS LATEST TRUCKS FROM SCANIA, SETTING RECORDS FOR ELECTRIC-POWERED HEAVY GOODS VEHICLE WEIGHTS BASED IN THE TOWN of Piteå in northern Sweden, chemical distributor Wibax has a lot of ground to cover to serve its customers. And, in this pristine environment, it also has to pay a great deal of attention to its carbon emissions.

Indeed, ever since it was established in 1986, Wibax has put sustainability high on its operational agenda and its ambition is to be a sustainable chemicals supplier that takes both people and the environment into consideration.

“We have identified transport as having the biggest climate impact in our operations,

 SCANIA HAS REACHED A NEW MILESTONE WITH THE DEVELOPMENT OF LARGE ELECTRIC TRUCKS FOR WIBAX

HCB MONTHLY | JANUARY 2022

so we have to deal with this,” says CEO Jonas Wiklund. One obvious answer is to plug into the available network of green electricity in the region. “However, when vehicles weigh as much as ours do, it starts to get complicated with electric power,” Wiklund notes.

To overcome this hurdle, Wibax has been working with Scania for a long time and the two companies have developed a new truck that will shortly enter service, the first of several Wibax intends to add to its fleet.

With the ability to haul a 64-tonne payload, these will be the largest ADR-approved electric truck in use. “This vehicle alone will enable us to reduce our carbon footprint by up to 1,370 tonnes of CO2, doing so with a vehicle

that offers full towing capacity. In other words, this is a real game changer,” says Wiklund.

“This is the first electric 64-tonner to enter service with a customer. Step by step, we are showing that electric solutions are happening very quickly and virtually across all segments,” says Fredrik Allard, head of e-mobility at Scania.

BUILD A NETWORK Just as important as designing a heavy-duty truck is having the infrastructure in place to fuel it. “Electrification means that we have to optimise transport based on parameters that are different from those used today,” says Magnus Sundström, CEO of Wibax Logistics.

Skellefteå Kraft has supplied a customdesigned charging station for the Piteå site and Wibax will initially use it to run trucks working on shorter runs in northern Sweden.

“The vehicles that will be electrified last are the longer haul ones, where range is the issue,” Sundström adds.

But gaps in the supply network cannot be used as an excuse to hold up the process of electrification, as Wiklund stresses: “Electricity supply is a hotly debated issue today and, for electrification to have its full impact, the entire electrical system must be strengthened. For us, this is a long-term strategic investment and we have confidence that those who are capable electricity suppliers will ensure that we have a sustainable and strong electricity system. At the moment, it feels natural to start in northern Sweden, where we already have a stable grid with sustainably produced electricity.

“It is important for us to be at the forefront of sustainability issues. The bottom line is that it should not just look good on paper, but mean something in reality,” Wiklund says.

“Lighter electric trucks have been on the market for a while, but for us it has not really been sustainable until now when we can electrify the haulage of 64-tonne loads.

Our core value is ‘good chemistry’ and this initiative keeps in step with this principle.

These issues have been discussed for ages, but now we are also noticing that market demand for more sustainable transport solutions is increasing, so things are really starting to happen.” www.wibax.com

SECTION SLUG

21

PRECISION. YOU CAN’T BEAT IT. It’s a simple theory, but one that has helped us to succeed for over 50 years - hard work, dedication and innovation - coupling those core values with our industry-leading safety, precision and quality gives us an advantage over competitors. We have always believed that the best way to lead is from the front, by setting an example - by being leaders, not followers.

We stake our reputation on the verifiable technical integrity of our range of products. That’s why we built our own 3rd party approved Test Laboratory – we conduct cycle & endurance tests, air & liquid flow tests and flame & explosion tests.

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22 TANKER SHIPPING

DOWN IN THE HOLE CARBON DIOXIDE • DANISH PLANS FOR THE TRANSPORT OF CO2 FOR STORAGE ARE COMING TOGETHER, FOLLOWING APPROVAL IN PRINCIPLE FROM ABS FOR VESSEL DESIGNS DAN-UNITY CO2, a joint venture between Danish gas tanker operators Evergas and Navigator Gas, says it is now in a position to place orders for the first dedicated gas carriers for the large-scale transport of carbon dioxide. New vessel designs, developed

by TGE Marine, for 12,500-m3 and 22,000-m3 carriers have received approval in principle (AiP) from the American Bureau of Shipping (ABS) and Dan-Unity CO2 will now move on to invite shipyards to take part in the project.

The company notes that the vessels will be purpose-built and therefore not compatible with other trades; as a consequence, long-term

Dan-Unity CO2 notes that the recent COP26 summit agreed to phase down the use of coal and to increase the focus on improving CCS technology to limit global warming. The transport of CO2, whether for CCS or carbon capture and use (CCU), will be a key element in the storage of emissions from industries and power plants.

Steffen Jacobsen, CEO of Dan-Unity CO2, says: “We see a growing interest in CCS and CCU and are committed to identify solutions that combine capture, transport and storage.

As a leader in the industry, Dan-Unity CO2 is deeply involved in shipping requirements in

contract commitments will be required to support newbuilding projects. It is anticipated that the ships will transport CO2 from north-west Europe to the Coda Terminal near Reykjavik, Iceland currently being developed by Carbfix, a partner in the Dan-Unity CO2 project, for carbon capture and storage (CCS) use.

North European projects of scale.”

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A ROLE IN THE FUTURE Vassilios Kroustallis, senior vice-president of global business development at ABS, notes: “Carbon capture can play a role in reducing emissions in a range of industries, but the

supply chain will need vessels capable of transporting CO2 safely and efficiently.

That’s why ABS is proud to be able to use its industry-leading expertise in gas carriers to support development of these important vessels.”

“Dan-Unity CO2 has taken a leading role in developing the needed transport solutions and the Danish Maritime Fund has supported us in our goals with a grant of DKr 2.8m to develop the vessel designs. We are proud to present the ground-breaking vessel design to yards, interested in building our new vessels,” Jacobsen adds.

Once newbuilding contracts are in place, Dan-Unity CO2 expects that the number of vessels required can be delivered within some 28 months; they will, naturally, run on green energy.

The Carbfix plan involves the storage of captured CO2 in Iceland’s volcanic bedrock, where it will petrify within two years; the project will be able to accommodate 2,500 gigatonnes of CO2, equivalent to more than 55 years’ worth of global emissions. In addition, Dan-Unity CO2 is a partner in Project Greensand, which is aiming to validate the technical and commercial feasibility of CO2 storage in the Danish part of the North Sea. dan-unity.dk www.carbfix.com

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NEWS BULLETIN

TANKS & LOGISTICS

TALKE TAKES AIM ON ASIA

Alfred Talke has firmed up plans for its first venture in south-east Asia, saying it will start work in spring this year on construction of a 17,500-m2 dangerous goods warehouse in the bonded area of Westports Terminal at Port Klang, Malaysia (right). A second, similar warehouse for non-dangerous chemicals will be added afterwards.

“Westports Port Klang has great potential for the development of integrated facilities for polymers and chemicals,” says Alex Herreboudt, director, Middle East & Africa, at the Talke Group. “We firmly believe that the region and our facilities will be of great strategic importance to our existing and new customers in the years to come. We want to further develop the entire site and have committed ourselves to extensive investments. We are able to flexibly adapt to changing market and customer requirements and can offer services that are not yet sufficiently available in Port Klang.”

The planned dangerous goods warehouse will be unique in Port Klang and will also offer value-adding services such as refilling and packaging. Through the project, Talke will create a hub in south-east Asia for its customers, building on recent rapid growth in container traffic in Malaysia. Port Klang is the second largest port in the region, behind Singapore, and has become an attractive alternative. As part of the deal, Talke plans to be actively involved with Westports in shaping the future of Port Klang. www.talke.com PSA TO BUY BDP

PSA International, the Singapore-based global port group, has agreed to acquire BDP International from Greenbriar Equity Group.

PSA says it has been collaborating with its customers and other partners to offer supply chain solutions beyond port limits and this acquisition will add BDP’s global expertise in

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end-to-end supply chain services, which have specialities in the chemical, industrial, healthcare and other sectors.

“This is an exciting time for us, as BDP will be PSA’s first major acquisition of this nature – a global integrated supply chain and transportation solutions provider with end-to-end logistics capabilities,” says Tan Chong Meng, group CEO of PSA International. “Its strengths will complement and extend PSA’s capabilities to provide agile, resilient and innovative cargo solutions.

Customers will be able to benefit from the extensive capabilities of both BDP and PSA, while accelerating their shift towards sustainable supply chains. We see this as a significant and strategic step forward in our vision to co-create an Internet of Logistics and we look forward to welcoming BDP into the PSA family.”

“The synergies between BDP and PSA are apparent, with foundations built on service excellence, delivering value to customers and stakeholders, and by creating rewarding careers for our colleagues,” adds Mike Andaloro, CEO and president of BDP International. “With the

extensive capabilities of PSA and their significant market presence worldwide, we will undertake a new chapter of growth with incredible opportunities to optimise global supply chain activities for our customers.” www.globalpsa.com www.bdpinternational.com MILKYWAY INNOVATES

Milkyway Chemical Supply Chain Services has despatched its first ever block train of liquid chemicals from China to Europe. The train, carrying 82 tank containers with some 2,000 tonnes of butanediol from Zhongtai Markor Chemical in Korla, Xinjiang, departed on a 15-day trip to Ludwighafen, Germany, a distance of more than 8,000 km.

Milkyway says the new service, its response to the national Belt & Road strategy, greatly improves the efficiency of international logistics to Europe, shortening the cargo circulation cycle and helping China’s chemical manufacturers to become more deeply integrated into the international market.

Meanwhile, Milkyway has also commissioned a new warehouse complex in Zhangjiagang,

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on the Yantze River in Jiangsu province, China.

This is Milkyway’s first second-generation “intelligent chemical warehouse”, building on its experience with the first unmanned, explosion-proof warehouse opened in 2020.

Milkyway’s IT team has spent six months developing the automation system, adding fully automated forklift operations and enhancing accuracy, further reducing operating costs. www.mwclg.com N-W ADDS WEMMERS

Nijhof-Wassink has agreed to acquire Wemmers Tanktransport, effective 1 January.

Wemmers, based in Evergem, Belgium, specialises in the transport of liquid bulk foodstuffs in road tankers and intermodal tanks, complementing Nijhof-Wassink’s expertise in liquid and dry bulk chemicals and animal feed.

Wemmers also has operates two cleaning stations in the Netherlands.

“The possibility to add food logistics to its existing portfolio will diversify the range of specialised transport the company can offer,” says Erik Schiphorst, CEO of Nijhof-Wassink Group. “This will have a positive impact on the continuity of our company. In recent years,

we have made huge progress in data analysis, efficiency and effective fleet management.

We want to implement the same progression at Wemmers, a respected company that is active in many European countries.”

“At Wemmers, we examined the current market circumstances and various scenarios to identify how we could remain a healthy business in the future. An acquisition was one of the options,” says Paul van den Nieuwenhuizen, director and owner of Wemmers Tanktransport. “During discussions with Nijhof-Wassink we felt a special connection, and the right feeling. NijhofWassink is a close-knit, family-run company with a strong focus on its human capital.

Incorporating our brand names Wemmers and Troll in the Nijhof-Wassink Group unites two companies that share the same DNA and focus.

We can mutually benefit from each other’s strong points.”

On completion of the acquisition, NijhofWassink will be a specialist in the transport and storage of dry and liquid bulk goods for the chemical and animal feed industry and the food sector, employing 1,750 colleagues based in eight different counties and operating almost

800 different truck-trailer combinations. nijhofwassink.com wemmers.nl E-COMMERCE FROM FORT VALE

Fort Vale has opened a new online webshop, featuring a wide range of spare parts and accessories. The shop, which can be accessed directly at https://shop.fortvale.com/en/, gives customers the ability to specify and order parts - safe in the knowledge that they come direct from the manufacturer. Fort Vale says it has made great efforts to ensure that ordering is a quick and simple process.

The site is so far only for UK customers but will be opened up to the European market early in 2022. It also features quantity discounts, special offers and flexible delivery options. “Fort Vale’s new e-commerce site has been in the pipeline for a while now as part of our ongoing efforts to make it easier for our customers to purchase branded spare parts and accessories, and giving them the reassurance that the parts they buy are of the highest quality possible,” says Graham Blanchard, global marketing director at Fort Vale. www.fortvale.com MORE TANKS FROM GATX

GATX Europe has begun construction of a series of type 7182 rail tank cars for lease to its chemical industry customers in mid-2022.

The 82-m3 tank cars, built at GATX’s WSO workshop in Poland, are optimised for the transport of ethyl and methyl chloride and vinyl chlorides, manufactured from P460/630 grade steel and equipped with hydraulically operated bottom valves. They also feature a DOT Telematik self-sufficient telematics system for tracking and tracing and are compatible with the Digital Automated Coupling (DAC) system, a project in which the company has played an active role. www.gatx.eu

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DIGITISATION

AWAY WITH THE PAPER TRANSPORT • ECTA IS CONTUING WITH ITS EFFORTS TO IMPROVE EFFICIENCY BY STANDARDISING DATA FLOWS IN THE EUROPEAN CHEMICAL TRANSPORT SECTOR WITH TWO NEW GUIDELINES THE EUROPEAN CHEMICAL Transport Association (ECTA) has in recent years been promoting the growing use of digital transmission of data through the chemical supply chain, pushing its members (and others) to adopt new technologies and to reap the benefits on offer. That process has included working with other bodies to develop the electronic EFTCO Cleaning Document (e-ECD) and the development of ‘milestones’ in transport operations to help standardise electronic documentation.

ECTA’s digital workgroup has now drawn up two best practice guidelines, one on the exchange of transport order data for bulk chemical shipments and the second on equipment master data standards for bulk and packaged chemicals.

The first of these, on transport order data standards, builds on the transport visibility guideline published in January 2021. In the order-to-cash process within bulk logistics, additional data is exchanged between shippers and logistics service providers (LSPs). Order-related information is transmitted from the shipper to the LSP to specify shipment instructions and, after the transport has been completed, invoice-related information is exchanged to trigger the completion of the service. The payment process involves not just the basic freight cost but also other items, such as heating, waiting time and auxiliary services.

At present, ECTA says, many different electronic data sets are being exchanged between shippers and carriers, leading to extra complexity, process inefficiencies and incorrectly fulfilled customer orders.

The objective of this new ECTA guideline

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is to give the involved stakeholders additional guidance on how to exchange transport order information in a standard way, so as to further enhance the digital adoption rate and improve interoperability. It also recommends the application of order data standards based on the OAGIS® Chem eStandard 5.4.

MASTER THE DATA While the transport order data guidelines build on existing work, the new best practice guideline on equipment master data represents a move into a new area. Currently, ECTA says, checklists and data sharing concerning vehicle equipment is a paperbased activity, involving the exchange of pieces of paper by humans at loading and unloading sites, with all the potential for error and falsification. Furthermore, the structure and content of those checklists can vary.

To to bring chemical logistics up to the next level of safety, quality, sustainability and

efficiency, ECTA believes this process needs to be standardised and digitised. This will help customers and suppliers to better address the more complex business needs and equipment requirements at both loading and unloading places.

Such digital sharing of master data regarding equipment is in its infancy, ECTA says. There is the opportunity for players along the supply chain to find new ways to collaborate that will improve operational accuracy and reduce the need for information to be re-keyed in each player’s system. Such technology will also make it easier to confirm that applicable regulations and standards are being met.

The ECTA guideline on equipment master data represents a first step in this area and the organisation says it expects it to evolve and expand over time. In this first edition, it is limited to those pieces of equipment that come into closest contact with the chemicals being transported, focusing on box containers, tank containers, tank trailers and tautliners (aka curtain-siders).

The guideline includes a master data template in Excel format for the four different types of transport equipment. This makes it easy to keep information up to date and, by using a standard format, to exchange that information between the various actors in the supply chain.

More information on both new guidelines can be found on the ECTA website at www.ecta.com/ guidelines/.

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NOTE: IF THERE IS A ONE PAGE FEATURE (LEFT HAND SIDE) NEXT TO AN ADVERT THEN YOU NEED TO MOVE THE “SECTION SLUG” OVER TO THE OTHER SIDE SO THE READER KNOWS WHAT SECTION THEY ARE IN. IF TWO ONE PAGE FEATURES ARE SIDE BY SIDE, BUT THEY BELONG TO DIFFERENT SECTIONS THEN YOU NEED TO HAVE A “SECTION SLUG”

2022 ON BOTH SIDES

AND BEYOND

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FLY BY WIRE AIR CARGO • LUFTHANSA CARGO HOPES TO KICK-START DIGITISATION ACROSS THE AVIATION SECTOR WITH ITS ADOPTION OF IBS SOFTWARE’S TOOLS FOR HANDLING CARGO

IN A MAJOR STEP towards digitalisation and improving quality in worldwide cargo handling, Lufthansa Cargo is partnering with IBS Software to digitalise critical handling processes for special products and services, including dangerous goods, pharmaceuticals and fresh produce. The deployment represents significant progress for Lufthansa Cargo’s ‘Mobile Digital Handling’ initiative, created to eliminate paper-based processes across its operations by digitising tasks and process checks carried out by its Ground Handling Agent (GHA) partners.

The initiative leverages IBS Software’s latest iPartner Handling solution to extend Lufthansa Cargo’s special checks and standard operating procedures (SoPs) to its extensive global GHA network. The solution seamlessly integrates with airlines running IBS Software’s iCargo cloud platform for air cargo management to provide a single access, easy to use set of mobile and web tools that GHAs can use to carry out specialised workflows and tasks.

Through the iPartner Handling solution, rich information captured by GHAs is made available to Lufthansa Cargo on a real-time basis, enhancing the quality and service levels of all of its cargo products. The platform also offers digital connectivity options for GHAs via APIs and has been architected keeping future industry initiatives such as ONE Record in mind.

The roll out has been planned in two phases, the first of which will see more than 30 Lufthansa Cargo stations across Europe, Asia and the Americas going live, followed by additional stations and several new use-cases

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and enhancements being added to the solution. The first wave of five stations has already successfully gone live.

THE BIGGER PICTURE “Driving the digital transformation of our industry has always been an ongoing priority for us at Lufthansa Cargo,” says Dr JanWilhelm Breithaupt, vice-president of global fulfilment management at Lufthansa Cargo.

“Aside from directly improving the data quality and thus making processes more efficient, the ‘Mobile Digital Handling’ initiative also opens up tremendous opportunities for us for further innovating and improving how we work with our partners along the whole supply chain.”

“There is significant impetus in the industry to foster digitalisation initiatives that enhance partnerships and collaboration in the supply chain,” adds Ashok Rajan, senior vicepresident and head of Cargo & Logistics at

IBS Software. “The iPartner Handling solution takes us one step further towards our over-arching goal of building a digital ecosystem for our iCargo customers that can help generate positive business outcomes for them quickly and effectively.”

“We are glad to develop our long-term partnership with IBS Software even further.

‘Mobile Digital Handling’ is the next success story for how the combination of IBS Software’s technology leadership and Lufthansa Cargo’s innovation capabilities contributes to shaping our industry,” comments Dr Jochen Göttelmann, CIO at Lufthansa Cargo. “It was a pleasure to see how the realisation of our vision went hand in hand with the development of the iPartner Handling solution. Being the launching customer, we hope that other cargo airlines will join soon this new community solution.

In joining forces we will drive the digitalisation of the industry.”

IBS Software, owned by Blackstone, is a leading SaaS solutions provider to the travel industry globally, managing mission-critical operations for customers in the aviation, tour and cruise, and hospitality industries. IBS Software’s solutions for the aviation industry cover fleet and crew operations, aircraft maintenance, passenger services, loyalty programmes, staff travel and air cargo management. lufthansa-cargo.com www.ibsplc.com

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ASKING QUESTIONS INSPECTIONS • OCIMF IS UPDATING ITS LONGSTANDING SHIP INSPECTION PROGRAMME, LEVERAGING TECHNOLOGY TO MAKE IT MORE USER-FRIENDLY AND PROVIDE RICHER RESULTS THE OIL COMPANIES International Marine Forum (OCIMF) is overhauling its Ship Inspection Report Programme (SIRE) and taking advantage of technology developments by introducing tablet-based inspections.

This will, OCIMF says, deliver a more comprehensive inspection process and enhanced policies and procedures as from the second quarter of this year. The new programme, SIRE 2.0, will facilitate a risk-based approach to assessing the safety and quality of a vessel and its crew on an ongoing basis, but will require a “change in mindset” from industry, OCIMF has warned.

Under SIRE 2.0, accredited inspectors will complete a Compiled Vessel Inspection Questionnaire (CVIC) in real time using a tablet device. Unlike the existing paper-based questionnaire, the SIRE 2.0 CVIQ uses a sophisticated algorithm to select questions from a question library based on the type of vessel, its outfitting and operational history to create a bespoke risk-based inspection questionnaire. This means no two inspections will be the same.

In another significant change to the reporting process, most questions require the inspector to provide responses based on hardware, processes and human factors, with observations graded from “not as expected” through to “exceeds expectation”.

Observations will also be supported with

and negative observations can be documented.

Enhanced governance processes will ensure greater transparency and control for OCIMF and other parties involved in the programme, with stringent compliance requirements enhancing accountability and creating an altogether more robust programme that can more easily be adapted to the evolving risk profile of the industry.

documentary and photographic evidence (where permitted).

As a result of these enhancements to the programme, each inspection question set is varied, providing vessel operators and crews greater opportunity to demonstrate their best practices, and for the first time both positive

to encourage a safety culture aligned with the principles contained in the OCIMF Human Factors Approach paper and framework for integrating human factors in management systems.”

Software for the intrinsically safe tablet devices has been developed in consultation

DETAILED TAILORING OCIMF’s managing director Karen Davis explains: “The development and introduction of the SIRE 2.0 tanker inspection regime represents a significant change for OCIMF, its members, users of the inspection programme and the marine industry as a whole. It’s a move away from a snapshot ‘yes/no’ approach to providing richer, more meaningful insight that can be acted upon.

“The new programme will ensure observations are given context and will result in more detailed, reliable, granular and comparable marine assurance data, helping the report recipient better understand how well a vessel is managed,” Davis adds.

“Central to SIRE 2.0 is the integration of human factors assessments which will take into account performance-influencing factors, as OCIMF acknowledges that mistakes are typically due to conditions and systems that make work difficult. SIRE 2.0 is designed

with ports, terminals and ship operator stakeholders, in accordance with best practice as defined by the International Safety Guide for Oil Tankers and Terminals (ISGOTT). Given the complexity of the project, over the past three years OCIMF has been engaging with different stakeholder groups at relevant junctures to gather feedback, input and technical expertise.

Sam Megwa, OCIMF’s programme director, explains: “At OCIMF we are doing everything we can to support industry to transition from SIRE to SIRE 2.0. While there is work still to be done to bring SIRE 2.0 online, the team are well underway with the trial inspections programme and have already rolled out a series of workshops with more planned over coming months. Transition training of inspectors has also been underway for some time already, with additional courses due this year. We will continue to engage with all stakeholders to ensure the successful implementation of the programme, and to help our industry achieve zero accidents to people and the environment”. www.ocimf.org

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DIP YOUR TOES ONLINE TRAINING • DAN LEE, ONE VERY SATISFIED CUSTOMER, EXTOLS THE UNEXPECTED VIRTUES OF A NEW APPROACH OFFERED BY DANGEROUS GOODS ONLINE TRAINING THE FUTURE IS HERE! I prostrate myself on the altar of forgiveness for daring once to say that e-learning will never replace the skill of a trainer in a classroom environment. There now exists an online e-learning programme of such power and effectiveness that we need never have to endure another gut-wrenchingly boring delivery of IATA Dangerous Goods by Air as we sit through two days of a refresher or re-do three days for an expired initial course.

The future is, as I said, already here and it brings with it these benefits: • It’s cheaper than a standard instructor-led course and there are no travel or

accommodation fees to add • You learn at your own pace – as slowly or as quickly as the program will let you • Direct feedback lets you know if you have correctly understood and thus correctly applied the learning within each module • Access to a book of knowledgeconfirmation exercises and further explanation of key points • Doing the end-of-course examination in the comfort of your own home • Receiving detailed written feedback on what you answered incorrectly or incompletely.

Those who know me will attest that I am not a big fan of International Air Transport

Association (IATA) training; this stems from my days working for what was at the time the world’s largest airline and attending various DG by Air training courses delivered by a wide range of training providers who all had one thing in common: strict adherence to the boring IATA process where the content is delivered by an instructor.

MAKE THE CHANGE When I left the airline world I reduced my exposure to the biannual tedium of IATA DG

by Air training to once every five years, just to keep my hand-in and to maintain my sanity.

I am a firm believer that a DGSA or DG professional must learn more than just the road element of their craft. The UK is an island nation and both the sea and air modes of transport are vital elements to get dangerous goods items away from our shores.

I used to resent having to take three days of unpaid leave (I am self-employed) and sit through a course that was akin to being slowly bludgeoned to death by a manual with blue and yellow pages, so it was out of a mixture of curiosity and necessity that I embarked on the new method of IATA DG by Air delivery offered

by Paul Horner and his team at Dangerous Goods Online Training.

My curiosity came through various experiences and exposure to e-learning from my time as a police law trainer back in the 1990s and in airlines and freight forwarders during the 2000s. My necessity was due to a client requesting an ‘in-date’ IATA DG by Air certificate. Covid-19 restrictions on both travel and attendance for one of the few DG by Air courses being delivered around the country also had a bearing on my decision to take the plunge and immerse myself with the online process.

I do not want readers to think that I curried favour by asking for a discount to undertake the

 SHIPPING DANGEROUS GOODS BY AIR IS A COMPLEX BUSINESS AND EFFECTIVE TRAINING IS VITAL TO PREVENTING MISTAKES AND ACCIDENTS

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training. I am a great believer in paying the full price for training as I never offer discounts for my training courses because when you know something is good why would you sell it cheap?

HOW IT FEELS The administration, payment and access to the Dangerous Goods Online Training course is almost instantaneous. Once you receive your password and username you can commence the learning immediately. The content is delivered in 12 modules that cover all the basics of the IATA DG by Air content that you would expect from a standard course.

But, unlike a standard course, you can go back and play the module again if you didn’t quite understand the content. If you are struggling after playing it through a couple of times you can email an online instructor to give you specific help.

Each module is provided in text and picture format with a narration so you can listen and read the content as it is delivered. There are regular knowledge checks in the form of exercises and questions to let you know whether you are applying the content in each module correctly.

I particularly liked the reference to reading the content of the relevant section rather than just relying on the delivery of the e-learning module’s content. This is an important point that is often missed or rushed through on standard IATA DG by air courses – you have to read and understand the content in the manual in order to apply it properly.

The e-learning programme is well thought through and delivered very professionally.

You could do the whole 12 modules in one day – but why would you? Or you could do it as I did, spread over a couple of weeks. I enjoyed

listening and engaging with the modules with a cup of tea, glass of beer or tumbler of whisky to hand. Some modules I did in a spare hour in the morning, a stolen hour prior to picking up the kids from school and in the wee small hours when the rest of the house was asleep.

I knew then that I could never go back to sitting in a training room in some grey, featureless hotel with 20 other people crammed in a room where 12 was the maximum occupancy, all struggling to make sense of where we were in the manuals and what the instructor was going on about…

FEEDBACK LOOP When you have received and completed all the modules within the e-learning programme you are immediately contacted with an email to arrange your exam. The exam paper is delivered via a parcel delivery service and the exam is taken within a one-on-one, online, invigilated session. The following day, the paper is collected by the same parcel delivery service back to Dangerous Goods Online Training.

The result of your exam is provided within three days of receipt (mine was the next day) and you get detailed written feedback as to which questions you failed to score the maximum points on. Fortunately, I passed the exam and I had my certificate ready to send to the client within the email congratulating me on my result.

I can hear the swathes of DG instructors and trainers protesting that such online learning programs can never replace the interaction that they have with their student as they struggle to comprehend the weird and multi-levelled world of dangerous goods. They

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may have a point for ADR and DGSA training but, when you stop the automatic and natural objections to something that could threaten your livelihood, the premise of consistent delivery of the IATA DG training is what is needed in the theatre of global compliance to an agreed standard.

If you view this online training programme objectively you will see that it now frees up the existing IATA DG trainers to go and assist companies by doing more specific and directed learning as their IATA DG training needs analysis requires. As a qualified trainer, I welcome training a group of staff who all have a known, consistent level of knowledge so that I can take their development to the next level of competence and effectiveness where their DG knowledge leads to fewer business delays and an enhanced business reputation of being able to get the air freight moving with minimal delay. Isn’t that after all what a company wants, more than just a tick in a CAA Audit Compliance List?

Well done Dangerous Goods Online Training, I am converted! All my requirements for IATA DG by Air will, in future, be met by DG Online Training’s excellent training programmes and I will heartily recommend any DG professional, who hasn’t done so already, to dip their toe in the Future of DG by Air learning to determine whether this method of delivery meets their requirements too.

This is an edited version of an article written

by Dan Lee of Dan Lee Training (www. danleetraining.com) for the British Association of Dangerous Goods Professionals’ (BADGP) newsletter.

For further details about Dangerous Goods Online Training’s courses, visit www.dgonline. training or call +44 800 649 6799.

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PRIME MOVER REGULATIONS • CANADA IS SET TO BECOME THE FIRST COUNTRY TO APPLY COMPETENCY-BASED TRAINING REQUIREMENTS IN ITS DOMESTIC DANGEROUS GOODS TRANSPORT RULES TRANSPORT CANADA has opened a consultation on its proposals to amend Part 6 of the Transportation of Dangerous Goods (TDG) Regulations, which sets out training requirements. The proposals, published in Canada Gazette Part 1 on 11 December 2021, aim to provide a stronger framework for the oversight of training by removing the phrase “adequately trained” from the TDG Regulations and inserting references to the new standard CAN/CGSB-192.3-2020, ‘Transportation of dangerous goods training, assessment and competency’.

The move comes as a result of increasing

awareness that the existing provisions do not provide a robust set of rules and that, while most stakeholders meet or exceed the current training requirements, Transport Canada (TC) inspectors have identified that some employees lack the knowledge and skills required to conduct their dangerous goods tasks despite possessing a valid training certificate. TC’s TDG monitoring programme revealed that, of the 409 dangerous goods incidents resulting in injury or death reported between 2014 and 2019, approximately 55 were attributed to improper or insufficient training.

TC has been working for some years on the

issue. It began a targeted consultation in 2016, involving more than 100 representatives from federal, provincial and local authorities, companies, industry associations and training providers, followed by a more tightly targeted consultation with 35 of these stakeholders; this was followed by a public online consultation and then the development of standards and proposals for regulatory amendment.

QUESTIONS RAISED In that consultation process, most stakeholders who provided comments agreed that the term “adequately trained” is subjective and should be clarified, by identifying the specific responsibilities regarding the training and the maintenance of knowledge and skills for persons who handle and transport dangerous goods.

It was also clear that cost is an issue and that any changes to the current requirements that resulted in added costs would be unwelcome. TC had already raised the idea of moving to a competency-based training and assessment (CBTA) approach, which some stakeholders felt could be costly. The general view was that any new provisions should allow for flexibility, with the option to use costeffective methods such as in-house and online training, where these methods meet TC’s standards, rather than on the sole option of off-site, in-person training. Indeed, if TC were to certify trainers, this could result in a reduction in available training capacity and an increase in costs to employers.

Those concerns were carried through into the development of the new standard under the direction of the Canadian General Standards Board (CGSB), with work carried out by industry, training organisations and governmental departments. CAN/CGSB192.3-2020 was published online in November 2020. One aim of its approach was that there should be no policy change for those employers that are already complying with

 THOSE SUBJECT TO THE PROVISIONS OF THE TDG REGULATION WILL HAVE TO DEMONSTRATE THAT THEY ARE COMPETENT TO PERFORM THE ACTIONS REQUIRED BY THEIR ROLE IN THE TRANSPORT OF DANGEROUS GOODS

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the training requirements. Also, by specifying the requirements for both general awareness and function-specific training and assessment in the training standard, the Canadian training requirements would be better aligned with international TDG training requirements.

WHAT’S THE DIFFERENCE? Competency-based training is a performancebased approach that focuses on the outcome (competency) rather than prescriptive methods (such as specifying the number of hours of training required). Competency-based training is deemed successful when employees demonstrate they have acquired the necessary “knowledge, skills and attitudes to carry out activities or tasks under specified conditions”, which represents the ‘assessment’ element of CBTA. This approach is taking broader hold in industrial applications; in particular, the International Civil Aviation Organisation (ICAO) has employed it in various training provisions in general aviation disciplines and is preparing to introduce it to the carriage of dangerous goods by air as from 2023. Its plans have been widely circulated to give industry time to prepare and, based on feedback from dutyholders, have been amended and improved since they were first announced.

ICAO defines ‘competency’ as a combination of knowledge, skills and attitudes required to perform a task to the prescribed standard.

The main component of that standard is that employees (and the self-employed, who are also covered by the TC proposals) receive both general and function-specific training for their tasks; that there are set performance criteria in place to evaluate competence in performing those tasks; that records of training and assessment are maintained; and that there is recurring training and assessment as needed to maintain skills.

ICAO has encouraged the UN Subcommittee of Experts on the Transport of Dangerous Goods to consider the adoption of the CBTA approach across all modes.

TC’s proposals are in line with that request.

PROPOSALS IN DETAIL TC is proposing that, instead of using the vague term “adequately trained”, the TDG

Regulations will specify that, to be competent for TDG tasks, a person must receive both general awareness and function-specific training and assessment. The assessment would be documented in a ‘certificate of competency’, which would replace the current ‘certificate of training’.

The CGSB training standard would be incorporated by reference (as amended from time to time) in the TDG Regulations.

The training standard would outline requirements for training, assessment and competency of persons who handle, offer for transport or transport dangerous goods by road, rail, marine and air in Canada.

The certificate of competency would contain similar information to that of the previous certificates of training. However, certificates of competency would need to indicate that the person has received general awareness and function-specific training in accordance with the standard. Function-specific training should be indicated by codes identified in the standard. Based on consultations, the requirement for an employee’s signature on the certificate of competency has been removed to minimise the information on the certificate. The requirement for certificates of competency to be signed by the employer, an employee acting on behalf of the employer or a self-employed person could be done electronically.

The provision will enter into force on publication in Canada Gazette Part II; however, there is a proposed 12-month transition period, after which time all training will have to comply with the new requirements.

Employers may need to manage both the old and new requirements until the expiry of the certificates under the old requirements. This means it may take up to four years before all employees comply with the new requirements.

Before then, TC is planning to help facilitate implementation through a number of outreach and publicity efforts. Its website will be

uses to consult with industry, will also provide information and updates on research; TC says industry is aware of the proposed amendment to Part 6. An article will be included in the TDG Newsletter for publication in the next issue after the amendment comes into force.

TC’s TDG inspectors and provincial/territorial inspectors will also be given training on the new requirements, which may include a combination of classroom instruction, web-based learning, advisory notes, bulletins, frequently asked questions and enforcement instructions. Costs for such training will be managed within TC existing resources.

Following the transition period, inspectors will ensure that all persons handling, offering for transport or transporting dangerous goods are competent, based on their functionspecific tasks and the company’s operations.

To verify compliance of employers, inspectors could review certificates of competency and

updated regularly, with new awareness materials, alerts, advisory notices and bulletins. The TDG website will also be updated to include the text of the amendment and any safety awareness materials developed in response to stakeholder requests. The TDG General Policy Advisory Council, which TC

training records, and identify tasks that employees perform, ensuring that they are included in the employee’s task description.

The consultation period ends on 9 February; full details can be accessed via TC’s TDG website at tc.canada.ca/en/dangerous-goods/ transportation-dangerous-goods-canada.

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34 COURSES & CONFERENCES

CONFERENCE DIARY The ongoing global Covid-19 pandemic continues to cause the cancellation or postponement of many events planned for the next few months and many organisers are taking their events online. HCB is doing its best to keep on top of developments but readers should check the dates and locations shown below as things change rapidly.

JANUARY COHMED JANUARY 24-28, SAN DIEGO Annual conference of the Cooperative Hazardous Materials Enforcement Development (COHMED) programme https://cvsa.org/eventpage/events/cohmedconference/ European Oil & Energy Storage Conference JANUARY 25-26, AMSTERDAM Platts’ 15th annual conference on oil markets for terminal owners, ports, oil traders, financiers and analysts https://plattsinfo.spglobal.com/european-oilenergy-storage-conference#/summary

FEBRUARY Internationale Gefahrgut-Tage Hamburg 2021 FEBRUARY 14-15, HAMBURG 37th annual conference on dangerous goods transport (German language) www.ecomed-storck.de/Veranstaltungen/ Internationale-Gefahrgut-Tage-HamburgVeranstaltung-Hamburg-14-15-02-2022.html Battery Recycling Europe FEBRUARY 16-17, LONDON Conference for the battery recycling and manufacturing sectors www.wplgroup.com/aci/event/battery-recyclingeurope/ International Energy Week FEBRUARY 22-24, VIRTUAL/LONDON Annual week of meetings, conferences and seminars (formerly ‘IP Week’) www.ieweek.co.uk

StocExpo 2022 MARCH 8-10, ROTTERDAM The main annual exhibition and conference for the European tank terminal industry www.stocexpo.com/en AFPM Annual Meeting MARCH 13-15, NEW ORLEANS AFPM’s annual meeting for refiners and marketers www.afpm.org/events/2d323f000003c1 Intermodal South America MARCH 15-17, SÃO PAULO/HYBRID 26th annual international exhibition on intermodal logistics, cargo transport and international trade www.intermodal.com.br/en Hydrogen & Fuel Cells Energy Summit MARCH 16-17, PORTO Conference to discuss innovations in hydrogen and fuel cell technology, production and transport www.wplgroup.com/aci/event/hydrogen-fuel-cellsenergy-summit/

BADGP MARCH 24, COVENTRY Annual AGM and seminar of the British Association of Dangerous Goods Professionals www.badgp.org/ AFPM IPC MARCH 27-29, SAN ANTONIO AFPM’s annual International Petrochemical Conference www.afpm.org/events/2d321600000fbc ChemCon Europe MARCH 28-APRIL 1, LONDON Platform for discussion on international chemical legislation https://chemcon.net/

LNG Congress Russia MARCH 16-17, MOSCOW Eighth annual congress and exhibition on developments in Russian and Arctic LNG www.lngrussiacongress.com/en

LogiChem MARCH 29-31, ROTTERDAM Chemical supply chain and logistics conference http://logichem.wbresearch.com/

AHMP National Conference MARCH 19-23, LAS VEGAS Annual conference of the Alliance of Hazardous Materials Professionals www.ahmpnet.org/events/EventDetails.aspx

APRIL

MARCH

Tanks and Terminals 2022 MARCH 21-23, DUBAI Third annual conference and workshop on integrity management of aboveground storage tanks www.marcusevans-conferences-middleeastern. com/marcusevans-conferences-event-details. asp?EventID=26765&SectorID=42#.YZvCdlPLdMA

PPC Spring Meeting MARCH 6-8, TUCSON Bi-annual meeting and tradeshow of the Petroleum Packaging Council www.ppcouncil.org/upcoming-meetings.php

Hazards Asia Pacific MARCH 22-23, VIRTUAL Annual process safety conference www.icheme.org/career/events/hazards-asiapacific/

HCB MONTHLY | JANUARY 2022

2+2 MARCH 22-25, SAN FRANCISCO Joint event by the International Air Cargo Association (TIACA) and Transport Logistic to discuss innovation in the logistics sector www.aircargoforum.org/conference/2plus2/

CVSA Workshop APRIL 3-7, BELLEVUE, WA Meeting for industry, regulators and enforcers to improve commercial vehicle safety www.cvsa.org/events/cvsa-workshop/ Nor-Shipping APRIL 4-7, OSLO Biennial exhibition for the global maritime industry http://nor-shipping.com/ COSTHA 2022 APRIL 4-8, VIRTUAL Annual forum and expo of the Council on Safe Transportation of Hazardous Articles www.costha.com

COURSES & CONFERENCES

35

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36

INCIDENT LOG ROAD/RAIL/AIR INCIDENTS Date

Location

Vehicle Type

Substance

Details

Source

31/10/21 Karnal, road tanker fuel

Haryana, India

Fuel tanker with load from Panipat refinery collided head-on with truck on Assandh-Jind road near Gangatehri; tanker driver was trapped and died in ensuing fire; three other people injured in crash; police investigating

Hindustan Times

31/10/21 Enagi, road tanker diesel

Niger, Nigeria

Road tanker with diesel collided head-on with cement truck; at least two people killed in crash; fire from burning diesel spread to several other vehicles, nearby shops

Nigerian Tribune

31/10/21 Durban, road tanker gasoline

KSN, South Africa

Fire broke out in road tanker parked in Clairwood industrial area, cause unknown; burning gasoline flowed into nearby river, sparked explosion, fire on Transnet pipeline; at least two people killed

Sowetan Live

2/11/21 nr Divide, road tanker

Colorado, US

Tank truck with sodium cyanide cargo rolled over on Highway 67 near Mueller State Park, cause unknown; no leak of cargo discovered but highway was closed indefinitely as a precaution during response

The Gazette

3/11/21 Manchester, road tanker gasoline

New Jersey, US

Tank truck with 8,700 gal (33 m3) gasoline caught fire on Route 37 after hitting car disabled after striking a deer in the road; tanker swerved, struck concrete divider; no serious injuries; road closed in both directions

Asbury Pk Press

5/11/21 Freetown, road tanker fuel

Sierra Leone

At least 130 people were killed, many more injured by explosion after leak of fuel from tanker that collided with truck while turning into filling station; many of those killed had been collecting fuel spilling from tanker

CNN

6/11/21 nr Hurn, van fireworks

Hampshire, UK

Van carrying fireworks for display at Matchams race track caught fire after some lit fireworks fell onto it; spectators fled as fireworks rained down on them, criticising organisers for lax safety

Daily Echo

8/11/21 Edati, road tanker fuel

Niger, Nigeria

Four vehicles were involved in collision on Kutigi-Mokwa road after one, an overloaded bus speeding to a market, collided with a truck, possibly tanker; fire broke out, killing nine people, injuring 11 more

NAN

8/11/21 Sagamu, road tanker LPG

Ogun, Nigeria

Fire broke out in LPG tanker on Lagos-Ibadan highway, cause unknown; tanker then exploded; three people in cab were injured; police put diversion in place to prevent further accidents during response

The Eagle

10/11/21 Barmer, road tanker

Rajasthan, India

At least 12 people died, others injured when fire broke out after collision between tanker and bus on Barmer- Jodhpur highway; cause of accident not clear; bus said to be carrying 25 at the time

India TV News

11/11/21 Ode-Aye, bus ethanol

Ondo, Nigeria

Two buses collided due to reckless overtaking; one bus was carrying large amount of ethanol, which caught fire; six people on the bus were burned to death, several others badly injured and were rushed to hospital

Vanguard

15/11/21 nr Del Rio, road tanker jet fuel

Texas, US

Train clipped rear of Outlaw Transportation tank truck with jet fuel for Laughlin AFB, causing leak and major fire; truck driver suffered minor injury; base’s fire crews helped with response

The 830 Times

18/11/21 Ibadan, road tanker gasoline

Oyo, Nigeria

Fire broke out in engine of tanker; driver jumped out while vehicle was still moving; tanker crashed, spilling gasoline to road before exploding; two passing cars burned; several people injured in fire but no fatalities

Premium Times

24/11/21 Bahawalpur, road tanker oil

Punjab, Pakistan

Road tanker with 50,000 litres unspecified oil caught fire after tyre burst due to speeding on Khanqah bypass; tanker was heading from Karachi to Sheikhopura; fire crews attended, police closed road; no injuries reported

Urdu Point

28/11/21 Sorek, truck

Israel

Truck carrying unspecified hazardous materials overturned after accident at Sorek interchange; driver was trapped in cab, freed after two hours; vehicle’s load said to have been pumped off, suggesting it was liquid

Jerusalem Post

Road tanker overturned on poor road surface, spilling gasoline cargo; subsequent explosion blamed on ‘hoodlums’ who had collected spilling fuel, looted nearby shops, attacked responders; two people killed

Punch

sodium cyanide

sulphuric acid

hazardous materials

29/11/21 Lafenwa, road tanker gasoline

Ogun, Nigeria

MARINE/INLAND WATERWAY INCIDENTS Date Location

Vessel

Substance Details

Source

flammable corrosive

Containership lost 40 containers in heavy swells in Straits of Juan de Fuca, anchored off Victoria; fire broke out next day in two damaged boxes on board containing potassium amylxanthanate; fire spread to other boxes

Maritime Executive

25/10/21 off Isle of Wight, Chem Alya unknown

UK

Product/chemical tanker (17,000 dwt, 2009), leaving Fawley for Alexandria, veered off fairway and grounded; presumably in cargo but no damage reported

FleetMon

27/10/21 Durban, NS Qingdao chemicals

KZN, South Africa

Bulk carrier, discharging unspecified bulk chemical cargo in rainy weather, had to be removed from berth due to toxic fumes; vessel sailed around cape for St Helena Bay, where cargo was neutralised, offloaded

FleetMon

8/11/21 Brunsbüttel, Mostraum unknown

SH, Germany

Product tanker (10,500 dwt, 2019) en route Kokkola struck dolphin on approach to Kiel Canal, was holed above waterline in way of port cofferdam; berthed in Brunsbüttel for repair; not clear if it was in cargo at time

FleetMon

22/10/21 off Vancouver Island,Zim

BC, Canada Kingston

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SAFETY

37

MISCELLANEOUS INCIDENTS Date

Location

Plant type

Substance

Details

Source

gunpowder factory

gunpowder

Seven people killed, nine missing and presumed dead after explosion at Elastik factory; massive response to resulting fire; officials suspect violation of safety procedures or short circuit as cause of blast

AP

29/10/21 North Nazimabad, filling Sindh, Pakistan station

gasoline

Four people were killed, six injured by explosion in electric room of ‘petrol pump’, possibly due to leak from gas cylinder or ignition of fugitive gasoline fumes; bomb squad also investigating

SAMAA

31/10/21 Puebla, Puebla, Mexico

pipeline

natural gas

Series of explosions, possibly resulting from illegal tap on gas line, killed one, injured 11, damaged dozens of homes and caused evacuation of some 2,000 people; fires were later put out by heavy rain

AP

5/11/21 Abuja, FCT, Nigeria

market

kerosene

Explosion in tank with kerosene (possibly adulterated) at Kubwa Village Market killed five, injured scores; spark from transformer thought to have ignited vapours; authorities planning crackdown on illegal operators

The Eagle

7/11/21 El Carmen, El Salvador

house

fireworks

Five people were killed by explosion in home being used as an informal (and illegal) workshop for making fireworks; those killed lived in the property; such incidents are not uncommon at this time of year

AFP

8/11/21 Point Lisas, Trinidad

printing supply company

solvents

Fire broke out at Gemini Inks in eTecK industrial park, possibly in store with chemical solvents; fire crews managed to prevent blaze from spreading to other solvent tanks, chemical plants and units using natural gas

Petroleum World

10/11/21 nr Karaj, Alborz, Iran

LPG filling workshop

LPG

Series of explosions at unauthorised LPG cylinder filling plant west of Tehran; fire crews brought blaze under control in half an hour, removed 60 cylinders outside to cool them; cause not known

Xinhua

13/11/21 Cilacap, C Java, Indonesia

oil refinery

gasoline

Fire broke out in gasoline storage tank at Pertamina refinery; cause not known; nearby residents evacuated; Pertamina crews battled fire; no casualties reported

AP

13/11/21 Kruger Nat’l Park, filling South Africa station

fuel

Lightning strike sparked fire at filling station at Lower Sabie, which was destroyed; fire was contained on the site; visitors advised to get fuel at other sites on or off the Kruger National Park

The South African

18/11/21 Coniston, Ontario, Canada

container

Explosion blew hole in shipping container at industrial park in Greater Sudbury; not clear what exactly happened but residents reported strong smell of chlorine after the explosion; no threat to the public

CBC

22/10/21 Ryazan, Russia

industrial park

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38

IN THE KNOW COMPLIANCE • EXIS TECHNOLOGIES CONTINUES TO PLAY AN IMPORTANT ROLE IN ENSURING SAFETY IN THE MOVEMENT OF CONTAINERISED DANGEROUS GOODS AND SEES MORE WORK AHEAD WHEN THE ROOTS of containerisation began back in 1956, spearheaded by American entrepreneur Malcom McLean looking for a way to get his trucking company’s entire cargo loaded onto a shipping vessel as quickly and efficiently as possible, it would have been hard to expect that by 2022 container shipping would be transporting around 90 per cent of the world’s non-bulk cargo – of which some 10 per cent is recognised as dangerous goods.

In 2022 Exis Technologies celebrates 35 years supplying IT solutions for the management of these dangerous goods in sea transport, helping shippers, consignors, forwarders and shipping lines to comply with the regulatory requirements.

Early, paper-based, methods of shipping dangerous goods were time-consuming and relied on many people in the process understanding the cargo and its handling requirements. There could be catastrophic consequences to getting the answers wrong

to important questions like: Which goods are actually classified as dangerous goods?

Can they be shipped together safely in a container? What packaging do they need? and Where should they be stowed in the ship?

When Exis began in 1987, the International Maritime Dangerous Goods (IMDG) Code, produced by the International Maritime Organisation (IMO), existed only in book format and the widespread use of digital solutions was not prevalent in the shipping industry. After the first digital dangerous goods list database was developed by programmers at Exis, basic look-up tools for international multimodal regulations followed to speed up the booking process.

By the 1990s Exis had its own digital solutions with the ability to find the correct UN numbers or proper shipping name, perform packaging and segregation/stowage checks and produce documentation that could be used in the transport chain. Exis continued

to innovate and by 2010 Hazcheck Validation Systems had been implemented by nine of the top 10 container lines. In parallel, Exis’ IMDG Code e-learning training tool was also launched in line with IMO’s new mandatory IMDG Code training guidelines.

INTRODUCING DIGITAL Digital solutions produced by Exis have allowed businesses to keep pace with the advances in container shipping. When Exis was formed in 1987, the largest container ships, restricted in size by the Panama Canal, carried around 4,600 TEU, now ultra-large ships with capacity of almost 24,000 TEU can be regularly spotted at terminals. In 1980, 102m tonnes of cargo was being carried by container ships globally. By 2017, this figure had jumped to 1.8m million tonnes, an increase of nearly 1,700 per cent.

Exis does not stand still, seeking out new collaborations and driving through initiatives to help with continued safety improvements in containerisation. In 2011 the Cargo Incident Notification System (CINS) was launched, a major industry collaboration involving five of the top container lines to analyse global operational information on all cargo- and container-related accidents. It now has 17 shipping line members, representing more than 85 per cent of the world’s container slot capacity. Exis, now a CINS advisory member, developed the CINSnet database that drives the CINS initiative.

Exis also contributed to a new industryaccepted safety system for the stowage of dangerous goods on containerships, prepared

by CINS and led by Maersk, following the fire on Maersk Honam. Exis Technologies was part of the working group and gave input focused around its detailed knowledge of the IMDG Code Dangerous Goods List, stowage requirements and categorising specific UN numbers into risk zones. Hazcheck Risk Zone data, comprising UN number, packing group and risk zones, is now available as a free resource to the container shipping industry.

BREAKING AMERICA In 2018 Exis became part of New York-based container/vessel cargo surveying and inspection company National Cargo Bureau

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SAFETY 39

(NCB) with the joint mission of Safety of Life and Cargo at Sea. NCB’s Dangerous Goods White Paper, launched in 2020, addresses the need to look at how the industry can join together to implement a robust approach to dangerous goods shipping and to avoid the carriage of undeclared and mis-declared dangerous goods. Statistics from the TT Club suggest that, on average, a containership is involved in a major fire every 60 days.

This isn’t being helped by the fact that cargo is deliberately declared incorrectly to save cost or time. Larger vessels are most affected, as some ships carry more than 1,000 containers with dangerous goods on any given voyage.

NCB and Exis have been working on ground-breaking new tools over the past four years to help with the dilemmas that containerisation can bring. Hazcheck Detect, the API-based cargo screening solution launched in 2020 is already in use with a number of large container lines. It scans all booking details for keywords and creates an industry library to enable suspicious bookings to be identified that may be mis-declared or undeclared dangerous goods. Cargo screening allows non-compliant cargo to be detected within seconds rather than days.

Last-minute changes to bookings, declarations, Bills of Lading and shipping instructions can be picked up in real time.

This immediate response avoids such cargo from being loaded onto a ship, thereby avoiding the risk of fires at sea.

NEXT ON THE LIST As the shipment of dangerous goods is complex, Blockchain may be a good way to increase safety in the maritime sector. A key proposition for using Blockchain is digital traceability of dangerous goods through the supply chain, increasing security and transparency. In 2018 Exis took part in the misdeclaration of dangerous goods blockchain project, Maritime Blockchain

 CONTAINERISATION HAS COME A LONG WAY IN THE PAST 50 YEARS AND FOR 35 OF THOSE YEARS EXIS TECHNOLOGIES HAS BEEN HELPING SHIPPERS AND CARRIERS COMPLY WITH COMPLEX REGULATIONS

Labs, led by Bloc with the support of Lloyd’s Register Foundation. There are still challenges to be addressed with the use of Blockchain, but if players in the supply chain are willing and able to share their data in the future it could play a big part in the safety of containerised shipments, digitising diverse dangerous goods documentation, automating transmission and updating information.

rejections per month.

The Hazcheck Inspections used by NCB in its container inspection database provide more than 100,000 data records, constantly growing. Hazcheck Detect is screening more than 15 million shipments per month. These data sets along with machine learning and AI techniques will be able to help improve the detection of invalid and dangerous shipments

Exis can now collect large amounts of data from all its Hazcheck tools. In 2021, the Hazcheck tools for declared dangerous goods were performing more than 400,000 validations per month, representing 82 per cent of the world’s containerised dangerous goods traffic, and picking up around 4,000

by creating new rules and search terms.

In 2022 Exis is looking forward to another year of delivering advancements in industry solutions because there is no standing still in the ever-changing and ever-expanding world of containerisation. existec.com

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40 SAFETY

the future by reducing harm from incidents globally. This partnership is a clear indication of how NCEC’s advice-focused approach to emergency response is valued within the market. We are all looking forward to getting started.”

services through its existing best-in-class network. On-site expert advice (Level 2) and on-ground response (Level 3) services will be provided by Ouray.

“Ouray is extremely excited about offering these combined services to the marketplace,” says Aaron Montgomery, president/CEO of Ouray. “This Ouray/NCEC partnership will allow our organisations to be the first in the world to provide combined Level 1, 2 and 3 services. This signifies a large step forward in Ouray’s mission to be a complete turn-key solution to the global chemical supply chain.”

“It is a great opportunity for NCEC/Ouray

OUR MAN IN SINGAPORE Ouray’s APAC Emergency Response Initiative is being put together with contributions from some of the company’s existing clients that have operations in the region, most notably Chemours, which is putting its cache of highly specialised transfer and response equipment at Ouray’s disposal. Ouray is also bringing in equipment needed for full and comprehensive emergency response up to level A personal protective equipment for incidents involving toxic-by-inhalation products.

The aim of the project is to give Ouray’s clients access to top-of-the-range response equipment and services at a reasonable cost, as the fixed costs of the project are shared among all the subscribers. As a result of the partnership with NCEC, that also includes telephone access to an experienced responder through a Singapore phone number, allowing Ouray to understand the conditions at the scene, the help that is needed and getting on-the-ground responders prepared ahead of their arrival.

Ouray is experienced in dealing with all types of chemical incident, including leaks from packagings, tanks and tanker vessels, involving all classes of product. Its subscription approach also gives its clients access to additional services, including hazardous materials training, safety and response preparedness audits, and other consultancy services.

Ouray has installed John West, one of its lead managers from its Denver office in Colorado, to head up the Singapore operation. As a licensed professional engineer and certified hazardous materials manager with more than 20 years’

to support customers with best-in-class emergency response services within the Americas and Asia-Pacific region. We are excited to be working with Ouray,” adds Jon Gibbard, director of NCEC. “This holistic approach to emergency response further supports our vision to create a world fit for

experience in the field, he has developed the ability to quickly determine appropriate objectives for assessment sites and implement proper procedures to ensure safe operations and quality information for decision making. the-ncec.com www.ourayservices.com

ONE IN THREE RESPONSE • THE LAST PIECE OF OURAY’S ASIA-PACIFIC RESPONSE JIGSAW HAS FALLEN INTO PLACE, WITH A PARTNERSHIP WITH NCEC TO PROVIDE LEVEL 1 TELEPHONE RESPONSE OURAY ENVIRONMENTAL SERVICES has struck a partnership with the National Chemical Emergency Centre (NCEC) to provide Level 1 emergency response services, with a focus on the Americas and Asia-Pacific regions. The latter will help support Ouray’s APAC Emergency Response Initiative, opening this month in Singapore and designed to provide an integrated chemical response service for the whole of the Asia-Pacific region.

Under the distributor agreement signed between the two parties, NCEC will provide telephone emergency response (Level 1)

 OURAY’S APAC EMERGENCY RESPONSE SERVICE WILL NOW BE ABLE TO OFFER A COMPLETE SET OF ADVICE AND ON-THE-GROUND RESPONSE TO CHEMICAL INCIDENTS ACROSS THE REGION

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SECTION SLUG

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42

local in nature, with relatively light or even non-existent oversight by enforcement agencies.

In the event of an accident, investigations are seldom made public, as they too are often the responsibility of a local agency. According to those involved in the containerised chain, though, a common cause of incidents in warehouses is incorrect handling and storage, including improper or ineffective segregation, as well as issues relating to the prolonged storage of material that can affect its stability.

Both of these factors were at play in the Tianjin and Beirut disasters, with too much ammonium nitrate being stored for too long in a facility that also contained material with the potential to initiate a major explosion.

When such accidents happen, those involved in the transport chain, including the container lines and freight forwarders, are often called in to help handle the response and to provide subject matter expertise on the dangerous goods involved. It has become clear to industry that there is a need for more guidance on dangerous goods warehousing in port areas, despite the plethora of existing regulation and standards.

THERE HAS BEEN an increase in the number of incidents involving containerised dangerous goods at sea in recent years, as the pages of HCB have frequently reported. At the same time, though, there has been a similar level of

concerned that any of the many other smaller incidents taking place around the world could have a similarly catastrophic outcome if rules and procedures are not followed.

There is, though, a problem. The transport

GET IT TOGETHER In response to that need, four industry organisations have developed a guidance document. The Dangerous Goods Warehousing White Paper is co-authored by the International Cargo Handling Coordination Association (ICHCA), the International Vessel Owners Dangerous Goods Association (IVODGA), the National Cargo Bureau (NCB) and the World Shipping Council (WSC). The contents of the white paper have been shared with relevant maritime regulators and the International Maritime Organisation (IMO) with an invitation to consider including the white paper and associated checklist in its various instruments, codes and circulars, as appropriate.

occurrences on shore in warehouses, especially in port areas, where dangerous goods are prepared for or stored after sea transport. Some of these incidents, such as those in Tianjin in 2015 and in Beirut in 2020, have hit the headlines but, as ever, these are only the tip of the iceberg. Industry is

of dangerous goods, whether packaged or in bulk, is well regulated, with consistent rules in place around the globe and, to a large extent, across transport modes. The storage of packaged dangerous goods in warehouses, on the other hand, is not subject to a consistent set of rules; such regulation as exists is often

IMO revised its Safe Transport of Dangerous Cargoes and Related Activities in Port Areas (MSC.1/Circ.1216) in 2007 but, the authors say, while this does contain valuable advice and recommendations, it is very much a ‘highlevel’ document. In contrast, the white paper contains practical guidance on the systematic

FIXING A HOLE WAREHOUSING • INDUSTRY IS LOOKING TO PLUG A GAP IN THE SAFE TRANSPORT OF DANGEROUS GOODS WITH GUIDANCE ON DEALING WITH THE HAZARDS THAT EXIST IN INTERMEDIATE STORAGE

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SAFETY 43

and documented management of dangerous goods in warehouses.

The value of the white paper has been recognised by endorsement from a range of influential industry representatives, including the Baltic and International Maritime Council (BIMCO), the Bureau International des Containers (BIC), the Container Owners Association (COA), the Council on Safe Transportation of Hazardous Articles (COSTHA), Danish Shipping, the International Chamber of Shipping (ICS), the International Federation of Freight Forwarders Association (FIATA), the International Group of P&I Clubs (IGP&I) and the TT Club.

MEETING A NEED Explaining the need for the white paper, Uffe Ernst-Frederiksen and Ken Rohlmann, both representing IVODGA, say: “The temporary or long-term storage of dangerous goods in a facility necessitates careful planning, supervision and continued due diligence.

While the major disasters in Beirut and Tianjin

 THE DEVASTATING EXPLOSION IN BEIRUT IN 2020 WAS A DIRECT RESULT OF POOR WAREHOUSING PRACTICE, WITH TOO MUCH AMMONIUM NITRATE STORED FOR TOO LONG IN A BUILDING WITH FIREWORKS AND OTHER FLAMMABLE MATERIALS

have been widely reported, there are many other incidents around the globe that do not garner the same attention, but which have the potential to escalate. There are existing international, national and local regulations for dangerous goods in transit for various modes of transport but there is no direct equivalent for warehouses.”

Furthermore, in any transport chain there will be a range of dutyholders, each subject to the appropriate regulations and standards, which impose specific obligations and requirements. Each dutyholder has to rely on the level of compliance shown by the preceding player in the chain and the goal of ensuring end-to-end safety can be compromised if any one dutyholder fails to fulfil its obligations. Intermediate storage along the supply chain, not subject to the same detail of regulation, therefore represents a weak link in the chain.

The Dangerous Goods Warehousing White Paper and its accompanying Checklist detail the risks involved in storing and handling dangerous goods and, importantly, the measures to be taken to contain those risks.

Topics covered include: competency and training of workforces; property construction; fire protection; security equipment and protocols; and emergency response procedures. It is intended as a practical guide to systematic and documentable processes

for those managing and operating storage facilities to ensure ongoing safety but also that incidents are containable if and when they arise.

“A pivotal element of our guidance is a Warehouse Checklist,” adds Richard Steele of ICHCA. “Given our aim to provide a practical management tool, we believe the Checklist format is a significant addition to the other elements of the white paper. Broken down into eight key functional areas of operation, this comprehensive 14-page Checklist is designed as both a planning guideline and a review tool, as well as an everyday device for maintaining safety management vigilance.”

LIMITS OF THE POSSIBLE The white paper notes that there are many factors that can affect the safe and secure storage of dangerous goods in storage facilities and warehouses. Those include adherence to applicable standards, workforce integrity (especially in terms of effective training), the construction and protection of warehouses (i.e. using non-combustible materials and having effective security controls in place), operational controls, storage conditions, and emergency response and preparedness.

The authors recognise that the white paper cannot address all circumstances and they note that applicable regulations and standards will always take precedence. However, the white paper and its associated checklist do offer a good place to start when considering safety in warehouse storage, whether in port areas or elsewhere.

The white paper also offers a selected list of links to existing standards and guidance documents, including legal provisions in place in the EU, the US, Ireland, the UK, Belgium and Australia, International Standardisation Organisation (ISO) standards, guidance from a number of trade associations and references to press reports on significant incidents.

The white paper and its associated checklist can be downloaded free of charge from the websites of the bodies involved. www.ichca.com www.ivodga.com www.natcargo.org www.worldshipping.org

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EV AT SEA BATTERIES • RAPID GROWTH IN THE USE OF ELECTRIC VEHICLES IS RAISING NEW SAFETY CONCERNS, PARTICULARLY DURING THEIR TRANSPORT BY SEA, AS THE UK P&I CLUB HIGHLIGHTS IT IS QUITE LIKELY that anyone reading HCB knows that lithium cells and batteries – both lithium ion and lithium metal – are treated as dangerous goods for transport purposes.

That goes equally for those contained in equipment (or packed with equipment) and for the batteries shipped alone. There have been numerous fires involving lithium batteries being transported by all modes, which are of particular concern in the aviation sector but are also a problem for maritime and road transport.

The recent rapid growth in the manufacture and use of electric vehicles has added to the list of hazards, during the transport of new

vehicles from production plants as well as during the return of damaged or defective batteries, not least since the batteries are generally quite large. However, as yet the amount of realistic data about the potential fire risk of electric vehicles is limited. To try and gather more information, the UK Maritime & Coastguard Agency (MCA) issued a consultation document this past October on a draft Marine Guidance Note (MGN 653(M)) on the transport of electric vehicles on passenger ro-ro (ro-pax) ferries; but the problem also presents itself in the specialised car carrier market.

The UK P&I Club is also trying to raise

awareness of the potential hazards, since it realises that regulations can be slow to respond to rapid changes in the nature of the shipping market and emerging hazards; the Club says the onus will be on the maritime industry to develop new operating procedures and on crews to use those procedures to mitigate the risks. Many vessel operators are already taking a cautious approach to the carriage of electric vehicles and those powered by alternative fuels.

A RANGE OF RISK It is not that electric vehicles are inherently unsafe; does a car with a large battery represent more of a risk than a car with a tank full of flammable liquid? The UK P&I Club says, though, that new technology always carries with it the potential for unintended consequences and it is important for every stakeholder to understand the risks to mitigate them effectively. There are also different types of new technology: there are ‘pure’ electric vehicles (EVs) that are fitted with rechargeable batteries and have to be charged from an external power source; plug-in hybrid electric vehicles (PHEVs) have a smaller battery but also a conventional engine powered by gasoline or diesel; and hydrogen fuel cell electric vehicles have no battery, instead generating power from hydrogen.

In recent years, the technology applied to electric vehicles has advanced remarkably quickly and will likely continue to do so, in a search for longer driving range and smaller batteries. This creates challenges in terms of battery manufacturing quality, the Club states.

The main hazard posed by a rechargeable lithium battery is that, if it catches fire, it can result in temperatures of 1,000°C or more; it can also release toxic gases. Such a fire on the cargo deck of a ro-ro vessel or on a car carrier could spread rapidly, posing risks to the vessel, the crew and the environment.

Such a fire could be initiated by the battery itself, either due to damage or faulty charging, leading to thermal runaway; a fire might start elsewhere and spread to the battery; or in the case of a fuel cell, there could be an explosion due to the release of hydrogen resulting from damage or fire engulfment.

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SAFETY 45

The UK P&I Club notes that the safety of charging electric vehicles aboard ships has not been widely discussed but, as it is an area on which MCA is currently consulting, if clearly needs to be considered.

WHAT’S TO BE DONE Pending the introduction of specific regulation or industry standards, the UK P&I Club has offered some ideas for operational changes that could be made to minimise the risks involved in the transport of electric vehicles aboard ships. It is important that the crew understand the risks the vehicles present and be provided with appropriate personal protective equipment. It is also important for the crew to know where such vehicles are located; they should be clearly marked on the stowage plan so that, in the event of an incident, emergency responders can act appropriately. Training and equipment for rescue workers may need to be adapted, the Club suggests.

Existing sprinkler systems are unlikely to be effective against a fire involving an electric vehicle; these fire suppression systems typically shower water from the deckhead down, whereas batteries are usually located close to the floor of the car. High pressure water mist systems seem to be particularly suitable due to their inerting and cooling effect, so these systems are preferable for battery fires. Furthermore, cooling a battery on fire requires large quantities of water.

Thus, to avoid endangering the stability of the ship, it is important to ensure that extinguishing water can run off unhindered, while keeping it free from burnt material and cargo.

Watch-keeping and fire rounds are essential to keep a close eye on damaged cars, coolant leakages, indications of heat, and venting.

Use of thermal imaging scanners by the cargo watch-keepers is suggested, and some vessels are provided with CCTV cameras for

 WHILE THE TRANSPORT OF NEW AND USED CARS BY SEA IS AN ESTABLISHED BUSINESS, THE EMERGENCE OF BATTERY-POWERED VEHICLES RAISES NEW CONCERNS, NOT YET FULLY UNDERSTOOD

monitoring which can lead to early detection.

A quick muster, decision making, and effective teamwork can ensure a fire is under control quickly before it spreads. Electric vehicles should be transported in special areas equipped with appropriate gas and fire detectors, fire extinguishing equipment and fire extinguishing agents. In the case of a fire, the possibility of separating vehicles by means of a water wall or mobile partitions could be explored.

There are particular hazards relating to fuel cell vehicles. The escape of hydrogen on a closed or even semi-open deck can easily

remember that hydrogen is much lighter than air and, if released, will collect under the deckhead; current explosion protection provisions concentrate on gases that are heavier than air.

According to the UK P&I Club, there are several areas where further investigation is warranted: for instance, what is the ideal state of charge for a battery vehicle being transported; and what is the effectiveness of different combinations of fire detection, gas detection and firefighting installations.

As more reliable data emerges, the Club says, more concrete ideas for operational changes

lead to an explosive atmosphere and the Club recommends that such cars be transported only on open loading decks. Furthermore, areas where hydrogen could escape must not be protected by a CO2-based fire suppression system, as the CO2 being discharged may ignite hydrogen. It is also important to

may also be developed. However, it warns, existing ro-ro vessels are unlikely to undergo any significant design changes in terms of fire detection or firefighting capability, so operators will need to concentrate on adapting their procedures. www.ukpandi.com

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IGNITION KEY INCIDENT REPORT • NTSB HAS CALLED ON PHMSA TO LOOK MORE CLOSELY AT THE TRANSPORT OF USED VEHICLES FOLLOWING ITS INVESTIGATION OF A FIRE ABOARD A CAR CARRIER IN 2020 AN ELECTRICAL FAULT from an improperly disconnected battery in a used vehicle led to the fire aboard the vehicle carrier Höegh Xiamen in June 2020, resulting in $40m worth of damages, the US National Transportation Safety Board (NTSB) has said. The fire took hold after the vehicles were loaded aboard the vessel in Jacksonville, Florida; nine firefighters were injured in the fire, which took more than a week to extinguish. The vessel itself and its cargo of 2,420 used vehicles were declared a total loss. The ship was subsequently towed to Turkey for demolition.

Following its investigation, NTSB concluded that many of the vehicles loaded onto the vessel had batteries that were not disconnected and secured in accordance with procedures, which increased the risk of electrical arcing and component faults. During loading operations, both the loading personnel and crew missed opportunities to address these hazards.

The investigation also showed that the detection of the fire was delayed because the vessel’s fire detection systems had not yet been reactivated after loading was completed.

Additionally, the Jacksonville Fire and Rescue Department’s response to the accident was delayed because the Höegh Xiamen’s master did not immediately have available contact information for search and rescue authorities and did not know how to report a fire to local authorities.

NTSB determined that the probable cause of the fire was a lack of effective oversight of longshoremen by Grimaldi Deep Sea, charterer of the vessel, and SSA Atlantic, its stevedoring contractor. This failed to ensure that Grimaldi’s

HCB MONTHLY | JANUARY 2022

vehicle battery securement procedures were being followed. Further, the crew delayed reactivating the vessel’s fire detection system after the completion of loading. Contributing to the extent of the fire was the master’s decision to delay the release of the carbon dioxide fixed fire extinguishing system.

WHAT’S TO BE DONE In the wake of its investigation, NTSB has recommended that the Pipeline and Hazardous Materials Safety Administration (PHMSA) look at the current regulations for the transport of vehicles. “The transportation of used vehicles, such as those that were loaded on vessels like the Höegh Xiamen, is currently excepted from Hazardous Materials Regulations when a vessel has a stowage area specifically

designed and approved for carrying vehicles,” NTSB said in its report. “We found that used vehicles are often damaged and present an elevated risk of fire. We believe that greater inspection, oversight, and enforcement are needed to reduce this risk.”

NTSB notes that there have been five similar incidents since 2015, including a fire in 2019 aboard Grimaldi’s Grande Europa. On the basis of its experience, Grimaldi developed a battery disconnect procedure to reduce the risk of vehicle fires during transport. This procedure was used on Höegh Xiamen; however, the Coast Guard’s post-accident examination of a sample of 59 vehicles did not find a single battery that was secured in accordance with that procedure.

“The circumstances of this accident make clear that it is critical to ensure that the batteries of used vehicles are disconnected and properly secured during cargo loading operations,” the report says. “NTSB believes it is imperative that operators of similar roll-on/ roll-off vessels engaged in the transportation of used vehicles act to ensure that any personnel involved in loading operations – including vessel crews, stevedores, and longshoremen - be aware of the importance of disconnecting batteries on used vehicles.”

The full NTSB report can be downloaded at www.ntsb.gov/investigations/AccidentReports/ Reports/MAR2104.pdf.

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QUICK AND CLEAN ULTRASONICS • GETTING FAST AND ACCURATE THICKNESS MEASUREMENTS IS GETTING EASIER AND, THANKS TO CYGNUS INSTRUMENTS, SAFER IN HAZARDOUS ENVIRONMENTS ADVANCES IN TECHNOLOGY over the past decades have offered facility operators greater choice in equipment that promises to make their lives easier and their activities more efficient. For those operating in the highhazard sectors, however, there is the added complication of needing to have equipment that is capable of working safely in potentially flammable or explosive atmospheres.

This often restricts the choice of available equipment or, in some cases, actively prevents their adoption.

Ultrasonic thickness gauges are a case in point. Indeed, UK-based Cygnus Instruments says its Cygnus 1 Intrinsically Safe gauge is the only one of its kind in the world to be certified for use in Class 1, Division 1 (‘Zone 0’) areas under ATEX, IECEx and CSA-US. Like all Cygnus gauges, the Cygnus 1 employs the Multiple-Echo technique to read through coatings and gives an accurate measurement of the remaining metal thickness, guaranteeing crucial savings in time and money as it eliminates the need to remove and reapply coatings. It also avoids the risk of exposing the material under test to further corrosion. This has proved significant in the oil and gas and marine industries as pipelines and marine structures, found both on land and underwater, are usually coated and can suffer from internal corrosion, leading to costly leaks and emergency repair work. This can easily be prevented with routine thickness gauging checks.

BUILT TO BE TOUGH As well as being intrinsically safe, Cygnus 1 is extremely rugged and specifically designed for measuring metal thickness to determine

HCB MONTHLY | JANUARY 2022

wastage or corrosion in Zone 0, Zone 1 hazardous and potentially explosive environments. Boasting a highly durable, shock-proof and splash-proof (IP65 rated) construction, this heavy-duty unit is supplied ready to use, and offers up to 12 hours continuous testing before recharge is necessary, with no plant shutdown or hot work permit required.

The virtually indestructible exterior houses a large set of components, viewed via a bright LED display with polarised filter, in either

metric or imperial measurement to suit the user’s preference. Its features include an echo strength indicator to aid measurement, measurement self-verification to ensure maximum accuracy, stable calibration linear accuracy, no zero adjustment and sound velocity settings. The gauge can also be used with a range of varied frequency probes or a right-angle probe – more practical for reaching areas with restricted access.

This accuracy and ease of use makes the Cygnus 1 a popular choice. As one customer says: “There are many in the industry who have been using Cygnus meters for more than 20 years. I myself have used their underwater thickness gauge along with regular and Intrinsically Safe UT meters from the early stages of my career – and that goes back to more than 25 years for sure. As a global leader of inspection services, we use Cygnus Gauges for pipelines, tanks and vessel inspections. Our operators particularly love Cygnus – as readings come quick and accurate.” cygnus-instruments.com

SAFETY 49

NEWS BULLETIN

SAFETY

HELP WITH BATTERY RETURNS

Labelmaster has introduced a ‘Recall Ready Program’ for large-format lithium batteries, designed to simplify the recall process by providing manufacturers and distributors of such batteries with a comprehensive return logistics solution that includes regulatory guidance, custom packaging, customer service, e-commerce platforms and training.

“Recalls are unplanned and challenging events that companies across the supply chain are typically not ready for and for which they often make mistakes that cost time and money and put them at risk,” says Pia Jala, vicepresident of Labelmaster. “Recalls are especially difficult when they involve large-format lithium ion batteries, such as those found in electric vehicles, because they are big and heavy and fully regulated hazmat, so they cannot be put into a normal box and shipped like other goods.

Our turnkey solution combines deep DG supply chain knowledge with a proven packaging system that’s being used to transport recalled batteries worldwide.” www.labelmaster.com ESSO ADMITS LPG LEAK

Esso Petroleum has been fined £500,000 for breaches of Regulation 5(1) of the Control of Major Accident Hazard (COMAH) Regulations, following the uncontrolled release of some 15 tonnes of LPG from a valve at its Fawley refinery in Hampshire, UK in November 2015. According to the UK Health & Safety Executive (HSE), which inspected the incident, the leak went undetected for around four hours before being spotted by an employee cycling home. The leak was close to a main road used by road tankers visiting the refinery.

HSE found that the leak occurred because LPG was put through piping at a pressure too high for the valve to cope with, and there was no process in place to detect the discrepancy in the flow. Esso Petroleum pleaded guilty to the charges.

HSE inspector Jonathan Halewood said after the hearing: “Where companies handle large quantities of substances that can cause major incidents, such as LPG, they are required to have layers of protection in place to prevent incidents. In this incident a number of those layers either failed or were not in place, resulting in a significant leak. Even though there was no fire or injury on this occasion, there was potential for a major incident.” www.hse.gov.uk

was partly due to the provision of “deficient” dredging plans. More detailed documents would likely have identified the risk and the pipeline’s operator, Enterprise Products, could have instigated protection protocols.

NTSB has called on industry bodies and federal regulators to improve guidance and training on pipeline protection during dredging operations, and for more coordination between dredger operators and pipeline companies. www.ntsb.gov NEW BOSS FOR CHEMTREC

BEWARE OF PIPELINES

The US National Transportation Safety Board (NTSB) has issued recommendations following its investigation of the fire and explosion aboard the cutter dredger Waymon Boyd in Corpus Christi in August 2020 after it cut through an underwater propane pipeline, resulting in the deaths of five crew. The vessel was engulfed in the spreading cloud of propane following the breach, and NTSB investigators concluded that this vapour would have been drawn into the vessel’s engine room, where it was ignited.

NTSB found that the probable cause of the incident was inadequate planning and risk management by the vessel’s operator, Orion Marine, which failed to identify the proximity of the dredging operation to the pipeline; this

Chemtrec has appointed William Erny, formerly senior director of the American Chemistry Council (ACC), to lead its regulatory and strategic alliance initiatives.

As directory of regulatory affairs and strategic alliances, Erny will now aim to bolster work already underway, further strengthening relationships with government partners, chemical manufacturers and distributors, and advising on best practices and safety policy and protocols.

Bruce Samuelsen, Chemtrec’s chief executive, says Erny’s appointment is not only strengthening its position as the go-to chemical emergency service provider but enabling the industry to become even safer: “With William joining our team, we now have an incredible resource in his skillset and experience engaging senior government officials as well as industry leaders. As a key policy influencer in his past roles with the ACC and the American Petroleum Institute (API), he will be able to advance and further develop our products and services to enable the industry to become safer.”

“Chemtrec is already leading the field when it comes to managing hazmat incident response practices,” Erny says. “I’m looking forward to building on this work to enhance chemical safety and regulatory compliance within the industry as well as offering class-leading advice for clients worldwide.” www.chemtrec.com

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DEVIL IN THE DETAIL MULTIMODAL • IT IS NOT A STRAIGHTFORWARD TASK TO ALIGN RID/ADR/ADN WITH THE UN MODEL REGULATIONS AND THERE WILL BE A LOT OF CHANGES TO MAKE IN THE 2023 EDITIONS THE AD HOC WORKING GROUP on the Harmonisation of RID/ADR/ADN with the UN Recommendations on the Transport of Dangerous Goods met this past April under the chairmanship of Claude Pfauvadel (France), with the intent of reviewing those amendments included in the 21st revised edition of the UN Model Regulations and preparing them for inclusion in the 2023 editions of RID, ADR and ADN. A report on that meeting was provided to the Joint Meeting of RID/ADR/ADN Experts

amendments were largely adopted, with some editorial changes. Those amendments remain to be confirmed by the modal authorities.

This summary of the accepted changes is not exhaustive and excludes those of a purely editorial nature. Dutyholders under the three sets of regulations will, of course, be expected to take a close look at the new editions once they are available.

HCB will include a report on the rest of the work of the autumn session of the Joint

held in September where the proposed

Meeting in the next issue.

 THERE ARE MANY CHANGES RELATING TO THE USE OF TRANSPORTABLE PRESSURE RECEPTACLES IN THE 2023 TEXTS

HCB MONTHLY | JANAUARY 2022

PART 1 In 1.2.1, in the definition for ‘Bundle of cylinders’, “an assembly of cylinders” is replaced by “a pressure receptacle comprising an assembly of cylinders or cylinder shells”.

A new note is added under the definition of ‘Closure’: NOTE: For pressure receptacles, closures are, for example, valves, pressure relief devices, pressure gauges or level indicators.

The definition of ‘Cryogenic receptacle’ is amended to read: Closed cryogenic receptacle means a thermally insulated pressure receptacle for refrigerated liquefied gases of a water capacity of not more than 1 000 litres; In the definitions for ‘Cylinder’, ‘Pressure drum’ and ‘Tube’, the word “transportable” is deleted.

In the definition for ‘Metal hydride storage system’, “receptacle” is replaced by “pressure receptacle shell”.

In the definition for ‘Pressure receptacle’, after “Pressure receptacle”, the following new text is added: “means a transportable receptacle intended for holding substances under pressure including its closure(s) and other service equipment and”.

The definition of ‘Recycled plastics material’ is transferred from 6.1.4.8.8 and amended to read: “Recycled plastics material” means material recovered from used industrial packagings that has been cleaned and prepared for processing

REGULATIONS 51

into new packagings. The specific properties of the recycled material used for production of new packagings shall be assured and documented regularly as part of a quality assurance programme recognized by the competent authority. The quality assurance programme shall include a record of proper pre-sorting and verification that each batch of recycled plastics material has the proper melt flow rate, density, and tensile yield strength, consistent with that of the design type manufactured from such recycled material. This necessarily includes knowledge about the packaging material from which the recycled plastics have been derived, as well as awareness of the prior contents of those packagings if those prior contents might reduce the capability of new packagings produced using that material. In addition, the packaging manufacturer’s quality assurance programme under 6.1.1.4 shall include performance of the mechanical design type test in 6.1.5 on packagings manufactured from each batch of recycled plastics material. In this testing, stacking performance may be verified by appropriate dynamic compression testing rather than static load testing; NOTE: ISO 16103:2005 “Packaging – Transport packages for dangerous goods – Recycled plastics material”, provides additional guidance on procedures to be followed in approving the use of recycled plastics material. These guidelines have been developed based on the experience of the manufacturing of drums and jerricans from recycled plastics material and as such may need to be adapted for other types of packagings, IBCs and large packagings made of recycled plastics material.

The Note at the end of the definition of ‘Tank’ is deleted.

The definition for ‘Working pressure’ is amended to read: (a) For a compressed gas, means the settled pressure at a reference temperature of 15 °C in a full pressure receptacle; (b) For UN 1001 acetylene, dissolved, means

UN 1001 acetylene, dissolved.

In the definition for ‘Packing group’, the Note is deleted.

In the definition of ‘Over-moulded cylinder’, the word “shell” is added after “coated welded steel cylinder” and after “surface of the steel cylinder”.

A new sub-paragraph is added at the end of the definition of ‘Service equipment’: (d) Of a pressure receptacle, means closure(s), manifold(s), piping, porous, absorbent or adsorbent material and any structural devices, e.g. for handling; The following new definitions are added: Fibre-reinforced plastics means material consisting of fibrous and/or particulate reinforcement contained within a thermoset or thermoplastic polymer (matrix);” Inner vessel, for a closed cryogenic receptacle, means the pressure vessel intended to contain the refrigerated liquefied gas; Pressure receptacle shell means a cylinder, a tube, a pressure drum or a salvage pressure receptacle without its closures or other service equipment, but including any permanently attached device(s) (e.g. neck ring, foot ring); NOTE: The terms “cylinder shell”, “pressure drum shell” and “tube shell” are also used.

In 1.2.2.1, a new entry to define electrical resistance is added in the table. An explanation of the abbreviation ‘FRP’ is added in 1.2.3.

In Chapter 1.6, two new transitional measures are added: 1.6.1.49 The mark shown in Figure 5.2.1.9.2 applicable until 31 December 2022, may continue to be applied until 31 December 2026.

1.6.2.17 The requirements of Note 3 of 6.2.1.6.1 applicable until 31 December 2022 may continue to be applied until 31 December 2024.

In addition, in response to a proposal from Sweden during the Joint Meeting, the following is added: 1.6.1.50 For articles that meet the definition for DETONATORS, ELECTRONIC as described

the calculated settled pressure at a uniform reference temperature of 15 °C in an acetylene cylinder containing the specified solvent content and the maximum acetylene content; (c) For UN 3374 acetylene, solvent free, means the working pressure which was calculated for the equivalent cylinder for

in 2.2.1.4 Glossary of names, and assigned to UN Nos. 0511, 0512 and 0513, the entries for DETONATORS, ELECTRIC (UN Nos. 0030, 0255 and 0456) may continue to be used until 30 June 2025.

Sweden also said it would prepare a multilateral agreement on this subject to

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solve the issue until the entry into force of the RID/ADR edition 2023, which was welcomed by several delegations.

PART 2 In the list of collective entries in 2.2.3.3, for F1, the entry for UN 1169 is deleted and the entry for UN 1197 is amended to read: “EXTRACTS, LIQUID, for flavour or aroma”.

In the last sentence of the first paragraph of 2.2.41.4 and the last sentence of 2.2.52.4, “not listed in this sub-section” is added after “The formulations”. There are a few additions to both tables.

2.2.7.2.3.1.4 and 2.2.7.2.3.1.5, which deal with the testing of LSA-III radioactive material, are deleted. A new 2.2.7.2.3.4.3 is added: A solid material sample representing the entire contents of the package shall be immersed for 7 days in water at ambient temperature. The volume of water to be used

 THE REGULATORS HAVE BEEN WRESTLING WITH THE USE OF RECYCLED PLASTICS IN DANGEROUS GOODS PACKAGING

in the test shall be sufficient to ensure that at the end of the 7-day test period the free volume of the unabsorbed and unreacted water remaining shall be at least 10 % of the volume of the solid test sample itself. The water shall have an initial pH of 6-8 and a maximum conductivity of 1 mS/m at 20 °C. The total activity of the free volume of water shall be measured following the 7-day immersion of the test sample.

The beginning of 2.2.9.1.7(g) is amended to read: “Except for button cells installed in equipment (including circuit boards), manufacturers ...”

PART 3 Changes to the Dangerous Goods List in Chapter 3.2 include the addition of “396” in column (6) for UN 3538, “397” for UN 1002 and “398” for UN 1012, the name of which is changed to “BUTYLENE”.

The five entries for UN 1169 are deleted, while the five entries for UN 1197 are amended in column (2) to read “EXTRACTS, LIQUID, for flavour or aroma”.

A correction is made to in column (7b) for UN 3208 and 3209; “E0” replaces “E2” for UN

3208, while for UN 3209, “E2” replaces “E0”.

For UN 3269, packing groups II and III, and UN 3527, packing groups II and III, “E0” in column (7b) is replaced by “See SP 340 in Chapter 3.3”.

There are a number of changes against UN 1891 Ethyl bromide, following its reclassification from Division 6.1 to Class 3 with a Division 6.1 subsidiary hazard. That has also involved replacement of “T1” by “FT1” in column (3b), “100 ml” by “1 L” in column (7a), “E4” by “E2” in column (7b) and “MP15” by “MP19” in column (9b). For ADR, “TE19” is deleted from column (13) and in column (19) “S2 S19” replaces “S9 S19”; for RID, “CW31” is deleted from column (18) and in column (19) “CE7” replaces “CE5”.

There is one new entry in the Dangerous Goods List, for UN 3550 Cobalt dihydroxide powder, containing not less than 10% respirable particles, Division 6.1. The various codes are slightly different for ADR and RID. The Joint Meeting decided to delete some of the proposed codes in columns (9a) and (16).

There are various changes to the special provisions. A new Note is added to SP 225 after (a): NOTE: This entry applies to portable fire extinguishers, even if some components that are necessary for their proper functioning (e.g. hoses and nozzles) are temporarily detached, as long as the safety of the pressurized extinguishing agent containers is not compromised and the fire extinguishers continue to be identified as a portable fire extinguisher.

The first sentence of SP 389 is amended to read: This entry only applies to lithium ion batteries or lithium metal batteries installed in a cargo transport unit and designed only to provide power external to the cargo transport unit.

In SP 655, at the beginning of the first sentence, “and their closures” is deleted after “Cylinder”. In SP 674, for consistency with other changes, “shell” is added after “cylinder” throughout.

There are three new special provisions: 396 Large and robust articles may be carried with connected gas cylinders with the valves open regardless of 4.1.6.5 provided: (a) The gas cylinders contain nitrogen of UN No. 1066 or compressed gas of UN No. 1956 or compressed air of UN No. 1002;

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REGULATIONS 53

(b) The gas cylinders are connected with the article through pressure regulators and fixed piping in such a way that the pressure of the gas (gauge pressure) in the article does not exceed 35 kPa (0.35 bar); (c) The gas cylinders are properly secured so that they cannot move in relation to the article and are fitted with strong and pressure resistant hoses and pipes; (d) The gas cylinders, pressure regulators, piping and other components are protected from damage and impacts during carriage by wooden crates or other suitable means; (e) The transport document includes the following statement “Transport in accordance with special provision 396”; (f) Cargo transport units containing articles carried with cylinders with open valves containing a gas presenting a risk of asphyxiation are well ventilated and marked in accordance with 5.5.3.6.

 PROVISIONS ADOPTED BY THE UN EXPERTS FOR FRP TANKS HAVE PROMPTED A WHOLESALE REARRANGEMENT IN RID/ADR

397 Mixtures of nitrogen and oxygen containing not less than 19.5 % and not more than 23.5 % oxygen by volume may be carried under this entry when no other oxidizing gases are present. A Class 5.1 subsidiary hazard label (model No. 5.1, see 5.2.2.2.2) is not required for any concentrations within this limit.

398 This entry applies to mixtures of butylenes, 1-butylene, cis-2-butylene and trans-2-butylene. For isobutylene, see UN 1055.

PART 4 In Chapter 4.1, a new Note is added to the end of 4.1.1.15: NOTE: For composite IBCs the period of use refers to the date of manufacture of the inner receptacle.

In 4.1.1.20.2, the second sentence is deleted; in the penultimate sentence, “1 000” is replaced by “3 000”.

A new last sentence is added to 4.1.3.3: Where packagings which need not meet the requirements of 4.1.1.3 (e.g. crates, pallets) are authorized in a packing instruction or the special provisions listed in Table A in Chapter 3.2, these packagings are not subject to the mass or

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volume limits generally applicable to packagings conforming to the requirements of Chapter 6.1, unless otherwise indicated in the relevant packing instruction or special provision.

In packing instruction P003, under special packing provision P32, a new Note is added: NOTE: The packagings authorized may exceed a net mass of 400 kg (see 4.1.3.3).

Similar notes are added in P004(3), P005, P006(2), P130 (PP67), P144 (PP77), P408(2), P801, P903, P905, P906(2), P907), P909, and P910(3).

A new special packing provision ‘z’ is added at the end of P200(10) showing the calculation of maximum allowable working pressure for pressure receptacles containing fluorine mixtures.

A new indent is added to note a in P911 as well as in the same note in LP906: (i) In the case of multiple batteries and multiple items of equipment containing batteries, additional requirements such as the maximum number of batteries and items of equipment, the total maximum energy content of the batteries, and the configuration inside the package, including separations and protections

of the parts, shall be considered.

A clarification is provided in IBC02, special packing provision B15, where “of composite IBCs with a rigid plastics inner receptacle” is replaced by “of rigid plastics inner receptacles of composite IBCs”.

A new special packing provision is added in IBC07: B20 UN No. 3550 may be carried in flexible IBCs (13H3 or 13H4) with siftproof liners to prevent any egress of dust during carriage.

In LP906(2), the second paragraph is amended to read: A verification report shall be made available on request. As a minimum requirement, the name of the batteries, their type as defined in Section 38.3.2.3 of the Manual of Tests and Criteria, the maximum number of batteries, the total mass of batteries, the total energy content of the batteries, the large packaging identification and the test data according to the verification method as specified by the competent authority shall be listed in the verification report. A set of specific instructions describing the way to use the package shall also be part of the verification report.

A fourth indent is added: (4) The specific instructions for use of the package shall be made available by the packaging manufacturers and subsequent distributors to the consignor. They shall include at least the identification of the batteries and items of equipment that may be contained inside the packaging, the maximum number of batteries contained in the package and the maximum total of the batteries’ energy content, as well as the configuration inside the package, including the separations and protections used during the performance verification test.

In 4.1.6.6, at the end of the first sentence, “and taking into account the lowest pressure rating of any component” is added and a new second sentence inserted: “Service equipment having a pressure rating lower than other components shall nevertheless comply with 6.2.1.3.1.” The existing final sentence is deleted.

In Chapter 4.2 there are a variety of amendments to take account of the new provisions for FRP tanks in Chapter 6.9.

PART 5 In 5.1.5.1.3, the text after the heading is amended to read: A competent authority may approve provisions under which consignments that do not satisfy all the applicable requirements of RID/ADR/ADN may be carried under special arrangement (see 1.7.4).

In 5.2.1.9.2, the double asterisk is removed from the figure, deleting the requirement to include a contact telephone number for lithium battery shipments.

The Intergovernmental Organisation for International Carriage by Rail (OTIF) had proposed catching up with an earlier change in the UN Model Regulations by aligning with the description of the Class 9 hazard in 5.2.2.2.2 by deleting the words “, including environmentally hazardous substances”.

There are some important changes in Chapter 5.4. To expand the availability of

 REVISED PROVISIONS ARE INCLUDED FOR THE SELECTION OF SALVAGE PACKAGINGS AND THE INDICATION OF THEIR USE ON THE TRANSPORT DOCUMENT

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salvage packagings, the paragraph below the heading of 5.4.1.1.5 is amended to read: When dangerous goods are carried in salvage packagings in accordance with 4.1.1.19, including large salvage packagings, larger size packagings or large packagings of appropriate type and performance level to be used as a salvage packaging, the words “SALVAGE PACKAGING” shall be added after the description of the goods in the transport document.

When dangerous goods are carried in salvage pressure receptacles in accordance with 4.1.1.20, the words “SALVAGE PRESSURE RECEPTACLE” shall be added after the description of the goods in the transport document.

The relatively new provisions for stabilised substances have also been revamped. In ADR, the words “substances stabilized by temperature control” in the heading of 5.4.1.1.5 are replaced by “stabilized and temperature controlled substances”. The text under the heading is amended to read: Unless already part of the proper shipping name the word “STABILIZED” shall be added to the proper shipping name if stabilization is used and the words “TEMPERATURE CONTROLLED” shall be added to the proper shipping name if stabilization is by temperature control or a combination of chemical stabilization and temperature control (see 3.1.2.6).

If the words “TEMPERATURE CONTROLLED” are part of the proper shipping name (see also 3.1.2.6), the control and emergency temperatures (see 7.1.7) shall be indicated in the transport document, as follows: “Control temperature: ....°C Emergency temperature: .... °C” The same paragraph in RID is amended to read: 5.4.1.1.15 Special provisions for the carriage of substances stabilized by chemical stabilization Unless already part of the proper shipping name the word “STABILIZED” shall be added to the proper shipping name if stabilization is

necessary, this additional information shall be included in the transport document.

There is also a new paragraph for molten substances: 5.4.1.1.22 Special provisions for the carriage of substances carried in molten state When a substance, which is solid in accordance with the definition in 1.2.1, is offered for carriage in the molten state, the qualifying word “MOLTEN” shall be added as part of the proper shipping name, unless it is already part of the proper shipping name (see 3.1.2.5); A new sub-paragraph is added at the end of 5.4.1.2.2: (e) For carriage of UN No. 1012, the transport document shall contain the name of the specific gas carried (see special provision 398 of Chapter 3.3) in brackets after the proper shipping name.

by chemical stabilization alone (see 3.1.2.6).

Paragraph 5.4.1.1.16 is deleted.

An important new paragraph is added: 5.4.1.1.21 Additional entries in the case of the application of special provisions Where, in accordance with a special provision in Chapter 3.3, additional information is

leading to shut-off valves shall be sufficiently flexible to protect the shut-off valves and the piping from shearing or releasing the pressure receptacle contents.

There have also been some changes in 6.2.1.4 on testing and approval, with a new 6.2.1.4.3:

PART 6 A clarification is made in 6.1.1.2, 6.3.2.1 and 6.6.1.3, where “successfully to withstand the tests” in the second sentence is replaced by “to successfully fulfil the requirements”.

Following up on the revised provisions for the use of recycled material, a new second sentence is added in 6.1.4.13.1, 6.5.5.3.2 and 6.5.5.4.6: Except for recycled plastics material as defined in 1.2.1, no used material other than production residues or regrind from the same manufacturing process may be used.

There are a lot of small changes in Chapter 6.2, aligning the terminology and clarifying the applicability of the various provisions, especially with regard to closures, pressure relief devices and other equipment. This is also expanded on in a revised 6.2.1.3.2: Service equipment shall be configured or designed to prevent damage and unintended opening that could result in the release of the pressure receptacle contents during normal conditions of handling and carriage. All closures shall be protected in the same manner as is required for valves in 4.1.6.8. Manifold piping

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Pressure receptacle shells and the inner vessels of closed cryogenic receptacles shall be inspected, tested and approved by an inspection body.

There is also a new 6.2.1.4.4: For refillable cylinders, pressure drums and tubes the conformity assessment of the shell and the closure(s) may be carried out separately.

In these cases, an additional assessment of the final assembly is not required.

For bundles of cylinders, the cylinder shells and the valve(s) may be assessed separately, but an additional assessment of the complete assembly is required.

For closed cryogenic receptacles, the inner vessels and the closures may be assessed separately, but an additional assessment of the complete assembly is required.

For acetylene cylinders, conformity assessment shall comprise either:

 THE REGULATORS ARE ALSO LOOKING AT ALLOWING THE USE OF FRP MATERIALS IN THE CONSTRUCTION OF MANLID AND OTHER TANK APPURTENANCES

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(a) One assessment of conformity covering both the cylinder shell and the contained porous material; or (b) A separate assessment of conformity for the empty cylinder shell and an additional assessment of conformity covering the cylinder shell with the contained porous material.

Similarly, there are some significant changes to 6.2.1.5.2 on the testing and inspection of closed cryogenic receptacles and a new 6.2.1.5.4 on the inspection and testing of bundles of cylinders. There are further changes in Chapter 6.2 in terms of new and revised standards concerning pressure receptacles and provisions for the application of those standards; in particular, there are more detailed provisions for dealing with acetylene cylinders.

Helpfully, the regulators have amended 6.2.2.7.8: The marks in accordance with 6.2.2.7.7 may be engraved on a metallic ring affixed to the cylinder or pressure drum when the valve is installed, and which is removable only by disconnecting the valve from the cylinder or pressure drum.

A new 6.2.2.11 details the means of marking

of closures for refillable UN pressure receptacles, with the current 6.2.2.11 becoming 6.2.2.12. The European Industrial Gases Association (EIGA) had spotted that this needs to be referenced and a new 6.2.3.9.8 was added to state: “Marking shall be in accordance with 6.2.2.11”.

At the request of industry, the first sentence of 6.2.6.1.5 has been amended to read: The internal pressure of aerosol dispensers at 50 °C shall not exceed 1.2 MPa (12 bar) when using flammable liquefied gases, 1.32 MPa (13.2 bar) when using non-flammable liquefied gases, and 1.5 MPa (15 bar) when using non-flammable compressed or dissolved gases. In case of a mixture of several gases, the stricter limit shall apply.

The regulators have also recognised ongoing product development in a revised 6.5.1.1.2: The requirements for IBCs in 6.5.3 are based on IBCs currently in use. In order to take into account progress in science and technology, there is no objection to the use of IBCs having specifications different from those in 6.5.3 and 6.5.5, provided that they are equally effective, acceptable to the competent authority and able

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to successfully fulfil the requirements described in 6.5.4 and 6.5.6. Methods of inspection and testing other than those described in RID/ADR are acceptable, provided they are equivalent, and are recognized by the competent authority.

That is followed by a new 6.5.2.1.2 (with subsequent paragraphs renumbered accordingly): IBCs manufactured from recycled plastics material as defined in 1.2.1 shall be marked “REC”. For rigid IBCs this mark shall be placed near the marks prescribed in 6.5.2.1.1. For the inner receptacle of composite IBCs, this mark shall be placed near the marks prescribed in 6.5.2.2.4.

As noted above, there has been a wholesale reorganisation of the provisions for FRP tanks.

A new Chapter 6.9 has been adopted, taken from the UN Model Regulations, and the existing Chapter 6.9 has become Chapter 6.13, containing a lot of consequential amendments and removing a lot of text to avoid duplication.

ADVERT

PART 7 In 7.3.1.13, clarification has been provided on what should be meant by “structurally serviceable”. This has been done through the replacement of the existing indents (a) to (i) with just three: (a) Bends, cracks or breaks in the structural or supporting members, or any damage to service or operational equipment that affect the integrity of the bulk container, container or of the body of the wagon/vehicle; (b) Any distortion of the overall configuration or any damage to lifting attachments or handling equipment interface features great enough to prevent proper alignment of handling equipment, mounting and securing on a chassis or wagon or vehicle [, or insertion into ships’ cells]; and, where applicable (c) Door hinges, door seals and hardware that are seized, twisted, broken, missing, or otherwise inoperative.

In a similar vein, new text is added at the end of 7.5.1.2: The cargo transport unit shall be checked to ensure it is structurally serviceable, that it is free of possible residues incompatible with the cargo and that the interior floor, walls and ceiling, where applicable, are free from protrusions or deterioration that could affect the cargo inside and that large containers are free of damages that affect the weather-tight integrity of the container, when required.

Structurally serviceable means that the cargo transport unit is free from major defects in its structural components. Structural components of cargo transport units for multimodal purpose are e.g. top and bottom side rails, top and bottom end rails, corner posts, corner fittings and, for large containers, door sill, door header and floor cross members. Major defects include: This is then followed by the three indents in 7.3.1.13.

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HELP WITH READING COMPLIANCE • REGULATIONS ARE COMPLEX BY NECESSITY BUT, SAYS CEFIC’S SABINE SCHULTES, THERE IS AN OPPORTUNITY TO MAKE THEM SIMPLER AND EASIER TO UNDERSTAND IT IS OFTEN SAID that, if four dangerous goods experts are seated around a table and given a question on the transport regulations, they will come up with four different answers, each of which is justifiable, if not totally correct. But put four inexperienced people around a table and ask them the same question, and they will struggle to come up with an answer at all.

The regulations that govern the transport of dangerous goods are of necessity very complex. They also vary from place to place and from mode to mode. They have to cover an enormous range of products and possible means of containment and transport,

while also reflecting local conditions and the expectations of societies and governments.

That the complexity of the regulations can be a barrier to understanding has long been recognised, although it has proven difficult to overcome, since they are perforce written in a language and organised in a way that can provide a basis for legislation and for enforcement. Moreover, even if the regulations themselves can be understood, there may not be total clarity over the intent of the various provisions and, if not carefully worded, they may be open to different interpretation in different territories.

Speaking at the TT Club’s webinar on risk mitigation in the tank container sector, held online this past 25 November, Sabine Schultes, senior manager for transport and logistics safety at the European Chemical Industry Council (Cefic), urged the regulators – with the help of industry – to embark on a drive for simplification. Her call may come at an appropriate time, since the UN Sub-committee of Experts on the Transport of Dangerous Goods, which draws up the UN Model Regulations that provide a framework for all other regulatory regimes, has hinted that it will be looking at this very problem.

ACCIDENT AND RESPONSE Schultes’ presentation looked in particular at the July 2012 explosion and fire aboard the container vessel MSC Flaminia in the Atlantic Ocean and the regulatory changes that it prompted. After extensive investigation, it had been determined that the explosion occurred in two tank containers carrying divinyl benzene, stowed in the hold of the ship.

Those tanks had been left on the quayside in New Orleans for ten days, in hot weather, before loading onto the ship and had then been stowed near the ship’s heated bunker tanks. It is thought that those conditions led to the early expiry of the inhibitor in the cargo, allowing it to polymerise in an exothermic reaction that led to a leak of product and then to the explosion and fire.

In the wake of that event, the regulators introduced new provisions for the carriage of polymerising substances, found in the International Maritime Dangerous Goods (IMDG) Code in special provision 386 and section 7.3.7. These were designed to help ocean carriers prepare better for the risks associated with carrying those substances that require stabilisation by means of chemical inhibitors and/or temperature control.

This was an obvious solution, Schultes said, but it has raised problems and questions.

 THE MSC FLAMINIA FIRE AND EXPLOSION LED TO NEW REGULATIONS FOR THE CARRIAGE OF POLYMERISING CARGOES BUT THESE RELY ON ALL PARTIES IN THE SUPPLY CHAIN BEING AWARE OF THE RISKS AT ALL TIMES AND ARE FAR FROM EASY TO COMPLY WITH

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For example, it requires shippers to prepare their cargo with stabilisation sufficient to protect the cargo for the expected duration of the voyage and for the temperatures likely to be encountered. She noted that the current conditions of port congestion and delays both at sea and in land transport make it almost impossible for shippers to know for certain how long it will be before the cargo gets to the consignee.

WHAT THE PUBLIC WANTS It is the case that public perception of risk has changed; when a high profile incident – such as the MSC Flaminia explosion – occurs, regulators and authorities are under pressure to do something, and to do something quickly.

That can lead to hasty decisions and ineffective controls being put in place; new regulation may be incomplete or difficult to implement, leading to further changes in coming years that generate operational challenges for shippers and carriers. Almost inevitably, new requirements will bring new management requirements and, quite possibly, delays in the supply chain, increasing costs. Any further accidents of a similar nature will also erode the trust between the parties in the supply chain, raising the possibility of cargo rejection or further delays.

And governments, similarly under pressure to be seen to be doing something, may well react with stricter enforcement measures.

Schultes’ view of regulatory simplification does not necessarily mean fewer regulations, but their texts much be understandable for all personnel involved in moving dangerous goods. Those regulations need to be in language that is clear and simple.

In the maritime chain, changes to the IMDG Code are agreed by the International Maritime Organisation’s (IMO) Sub-committee on Carriage of Cargo and Containers (CCC), which entrusts the development of the details to its Editorial and Technical (E&T) Group.

 CARGO OWNERS AND VESSEL OPERATORS HAVE A LOT OF EXPERIENCE IN APPLYING THE IMDG CODE AND OFFER A RESOURCE THAT CAN HELP THE REGULATORS DEVELOP NEW RULES THAT ARE APPROPRIATE AND WILL DELIVER THE RESULTS THAT ARE NEEDED

CCC’s decisions also need to be ratified by IMO’s Maritime Safety Committee (MSC).

The bodies making the decisions at CCC, E&T and MSC are national authorities, Schultes pointed out. Trade associations and other non-governmental organisations can only have observer status.

A ROLE TO PLAY Schultes urged rulemakers to allow industry to be more closely involved in the rulemaking process to help ensure that new regulations are feasible and will lead to the desired outcomes. That involvement should take place prior to decisions being made, although she

requirements. This is something that Cefic, TT Club and other parties do for their members and for the wider industry.

Schultes also addressed the issue of trust through the supply chain, saying that transparency and open communication between all players can help foster trust in the process and also help to identify those “black sheep” that are not playing by the same rules. That transparency, she said, is the very foundation of compliance.

The regulations are now largely harmonised, Schultes concluded, which means there is the opportunity to look at how they can be simplified and clarified. However,

acknowledged that the urgency with which some changes are needed will place constraints on this involvement.

Trade bodies can also play a useful role through the provision and dissemination of guidance material, so as to help dutyholders understand and interpret the applicable

while that will be good for those who take their compliance responsibilities seriously, it cannot address the issue of wilful nonor mis-declaration of dangerous goods, which is something that only more attention on enforcement can deliver. cefic.org

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REGULATIONS

NO TROUSERS MARITIME • IMO’S MEPC IS STRUGGLING TO BALANCE THE EXISTENTIAL THREAT POSED TO ISLAND NATIONS WITH THE NEED TO MAINTAIN THE VIABILITY OF MARITIME TRADE IN THE WAKE of the COP26 conference in Glasgow in November, there was much anticipation for the 77th session of the International Maritime Organisation’s (IMO) Marine Environment Protection Committee (MEPC), which was held in a hybrid format from 22 to 26 November. COP26 had “invited” IMO to accelerate progress in the reduction of greenhouse gas (GHG) emissions from shipping, with the aim of reaching zero emissions by 2050.

Another topic of great interest was the prevention of pollution by plastics from ships, following the X-Press Pearl incident off the coast of Sri Lanka this past 20 May. A fire that broke out on the containership led to the loss of several containers before the ship eventually sank, at least one of which spilled

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its cargo of plastics pellets, causing a major environmental disaster. Sri Lanka had submitted a paper asking IMO to draw up tighter regulations for the transport of such pellets, suggesting an entry in the International Maritime Dangerous Goods (IMDG) Code might be in order.

In the event, MEPC spent so much time talking about GHG emissions that there was little opportunity to discuss the Sri Lankan proposal in detail. MEPC passed the matter on to the Sub-committee on Pollution Prevention and Response (PPR), indicating that, if new provisions are to be implemented, they will appear in the International Convention for the Prevention of Pollution from Ships (Marpol), likely in Annex V. MEPC did address marine plastics litter in general, as part of the IMO Action Plan adopted in 2018; this focuses more on plastics litter generated by – and retrieved by – fishing vessels. It also includes moves to improve the availability of port reception and treatment facilities. Again, though, little progress was made at the MEPC session, aside from a proposal to make the Garbage Record Book mandatory for smaller ships of between 100 and 400 gross tonnes; draft amendments to Marpol are to be prepared.

CONTROLLING EMISSIONS Similarly, there was a whole lot of talk but not much concrete action on GHG emissions.

Some island states being threatened by rising sea levels – Kiribati, the Marshall Islands and the Solomon Islands – proposed that IMO commit to reaching zero GHG emissions from shipping by no later than 2050; this was countered by the International Council of Shipping (ICS) with a target of net-zero by 2050 (which is not quite the same thing) on the grounds that this would be more plausible given current decarbonisation technologies.

ICS expressed concern that going for zero emissions would lead to a rationing of the supply of maritime transport.

MEPC declined to adopt either resolution but, heeding the call from COP26 to get on with it, adopted revised guidelines to its short and medium-term GHG reduction measures, without setting a target. MPEC also agreed to establish an ad-hoc Expert Workshop on Impact Assessments that will consider concrete proposals for improving the impact assessment procedure and provide recommendations as part of the lessonslearned exercise. This is to be held in early March, with the aim of developing a final draft revised strategy for presentation at MEPC’s 80th session in spring 2023.

“Strengthening the ambition of the Initial IMO GHG Strategy during its revision will be crucial,” said IMO secretary-general Kitack Lim at the close of the session. “Our collective actions must show our dedication to contribute towards the global issue, climate change.”

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THE YEAR AHEAD PREVIEW • WHILE THE COVID PANDEMIC IS STILL IMPACTING THE ABILITY OF REGULATORS TO COME UP WITH NEW REGULATIONS, THERE ARE SOME INDICATIONS OF ACTIVITY THIS YEAR THIS IS AN EVEN-NUMBERED year and, for the dangerous goods transport sector, that means not so much in the way of new regulation to deal with. The biennial pattern of updates gives us some respite in 2022 – but that isn’t to say that we can take our eyes off the ball.

For a start, two of the big regulatory changes have already happened, as they both took effect promptly on 1 January. Firstly, Amendment 40-20 to the International Maritime Dangerous Goods (IMDG) Code became mandatory on that date. In practice, though, that is not such a big deal: Amendment 40-20 has been available for use

since 1 January 2021 and it reflects the changes included in the 21st revised edition of the UN Model Regulations, published in 2019.

As such, it is also harmonised (more or less) with the other international and regional modal regulations that came into effect over the course of last year so many in the supply chain, particularly those consigning intermodal shipments, will have already taken up the new version.

The second update to have already come into effect is the 63rd edition of the International Air Transport Association’s (IATA) Dangerous Goods Regulations (DGR). IATA works on an annual rather than biennial cycle,

so the 62nd edition, which took effect on 1 January 2021, mirrors the current edition of the International Civil Aviation Organisation’s (ICAO) Technical Instructions on the transport of dangerous goods by air, once more based on the 21st revised edition of the UN Model Regulations. IATA says the annual update helps it to keep abreast of safety-critical issues and also that the revenue it receives from the sale of each year’s DGR helps fund its dangerous goods programme.

In even-numbered years, without the new ICAO Technical Instructions to follow, IATA’s DGR update generally contains fewer technical amendments, and the same is true this year, with most of those changes adopted referring to lithium batteries. A fuller report on the 62nd edition of the DGR can be found in the October issue of HCB (see page 87).

VIEW FROM THE TOP The international regulatory bodies are now halfway through their current biennium of work. They have, however, been affected like industry at large by the hygiene measures, travel restrictions and other interruptions resulting from the Covid-19 pandemic, which has slowed the pace of rulemaking. That has been compounded by space constraints at the UN’s Palais des Nations in Geneva, as well as restricted availability of live interpretation, which is needed if decisions are to be made.

Taking that into account, it can be expected that the 23rd revised edition of the UN Model Regulations, due to be adopted this coming December, will feature fewer changes than usual.

Indeed, Duane Pfund, current chair of the UN Sub-committee of Experts on the Transport of Dangerous Goods, said last year that the Sub-committee feels that the Model Regulations are now sufficiently mature that they require little in the way of maintenance, other than the adoption of provisions to deal with emerging hazards, many of which relate to energy storage technology.

Mirroring once more the current experience of the industry at large, the Sub-committee is now being expected to incorporate within its work reference to the UN’s Sustainability Development Goals; in practical terms this will involve regulating the transport of

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emerging, low- or zero-carbon fuels. It can easily be imagined that the Sub-committee will have to work quickly on this to keep up with the developments already being made in the industrial and transport sectors, especially as there will inevitably be a need for research to establish the type and extent of the hazards such fuels present.

Duane Pfund also said that the Subcommittee will be looking at improving the level of implementation of the UN Model Regulations and the other rulebooks that derive from it, not least in developing nations that may lack the necessary resources to make effective training available to those who need it, or to carry out the enforcement and oversight that are called for to ensure the regulations are being observed. In addition, Pfund said, the Sub-committee will be looking at issues of interpretation and wants to provide guidance on those areas of the regulations that are proving problematic.

NORTH AMERICAN ISSUES In light of Pfund’s comments, it is instructive to look at Transport Canada’s proposals to introduce a competency-based training and assessment regime in its domestic regulations (see page 32), akin to that which will be introduced to the air mode in 2023 via the ICAO Technical Instructions and IATA Dangerous Good Regulations. In its proposals, Transport Canada notes that it is the first country to take this approach but it would seem unlikely that it will be the last.

Transport Canada has also reported on its current programme of research projects, again pointing forward to potential regulation, if not this year then possibly in 2023. Not surprisingly, many of these are looking at new technologies and emerging fuels and will focus on establishing the risks such articles and substances present in transport. It is also considering how to apply digital technologies

 REGULATORS AROUND THE WORLD HAVE TO BE ALERT TO TECHNICAL DEVELOPMENTS. WHILE MANY OF THESE RELATE TO NEW ENERGY STORAGE SYTEMS, THE EMERGENCE OF FRP TANKS WILL ALSO NEED TO BE ADDRESSED

in various areas, including a geographic information system (GIS)-based risk assessment methodology and, interestingly, a ‘smart package’ for use with lithium batteries that provides an alert when there is an issue inside the package.

North America is also considering whether and how to apply the recently adopted provisions in the UN Model Regulations for the use of fibre-reinforced plastics (FRP) portable tanks; we have not yet seen any proposals from the US but composite tank truck barrels are already in use and it will not be too much of a stretch to see similar provisions for tank containers.

More broadly, the US Pipeline and Hazardous Materials Safety Administration (PHMSA) is now finding life a little easier under the Biden administration, and it is hoped that its biennial

into HMR where appropriate, and taking a data-driven approach to the development of new proposals.

The other international rulemaking bodies are now largely finished with their work to transpose the changes included in the 22nd revised edition of the UN Model Regulations into the various modal rulebooks. Those changes will be formally adopted by those bodies during the course of this year so that they can enter into force promptly on 1 January 2023 – although there will be the usual six-month transition period for RID, ADR and ADN (at least within the EU) and a one-year period where Amendment 41-22 of the IMDG Code will be usable alongside Amendment 40-20.

HCB will continue to bring readers timely information on amendments to the main

harmonisation rule, HM-215P, will appear in a timely fashion this year, allowing the US Hazardous Materials Regulations (HMR) to be aligned with international provisions from the start of 2023. Meanwhile, PHMSA is continuing with its efforts to clean up its list of special permits and approvals, incorporating them

international regulations and, wherever possible, also to domestic legislation and regulation. We will certainly be keeping a close eye on the interesting efforts being made to harmonise road transport rules across Latin America, a massive undertaking that is long overdue.

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NOT OTHERWISE SPECIFIED THE NEW SNAKE OIL There is, these days, an increasing gulf between what’s ‘true’ and what’s ‘believable’, it seems. Conspiracy theories abound, even (indeed, especially) in the more well educated societies. One of the most pernicious of recent theories is that 5G radio signals are causing the Covid pandemic, autism, erectile dysfunction, sterility and heaven knows what else. People have been setting fire to the masts that carry the 5G signal – although they were also doing that when 3G came around.

And, bizarrely, people have been trying to protect themselves from the invisible threat posed by 5G by doing things that are definitely hazardous, like using lead shields or, as Dutch authorities recently reported, wearing ‘negative ion’ jewellery to neutralise the signal. Officials from the Dutch Authority for Nuclear Safety and Radiation Protection (ANVS) said that ‘anti-5G’ necklaces and ‘quantum pendants’ could even damage DNA when used for a prolonged time.

ANVS found that the jewellery emits ionising radiation and, although this is at a low level, wearing it 24 hours a day for a year would deliver a dose of radiation well in excess of the legal limit in the Netherlands. It is, then, ironic that a lot of the misinformation about 5G is being passed around by smartphone and tablet, using the very pathway the conspiracists seek to destroy.

NOT SO MAGIC MUSHROOMS There are other ways of ‘sticking it to the man’, as we used to say back in the day, and taking charge of your own life. But you need to be careful. We hear regularly of things going badly awry when individuals seek to bypass the established supply chains. Here’s one

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example from Ukraine.

Four people were recently hospitalised with botulism in Lebedin, north-east Ukraine, after eating homemade canned mushrooms.

Unfortunately for the victims, the regional hospital specialising in infectious diseases and dermatology had only one dose of anti-botulism serum, which was given to the sickest of the four; one was already past helping and the other two managed to purchase the anti-toxin on the black market.

As is often the case, those who were affected were trying to do as best they could with the money and food available to them, eking out their mushroom harvest by preserving some of it. Sadly they are not alone: Ukraine reported at least 80 outbreaks of foodborne botulism in 2021, mostly involving food made at home or bought from unlicensed sources.

SOMETHING SMELLS FISHY Then there are those that succumb to bad practices in the mainstream food sector.

One migrant worker died and two others were hospitalised in a serious condition in Tamil Nadu, India in December. All three had been working at an established factory that uses fish waste to produce fish oil and fish powder and had been asked to clean an effluent storage tank.

IANS reported that the work was scheduled after the tank, in use for a decade, started giving off noxious fumes. All three fell unconscious as the tank was opened and an inquiry has been launched to determine what exactly it was that knocked them out, although anyone who has got up close and personal with a old bottle of nam pla may well have an idea of what they were faced with.

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