ITCO’s advice on sampling

GOLDEN RULES

SAMPLING • IF SAMPLES ARE TO BE TAKEN FROM TANK CONTAINERS, IT IS NOT THE DRIVER’S JOB. HOWEVER, IF NEEDS BE, IT CAN BE DONE, AS LONG AS SOME STEPS ARE TAKEN

THE INTERNATIONAL TANK Container Organisation (ITCO) has issued guidance to tank container operators and service providers on safety issues surrounding the sampling of substances being carried in tank containers or portable tanks. ITCO says the practice is increasing and its members report that their own personnel are being called upon to tank samples, which opens them up to risks from working at height and exposure to product vapours.

ITCO’s guidance document stresses that shippers and receivers should arrange sampling by their own properly trained and qualified personnel or by specialist cargo surveyors. ITCO strongly recommends that tank operators and service providers should not undertake sampling themselves.

However, ITCO recognises that there could be situations where a tank operator or service provider might agree to carry out the procedure, and its document sets out some of the steps that it recommends be taken to minimise risks to its personnel.

In particular, the operator/provider should obtain written instructions from the cargo owner as well as a safety data sheet (SDS), and undertake a risk assessment. Only properly trained and qualified personnel should be used and expert advice should be sought before any hazardous operation is undertaken.

HOW TO DO IT The ITCO guidelines themselves, which are quite brief, fall into three sections: safety considerations, procedures, and the liabilities that have to be taken into consideration. They make it clear that operators and service providers need to be aware of their liabilities and seek legal advice on a range of issues, including their obligations to train personnel and maintain training records; their obligations if instructing a third party, such as a transport company’s driver; contract terms and insurance; errors or omissions in the procedures; and their duty in the event of lost or unidentified samples or the deterioration or contamination of samples.

Clearly, if the guidelines are to be followed, an employee of a tank operator or service provider cannot simply respond positively to a request from a consignor or consignee to undertake the sampling operation. Any such request needs to be referred back to the company or companies involved so that the necessary measures can be put in place.

Indeed, the guidelines say that the shipper or receiver making any such request needs to have a documented sampling procedure with detailed instructions on all aspects of the operation, and provide training to those carrying out the procedure.

The ITCO guidelines do cover some aspects of the recommended procedure. For instance, they say that a valid SDS must be available and personnel need to be aware that some substances that are not deemed dangerous goods for transport do have hazardous properties that see them regulated under workplace safety legislation. Operatives need to be fully protected against those hazards, as well as any other hazards arising from the site or the tank itself. Tanks should be equipped with a sampling valve; ITCO is insistent that sampling via an open manlid or other opening is not recommended, although it says that a sampling adapter may be fitted to the valve.

It is also important to ensure that the sample collection vessel is fit for purpose and compatible with the substance being sampled; operatives also need to be aware of any regulations that would apply to the sample itself when being transported off-site. HCB

The full text of the ITCO guidelines can be downloaded from the Organisation’s website, www.itco.org.