HCB Magazine July/August 2021 by Enhesa Product

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EDITOR’S LETTER

Trade is, fundamentally, a simple business. Someone has

delays for vessels arriving from Asia with goods for US

something somewhere in the world and, if they can sell it for

consumers and having a dramatic knock-on effect on the

a higher price somewhere else and can cover the shipping

domestic haulage business. More recently, Covid restrictions

costs, that’s what they will do. It’s a concept that’s been

at the massive container port at Yantian, China in May and

around for a long time.

June caused immense backlogs of export goods, many

A successful long-term trade flow depends, therefore, on

destined for the US market.

stability in the cost of shipping, as well as in the price at the

Such interruptions in the containerised supply chain have

point of origin and the price that the buyer is prepared to pay

been compounded by actions by the liner operators to reduce

at the other end.

spare capacity, initially to reflect falling demand, and by the

For some years now, global trade infrastructure has allowed

six-day blockage of the Suez Canal caused by the grounding

the mature markets in North America and Europe to buy goods

of the containership Ever Given, with thousands of containers

and materials from China and elsewhere in Asia, where they

ending up in the wrong place or in the right place at the wrong

can be manufactured or produced at prices that cannot be

time. Empty containers are also in short supply, or in the

matched in the buying countries. That same infrastructure has

wrong place.

also been used to supply China and other Asian nations with

One significant result of all this disruption has been a surge

the raw materials and more up-market goods that they need

in ocean freight costs. At the end of May, Drewry Shipping

or, given their increasing wealth, desire.

Consultants calculated that the rate for a 40-foot container

More recently, that established pattern of trade has been threatened. Already destabilised by the US-China trade war, further disruption arrived with the Covid-19 pandemic. Originating

from Shanghai to Rotterdam was 485 per cent higher, at more than $10,000, than a year earlier. If the cost of shipping a container rises suddenly by $8,000,

in China, it first affected the volume of exports and imports from

then the economics of the trade may well begin to look shaky.

and to that country but, as the virus spread around the world,

Many small-scale enterprises in Europe, buying goods from

it took its impact with it, causing lockdowns and a collapse in

China, now find that their profit margin has evaporated. But for

demand for all manner of goods (and a surge in demand for

chemical exporters in Europe and North America the situation

others). As a moving target, supply chains had to react nimbly to

is the same: can they still turn a profit on exports to Asia? They

try to keep goods moving from wherever they could be sourced

may have to return to shipping in parcel tankers to get a margin,

to wherever the demand (and price) was greatest.

as high container rates look likely to be here for a while yet.

But working restrictions during the Covid lockdown caused chaos at ports on the west coast of the US, leading to massive

Peter Mackay

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CONTENTS VOLUME 42

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NUMBER 07

UP FRONT Letter from the Editor 30 Years Ago Learning by Training The driving seat Raising the awareness of compliance

TANKS & LOGISTICS Hold the fort Fort Vale invests Be prepared Matlack looks at pre-loading Right place, right time Hydera builds South Carolina depot Laundry and more Quala adds to sites and services Close the loop OPW advises on couplers Modal shift CSX acquires Quality Carriers News bulletin – tanks and logistics

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INDUSTRIAL PACKAGING Green inside Schütz expands recyclate use Good to go Greif starts the year well Back and forth Schoeller Allibert aids circularity News bulletin – industrial wpackaging

COURSES & CONFERENCES Close up GPCA calls for collaborative effort Conference diary Get together ChemUK is coming soon

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REGULATIONS The rules to follow US gets back into line at COSTHA Communication breakdown Problems with OSHA proposals To the point Joint Meeting sets to work

BACK PAGE Not otherwise specified

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TSA INSIGHT Supplement featuring the latest quarterly issue of the Tank Storage Association’s magazine

Editor–in–Chief Peter Mackay, dgsa Email: peter.mackay@hcblive.com Tel: +44 (0) 7769 685 085

SAFETY Incident Log Shine a light Headlamps must be ex-proof Where in the world Chemtrec aids compliance Foot on the ladder HSE highlights loading arm risks

Campaigns Director Craig Vye Email: craig.vye@hcblive.com Tel: +44 (0) 208 371 4014

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NEXT MONTH Consolidation in chemical tankers Latest from storage terminals Dealing with supply chain disruption

Managing Editor Stephen Mitchell Email: stephen.mitchell@hcblive.com Tel: +44 (0) 208 371 4045 Designer Richard Seymour

Commercial Director Marc Freed Email: marc.freed@hcblive.com Tel: +44 (0) 208 371 5136

Production Manager Alessandra Rossi Email: a.rossi@hcblive.com Tel: +44 (0) 208 371 4032

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HCB Monthly is published by Cargo Media 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.

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30 YEARS AGO A LOOK BACK AT JULY 1991 The July 1991 issue of HCB had a big focus on tank containers and in particular on the inchoate market for this comparatively young concept in the US. Editor Mike Corkhill pointed out that, whereas in Europe, where the “lay of the land (and water)” offers an appealing market for intermodal tanks, the entrenched forces of the US railroads and truckers had conspired to delay the development of a domestic tank container (that is, ‘ISO tank’) sector in North America. While some efforts had been made to expand the use of tank containers, notably by Union Pacific with its BulkTainer service, part of the problem was encouraging drayage companies to use suitable chassis, as well as the lack of dedicated regulation. However, the publication of HM-181 in December 1990, designed to bring the US Hazardous Materials Regulations closer into line with international provisions, was expected to help in that direction, while both Stolt and Hoyer had recently announced their commitment to the use of tank containers for US domestic transport(ation) and Stolt had formed an intermodal partnership with Chemical Leaman Tank Lines. Those figures were borne out by HCB’s annual fleet review of tank container operators, with Hoyer (4,640 tanks) and Stolt (4,350) being far and away the largest in the business; only Transport Coulier, GCA Trans,

the latest – in June 1991 at the Albright & Wilson Americas plant in Charleston, South Carolina – having killed six workers and injured several more. Indeed, the New York Times reported that 79 people had died and nearly 1,000 been injured in the 12 worst chemical and refining incidents in the previous four years, prompting investigations to determine if there were any common causes. At the time, investigation work was carried out by several different agencies, often with the results of those investigations being kept confidential over legal concerns. In 1990, the new Chemical Safety and Hazard Investigation Board (CSB) had been established following amendments to the Clean Air Act but a year later Congress had still not appointed any members of the Board nor approved any funding. The petrochemical industry was taking its own steps, with the US Chemical Manufacturers Association (CMA) having formed a Carrier Assessment Council to develop a third-party assessment system to periodically evaluate carriers for safety fitness and regulatory compliance. This was intended to be a cost-effective means of implementing the Distribution Code under CMA’s Responsible Care programme, rather than to address the hazards so apparent in the chemical processing sector.

Rinnen, VTG and Wim Vos – all European – having more than 1,000 tanks under their control. For the sake of comparison, in ITCO’s annual fleet survey this year, Stolt’s number was put at 40,330 and Hoyer – having been overtaken in the ranks by the now Chinese-owned NewPort Tank Container – at 35,500. Meanwhile, concerns were growing about safety standards in US petrochemical manufacturing facilities after a series of fatal incidents,

The move followed on from similar initiatives in Europe, where the European Council of Chemical Industry Federations (Cefic) and the European Petrochemical Association (EPCA) had recently been instrumental in setting up the International Chemical Environment (ICE) programme, which these days is in effect through the Safety and Quality Assessment for Sustainability (SQAS) and Chemical Distribution Institute (CDI) audit programmes.

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30 YEARS AGO A LOOK BACK AT AUGUST 1991 HCB’s August 1991 issue majored on industrial packaging, prompted in no small part by the adoption of the HM-181 rulemaking in the US. This represented a massive shift in the approval of packagings used to transport hazardous materials, with a move away from the longestablished US domestic system towards the UN model of performanceoriented packagings. But it was not to be a swift or smooth changeover. Our issue helpfully provided a digest of the important dates along the way, from publication of the final rule on 21 December 1990 to the effective date for HM-181 of 1 October 1991 and on through various deadlines to the end of the transition period five years later. And that was far from the end of it. In our report from the eighth International Conference on Steel Drums, which had taken place in Toronto in June 1991, we reported on the decline in the market share of steel drums in the US, in the face of increasing environmental pressures (and the consequent higher cost of compliance for informal recyclers), the difficulty in disposing of contaminated steel, and the generally bad image of the steel drum, often associated in the public mind with a broader toxic waste problem. Elsewhere in the August 1991 issue, John Pullen of Blagden

the UK position – Blagden’s open-head drums having successfully passed the test – he urged an international level playing field to avoid UK manufacturers losing market share to what could be deemed inferior drums imported from territories with a less stringent test. Another issue on a similar topic was provided by Martin Castle of Pira, the body that at the time was responsible for packaging approvals in the UK. The UN package testing and marking system was still relatively new and, although it had been adopted in all the modal regulations, there were some variations in how the requirements were presented. Martin also highlighted that, while each approval shows that the particular design has passed the relevant tests, that does not absolve the user of responsibilities. Furthermore, any change to the design will invalidate the approval. Martin discussed whether there was a need to follow the implementation of inspection schemes that had been introduced in a few countries, to ensure ongoing compliance. He felt it was not needed, unless there was an increase in the rate of packaging failures, although some formal quality control systems would be useful, especially for IBCs.

Packaging looked at the new delayed drop test requirement for openhead drums used to transport viscous liquids – typically paint and related materials. In this test, drums are filled with water and held for some time before the test; this can result in the head gasket swelling with absorbed water. In the UK, such drums were expected to be able to pass the test after standing for up to three weeks, while in the Netherlands the period was only 24 hours. While John supported

All these changes pointed towards a more structured, even ‘professional’ approach to the business of packaging and transporting dangerous goods. The European Commission was following suit, proposing that all firms involved in the business should appoint a suitably qualified risk prevention officer. That dream eventually became reality in the shape of the Dangerous Goods Safety Officer.

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LEARNING BY TRAINING by Arend van Campen

BUSINESS APARTHEID

There is now a test app that you have to use in order to gain access to travel or work somewhere. There are many advocates of vaccination, but I doubt that their motivation for getting a shot is valid. After all, many say they do it to regain their freedom or to be able to go on holiday again. It seems to me that this is not a well-considered decision, because it is not based on the maximum amount of information available about side effects. It seems to me to be based more on the so-called ‘confirmation bias’, which means that only information that confirms a bias is sought and accepted, while all information that contradicts it is ignored. This is not just dangerous, it is perilous. And that is why I declare that this is the Crime of the 21st Century. As you know I run a training company and work with clients all over the world. As I am writing this I am in Namibia to professionally upgrade employees to Marine Storage Terminals. Months of negotiations, the need to obtain a business visa, investment in airline tickets, hotel and car rental reservations that had to be pre-paid were all jeopardised by the demand for a negative PCR test allowing me to

This disturbing uncertainty is damaging all those whose business and income are dependent on their international networks and their ability to work on location. You may say to me: ‘just get vaccinated, so you can travel again,’ but remember that I am a business ethicist, thus to prove you are healthy first is highly unethical. Wake up my dear colleagues, our constitutional freedom to do business as we see fit has been taken away. That decision is not based on reliable scientific data, but on politicised suspicion, funded by Big Pharma and other corporations that benefit. And what about the airline industry, hotels, tourism, consultants, engineers, technicians, contractors? Will their businesses survive if these draconian restrictions are not lifted soon? If you feel that your freedom of doing your job is stolen from you and you do not want to get vaccinated, please contact me. We have to make a stand and we can only do that together. I created a Peoples Lobby Movement called the Human Well Being Fund to defend our human rights for freedom, wellbeing and dignity. A vaccine passport is just the beginning of a totalitarian surveillance state which will not be

travel. Okay, I was able to go, but before I can go back that whole circus starts again. Also, here I need to be tested to prove to an airline, local authorities, the immigration and health authorities in my home country Switzerland that I am healthy, because I am now a threat to public health. This is not only limiting the ability to conduct future international trainings, but also demotivational to travel at all.

beneficial to you or me, but only to those businesses that will profit. Time to shout, because this is called discrimination and it is wrong!

HCB MONTHLY | JULY/AUGUST 2021

This is the latest in a series of articles by Arend van Campen, founder of TankTerminalTraining. More information on the company’s activities can be found at www.tankterminaltraining.com. Those interested in responding personally can contact him directly at arendvc@tankterminaltraining.com.

HCB: There does seem to be a lack of awareness on the part of the C-Suite of the importance of proper compliance in DG transport. How can this be addressed?

THE DRIVING SEAT COMPLIANCE • LABELMASTER’S ANNUAL DG CONFIDENCE SURVEY, PRODUCED WITH HCB AND IATA, REGULARLY IDENTIFIES FAILINGS IN COMPLIANCE. WHAT CAN BE DONE TO CHANGE THAT? THE PROBLEMS FACING dangerous goods professionals in meeting their responsibilities have been well charted, not least through the annual survey conducted by Labelmaster in partnership with HCB and IATA. It is time that action was taken to change that pattern. HCB spoke to Robert Finn, Labelmaster’s vice-president, to talk through the problem. HCB: We have seen over several years that many DG professionals struggle to do their job effectively. Is this because of a lack of training or a lack of support?

non-compliance) can have on operational and financial performance and, as a result, don’t invest in the necessary DG resources, technology and training. This creates several key gaps within organisations’ processes and infrastructure that make maintaining a compliant and reliable hazmat supply chain challenging. These include: • Inadequate technology and a reliance on manual processes that are unable to meet current supply chain challenges • Insufficient DG training that doesn’t add real business value and is not adaptive to

RF: The extent to which a company’s leadership views DG management as a strategic supply chain lever directly impacts its level of investment in this area. Unfortunately, many senior leaders don’t understand the impact compliance (and

future needs • Incomplete/inaccurate master data that hinders moving new products effectively and efficiently across the supply chain • A lack of visibility across the supply chain • Ineffective processes in areas such as reverse logistics.

HCB MONTHLY | JULY/AUGUST 2021

RF: Companies invest in areas they believe will grow their business profitably and DG professionals need to find a way to change the conversation within their organisation. The willingness to fund technology and training related to hazmat often starts at the top levels of the organisation. But, for many, there is lack of awareness among company leadership regarding what those responsible for compliance actually do and how a forward-thinking hazmat shipping function can drive business growth. Organisations need to think of compliance beyond simply a regulatory necessity or mandate and recognise how it can be a competitive advantage that improves supply chain performance. When managed expertly, DG management can enable incremental revenue and share gain, risk reduction and better customer service. DG pros need to redefine their business value from a cost centre to a profit centre, a customer acquisition lever, and even a competitive differentiator. HCB: Do you have any examples of the revenue opportunities of improved compliance? RF: There are plenty. Firstly, better compliance means fewer fines and penalties and fewer rejected or snagged shipments, increasing customer satisfaction and allowing the organisation to out-perform its competitors’ on-time delivery rate. That in itself can drive more business. Similarly, it

 LABELMASTER’S ROBERT FINN (OPPOSITE) SAYS A LACK OF INVESTMENT IN COMPLIANCE CAN SERIOUSLY AFFECT COMMERCIAL PERFORMANCE - AND NOT JUST THROUGH THE SPECTRE OF PENALTIES AND DELAYED SHIPMENTS

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allows a better and easier flow of product through the warehouse or store, with more space for new products rather than returns. Internally too, having confidence in DG management frees up personnel to focus more on their operational goals, and also opens up time for innovation and a concentration on quality, safety and meeting increasing sustainability goals. In-house compliance expertise means that new product development can be aligned with regulatory standards, rather than having to reverse engineer after the event.

that using technology to automate processes is just a step, and it’s critical to invest in the people and processes in order to derive maximum value from that technology. HCB: What can Labelmaster offer to help the process?

HCB: How far can digital systems and automated hazmat software go in improving standards and making the compliance role more attractive to new entrants? RF: Despite modern technology advancements throughout the supply chain, many companies still rely on manual processes to handle DG compliance. This is highly inefficient and doesn’t enable DG pros to focus on more strategic, value-adding tasks. DG shipping software can help streamline DG management operations by providing instant, accurate, validated and compliant DG shipping documentation. By taking steps to ensure compliance – for labels, packaging, documentation, permits and more – companies can reduce the risk of stopped shipments and help ensure deliveries reach customers on time. Not only does investing in DG software help avoid fines and keep goods moving, it helps organisations maintain lean operations, better manage inventory, and identify more costeffective solutions to ensure they’re not spending more than necessary on packaging or protection of goods. Using DG shipping technology helps give organisations more complete and accurate master data. Having access to detailed information about a product’s components, makeup, dimensions and origins, not only helps those directly responsible for DG management but also manufacturing, procurement along with 3PLs, carriers,

“MANY SENIOR LEADERS DON’T UNDESTAND THE IMPACT NON-COMPLIANCE CAN HAVE ON FINANCIAL PERFORMANCE”

customers and other supply chain partners. However, while technology can significantly improve DG shipping operations, even the latest and greatest solution won’t work to its fullest potential without complete and accurate data or proper training for employees. Organisations must remember

RF: Global brands to smaller companies partner with Labelmaster to help them confidently and cost-effectively manage the complexity of the dangerous goods and hazardous materials shipping process. We have globally expanded our team of dangerous goods experts to assist companies across the world with regulatory questions, site assessments, customised training, parts classification and process improvements across multiple operating locations and supply chain partners. We have added an immersive, 3D experience to our online training modules that enables students to practice what they learned in a virtual warehouse world, increasing confidence and skill retention. Our technology - Dangerous Goods Information System (DGIS) - helps automate and streamline the DG shipping by providing instant, accurate and compliant DG shipping documentation while validating shipments against the latest regulations. DGIS can also help improve efficiency and reduce costs with features like electronic signatures, templates, training schedule management, parts inventory, and diagrams for packing and markings. DGIS can integrate with a TMS, WMS or ERP, providing organisations with the functionality they need in a familiar interface, while supporting compliance throughout the entire supply chain. This conversation will continue at Labelmaster’s annual DG Symposium, which this year will be held online in virtual form, beginning on 13 September; registration is free of charge via DGExchange.com. More information on Labelmaster’s range of products, systems and services can be found at www.labelmaster.com.

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the various markets after a couple of slightly difficult years. One thing we never lose sight of at Fort Vale is the importance of R&D and re-investment in the company and, due to significant growth in various markets, we are constructing an additional building onsite to extend our manufacturing capacity, ensuring efficiencies are maintained, whilst accommodating the additional processes and materials required to meet the increased demand. HCB Apparently you’re also moving into e-commerce, with the addition of a semiautomated warehouse - can you tell us a bit more about that?

companies in the industry quite hard but we found that not only were we well placed to negotiate the problems that Covid-19 posed, we have actually managed to turn it to our advantage. For example, we are a British company based in the north-west of England but we have a global reputation and a truly global reach, with offices all over the world. Because we control and manufacture all our own parts, we were able to act more quickly, and more effectively, than many of our competitors. As a result, 2020 delivered the third highest turnover Fort Vale has ever recorded, which was a massive

GB Yes, we’ve invested in an additional warehouse on site in the UK, operated semi-automatically by pre-programmed electric vehicles. This frees up space in the main factory, allowing for investment in new computer numerical control (CNC) machinery and increasing capacity. The nature of some of the new business generated in the rail industry has also meant that the size and space required for the larger equipment has started to pose some challenges for internal logistics, so we are building this warehouse to not only to serve the e-commerce market but to free up space in the main factory to enable us to move new processes into it, allowing us to utilise the factory space more efficiently, and again allow for increased manufacturing capacity. This is coinciding with the launch of our e-commerce web shop. Some may say we are a little late to the party with this type of service, but we would rather have a solution that works for us and our customers and I now believe we have found this. Initially, we will be launching the UK web shop for servicing our UK customer base for the spares and aftersales market. The new UK warehouse will help us achieve the service

achievement considering the extremely difficult circumstances the global market was facing. Not only that but, looking at 2021, our year-to-date sales are already exceeding last years’ total, which is a huge testament to the hard work our employees have been putting in, and also the positive recovery of

required for this type of offering. This will shortly be followed by our European web shop which will be serviced from Fort Vale BV in the Netherlands and will supply all countries and regions across Europe. This will offer our customers a better service for obtaining Fort Vale spare parts on relatively short lead times.

HOLD THE FORT EQUIPMENT • DESPITE THE PANDEMIC AND ITS ASSOCIATED RESTRICTIONS, FORT VALE HAS CONTINUED WITH ITS PROCESS OF PRODUCT DEVELOPMENT AND EXPANSION INTO NEW MARKETS SO FAR, 2021 has much been like 2020 - a series of false starts and hopes. Lockdowns have come and gone, as have variants of Covid. Hopes have risen and been dashed with monotonous regularity. But look closely and there is bright sunlight on the horizon - at least, that’s the opinion of Graham Blanchard, global head of marketing at Fort Vale, one of the world’s leading suppliers of tank valves and other equipment. HCB sat down (remotely) with Graham early in July to reflect on the year so far, upcoming Fort Vale projects, and their plans for the future. HCB So what has been happening at Fort Vale since we last spoke? How has the company managed? GB It’s been a frantic time, but in a good way! As you know, the pandemic hit some

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HCB What new Fort Vale products can the market look forward to over the rest of the year? GB Fort Vale as a company believes in the constant evolution of its products - we make the best product we possibly can, using the best materials - and then try and make it even better. One of the by-products of this philosophy is that lessons learned in one area can be utilised in others. For example, we have seen a significant growth of interest in our products for the rail industry coming from the US, due to experience in similar fields such as pressure relief safety devices. We have launched our new 6-inch Cleanflow valve this year for the road tanker market. This is a valve specifically designed for use on grease trap pumping and waste hauliers, where high flow rates are required. It’s superior to the more commonly used gate valve, and we’ve had this valve on field trials in the US since 2015, with no issues whatsoever - impressing our customer with its reliability and low operating costs. Because gate valves tend to be heavy and need specialist servicing, the Cleanflow has an unrestricted bore which keeps product residue to a minimum, enabling easy access for thorough cleaning and offering a much faster discharge time, and superb flow rates make it an ideal choice for waste product applications. As a result, we are getting considerable interest and orders from both the US and Europe. Similarly, our 2-inch BSP Twinact valve has been developed to complement the existing range of Twinact relief valves for the intermediate bulk container (IBC) sector. Following on from some benchmark testing of one of our main competitors, the new valve demonstrated better sealing performance at lower pressures and superior flow rates (up to 10 times higher) than that of the competitor valve. We then undertook further development

market we are growing rapidly in, and the interesting thing is that it’s manufactured from some quite exotic materials to improve corrosion resistance when used for transporting aggressive chemicals. HCB Do you see the US as a growable market for Fort vale? GB Yes, very much so. We have had a sizeable presence there for years supporting the ISO tank and road markets, but we are really beginning to pick up business there especially in the rail sector. This is due to contributing to industry technical boards and regulators and a lot of it has also come about by word of mouth, which is always the best kind of publicity. HCB Do you often benchmark test your products against competing manufacturers? GB Of course! It’s a vital part of the ongoing development of any of our products. Most of

 FORT VALE HAS INVESTED HEAVILY IN EXPANDING AND UPDATING ITS PRODUCTION FACILITY, TO COPE WITH GROWING DEMAND AND TO ACCOMMODATE NEW PRODUCT LINES, ESPECIALLY FOR THE US MARKET

our longstanding competitors are similarly involved in R&D and do their utmost to provide a safe, strong, usable product. But in recent years it has become apparent that there are other companies out there that perhaps aren’t so... committed to safety, shall we say? We recently benchmarked relief valves from all of the main suppliers into the ISO tank and European road market and, I have to say, the results were astonishing. Fort Vale valves ranged from 20 to 55 per cent higher flow rates than the other manufacturers. This of course begs the question of when fitting alternative valves to those that we produce, is one valve really enough to protect the vessel in the event of a fire, and to ensure operator safety? It was pleasing to see that from a random selection of production valves, each of our valves performed exactly as they should do, and that proved the consistency and reliability of the design, production methods and quality control that we have in place at Fort Vale. Our approach to continuous improvement and R&D comes at price, but it’s a price worth paying for peace of mind, and enables customers to trust in our products, and if the customer trusts you and your products, they tend to be happy customers - and that’s the kind we like! www.fortvale.com

that resulted in a low profile version of the 2-inch valve, which also resulted in better sealing and significant flow improvements over the other manufacturer. We are also in the final stages of developing a relief valve and angled transfer valve, for use in American rail under AAR regulations. It’s a

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BE PREPARED

THAT THERE IS a shortage of heavy goods vehicle drivers in the mature markets of North America and Europe is not news: the problem has been around for several years now, but that situation is becoming more acute, if not critical. An ageing pool of existing drivers, a profession that does not appear to appeal to the young, and competition from locally based home delivery services have all contributed to a position where the demand for freight transportation is beginning to outstrip the availability of drivers to satisfy it.

requirements, safety concerns, lifestyle choices including time away from family, compensation and other factors make recruitment of drivers difficult.” Matlack also notes that the driver shortage is particularly severe in the tank truck sector, especially in the transport of chemicals, where there are more stringent requirements for driver experience and safety. “The impacts associated with a shortage of drivers will increase as the country re-opens and industrial production and the economy

IDLE TIME Under the Federal Motor Carriers Safety Administration (FMCSA) Hours of Service (HOS) regulations, commercial drivers are permitted to work for 11 hours per day; however, Matlack notes, research by MIT Freight Lab published in May 2020 indicates that they spend on average only seven hours a day on the move. “Clearly there is room for improving efficiency and miles travelled,” Matlack says. “The time drivers spend loading and unloading in depots, terminals and manufacturing facilities, as well as time spent on breakdowns and equipment repairs contribute to delivery delays and increase the cost of goods.” During times of shortage, whatever the asset being considered, it makes sense to get more out of the available assets – and that includes drivers. Reducing gate-in to gate-out times is an obvious target but, at present, there are many barriers to improving driver

In the face of a lack of effective action by governments, haulage companies have been taking the initiative, offering steadily increasing wage rates and investing in cleaner and more comfortable cabs for their drivers. But still the number of active drivers declines. At Matlack Leasing puts it: “Regulatory

rebound,” the company says. While new technologies are in development and some regulatory action is likely, in the near term there is an immediate need to increase the time drivers spend on the road. That will be fine for drivers: they want to drive, not hang around waiting.

efficiency as they are dependent on a range of external parties, not least when operating as part of port logistics. While some factors affecting efficiency are not within the control of the operator or the port – inclement weather, road construction activity and, to an extent, traffic congestion – others can be

DRIVERS • TACKLING THE WIDESPREAD DRIVER SHORTAGE IS NO EASY TASK BUT, AS MATLACK LEASING SAYS, THERE ARE SEVERAL THINGS OPERATORS AND SHIPPERS CAN DO TO HELP

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addressed. Congestion within the port area itself, delays to cargo arrivals, maintenance and product sampling can all be eased, if only by providing better and more timely information to the carrier. “Truck turnaround times may be improved by investing in pre-loading, automation, timely maintenance and technology,” Matlack says. These strategies can add value in the supply chain by increasing the time drivers spend driving. GET READY One area that has been considered in Europe, without much success as yet, is the idea of pre-loading trailers. This can have a significant impact on truck turnaround times, with benefits for cargo owners, logistics companies and the terminal facilities themselves. At some facilities, pre-loading is already in place: the tank trailer, tank container or other container is loaded before the driver arrives on site so that the driver merely has to attach the trailer or chassis to the tractor unit and can depart promptly. Matlack notes that this will require the shipper or – more likely – carrier to invest in enough complementary equipment so that one trailer can be being loaded while another is on the road. Pre-loading can expedite the driver’s departure from the terminal, reducing time on site and improving their driving time. There are also benefits for the terminal, such as greater flexibility in terms of scheduling, something that often reduces overtime costs. It also means that truck drivers can adapt their schedules to avoid peak traffic times and get on the road faster, while shippers can offer earlier delivery time windows. Matlack believes that pre-loading is one tool to improve driver utilisation but there are also other changes that can be made. For instance, blown tyres, mechanical breakdowns and loads that are overweight or not properly secured can all lead to delays and reduce drivers’ mileage.

 PRE-LOADING OFFERS AN IMMEDIATE BENEFIT TO ALL PLAYERS IN THE LOGISTICS CHAIN BUT THERE ARE ALSO OTHER WAYS OF GETTING BETTER USE OF DRIVERS’ TIME, MATLACK SAYS

Companies that use younger equipment, implement timely routine maintenance and use the proper equipment for their freight experience fewer such disruptions and emergencies on the road, improving driver efficiency and driver satisfaction. LET’S GET DIGITAL Technology also has the potential to improve driver efficiency. GPS systems aid in route planning and can guide drivers on how to avoid traffic jams. Barcodes, scanners and hand-held tablets more accurately monitor freight and streamline formerly paper transactions during cargo drop-off and loading. Routine tasks such as vehicle inspections and trip logs are completed faster with improved accuracy and consistency. Advances in automotive technology also assist with the maintenance issues described above. Signals will alert drivers to shifting loads, low or flat tyres, and other safety

concerns that could delay the driver from reaching their destination. Employing technology results in a more productive work environment, Matlack says. Ultimately, driver efficiency and satisfaction are significant and growing concerns for chemical manufacturers, chemical distributors and other liquid bulk freight haulers. Driver compensation is based on miles travelled and it has been proven that higher levels of driver satisfaction are linked to higher compensation. That can only help in the drive to attract and retain new talent to the North American tank truck driving pool. This article is an edited version of a column written by Matlack Leasing’s April Uhlenburg and published this past April; Matlack Leasing, based in Bala Clwyd, Pennsylvania, is a major provider of tank trailers, tank chassis and tank containers. For more information, visit www. matlackleasing.com.

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14 TANKS & LOGISTICS

RIGHT PLACE, RIGHT TIME DEPOTS • TANK CONTAINERS RELY ON WELL LOCATED CLEANING AND REPAIR FACILITIES TO KEEP TRADING SEAMLESSLY. HYDERA IS AIMING TO OFFER SUCH A SERVICE IN SOUTH CAROLINA

FOR YEARS NOW, word coming out of the international tank container industry has been consistent: growing frustration with logistics bottlenecks along the eastern coast of the US. This frustration has been centred on the lack of tank cleaning infrastructure, poor service and a shortage of transport solutions in the area. Frustration has also been compounded by the further growth in the use of tank containers around the world and expansions of port infrastructure in the region, attracting yet more traffic. As a global service provider to the tank container and chemical industries, Ouray

Environmental Services repeatedly heard these frustrations from its tank container operator clients and determined to do something to help relieve the pressure on the global bulk liquids tank industry. Ouray identified the Charleston, South Carolina area as an ideal location for a new full-service depot for the tank container sector, not least since the state was opening a second

container terminal in the port, the Hugh K Leatherman terminal, that aimed to double the port’s intermodal capacity and with a specific goal to increase the volume of tank containers passing through Charleston. THE FULL PACKAGE This determination on Ouray’s part led to it forming a joint venture with local investment firm Pacolet Milliken this past January. That joint venture, Hydera LLC, is now building what will soon become a full-service tank depot designed specifically to service the tank container sector. It will offer a turnkey solution, including cleaning, maintenance, repair, heating, pressure testing and the storage of both loaded and empty tanks. Hydera has also partnered with Freedom Intermodal Tank Services (TCI Tank), a family-owned, Louisiana-based company, to provide s truly nationwide transport infrastructure. The Hydera facility is located with the secured perimeter of the Charleston International Manufacturing Centre (CIMC) in Goose Creek, South Carolina. CIMC, which meets the requirements of the Chemical Facility Anti-Terrorism Standards (CFATS), is a 1,600-acre (650-ha) heavy industrial business park that is home to manufacturing sites for several of the world’s largest chemical companies. It also has deepwater jetties and barge and rail access. Hydera says that this location within CIMC, along with the full suite of services it will provide, will deliver a facility that will be unparalleled in the North American marketplace. It plans to begin the storage and transport of loaded and empty tanks by September this year and to be in full operation by the end of January 2022. www.ourayservices.com

 WORK IS WELL UNDERWAY AT THE NEW HYDERA DEPOT IN CHARLESTON, WHICH WILL OFFER MUCH NEEDED TANK CLEANING, REPAIR AND STORAGE CAPACITY IN THE REGION

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16 TANKS & LOGISTICS

“This partnership brings together two industry leaders delivering high quality rail car cleaning and maintenance services in the Houston market,” says QRS president John Bauer. “Logistics and turnaround time are paramount for our customers, and our focus remains on reducing cost and completion time on each railcar at our facility.”

QUALA, WHICH OPERATES the largest independent network of tank cleaning depots in North America, has been busy this year expanding that network as well as the range of services available to its clients. The biggest slice of its annual revenues comes from cleaning tank trailers, but it is also capable of handling tank containers, rail tank cars, frac tanks, intermediate bulk containers (IBCs) or totes, and roll-off containers. Many of its more than 80 sites in the US and Canada also offer repair and maintenance services.

established a partnership with UTLX at the QRS facility in Pasadena, Texas. Under the agreement, customers now have access to UTLX Field Services’ suite of maintenance, repair, inspection and qualification services, including valve servicing, tank repairs, welding repairs, brake servicing and coupler repairs. QRS and UTLX will coordinate their operations so as to offer a seamless experience for customers. During the transition, Quala says it will continue to deliver services without

NEW SITES ADDED In early June, Quala moved into a new region with the acquisition of the tank trailer cleaning operations at Kraft Tank’s locations in Kansas City and Oklahoma City, expanding its network of chemical and foodgrade tank cleaning facilities to cover new customers and provide a wider service to its existing client base. Kraft Tank will continue to offer truck and trailer maintenance and other services at the two sites. “Our capabilities have always differentiated us from the competition and adding these facilities aligns with our vision to continue improving our network,” says Erik Leto, COO of Quala. “These two new facilities offer chemical and foodgrade tank and ISO container cleaning, heating services and IBC cleaning capabilities. In addition, these locations specifically offer new driver rooms, enhancing the overall experience with clean and convenient amenities.” That transaction followed on swiftly from the acquisition by Quala of two sites in California in late May. It bought a tank wash facility in Oakland from HTI and another in Walnut, formerly operated by Bulk Transportation. “We look forward to bringing these locations into the Quala family,” said Jeff Noble, executive vice-president of North American operations, at the time. “Both locations offer a full line of services to include cleaning,

In its latest move, Quala’s Quala Rail & Specialty (QRS) rail tank operation has

interruption, while maintenance and repair services are available immediately for existing and new customers. “Our goal with the partnership is to reduce operational logistics and cost for our customers by providing a coordinated solution at a single location,” Quala says.

product heating, specialised preps, ample paved parking, and onsite tenant opportunities. “These acquisitions allow us to expand our service offerings in both markets to support our customers while improving market capacity,” Noble added. quala.us.com

LAUNDRY AND MORE TANK CLEANING • LEADING NORTH AMERICAN DEPOT OPERATOR QUALA CONTINUES TO ENRICH ITS NETWORK, TAKING ON NEW LOCATIONS AND ADDING TO ITS SUITE OF SERVICES

 QUALA NOW OFFERS MORE SERVICES AT MORE LOCATIONS ACROSS NORTH AMERICA

HCB MONTHLY | JULY/AUGUST 2021

incident might occur during or at the conclusion of the loading and unloading of transport vehicles – most often rail tank cars and tank trucks – into a storage vessel.

WITHOUT THE CHEMICAL butadiene, people wouldn’t be able to drive their cars, cover their floors with carpet or go scuba diving. In other words, butadiene is one of those substances that most people haven’t heard of but, without it, we would not have the synthetic rubbers and elastomers that are integral components in the manufacture of vehicle tyres, shag

aromatic odour. As such, it is listed as a potential occupational carcinogen by the US National Institute for Occupational Safety and Health (NIOSH) and both short- and long-term exposure to it can cause a host of health issues. It is also extremely flammable in both its liquid and vapour forms. Butadiene is one of many chemicals that

TRANSPORT CHALLENGE As noted, the main challenge in transporting chemicals is keeping them adequately contained. This is especially true if the chemical is transported as a liquefied compressed gas in a pressurised railcar. If any of these substances exceed their boiling point and revert to a gaseous state, they will expand, thereby putting at risk the ability of the transport vehicle to contain the chemical. This could lead to a product release and/or explosion. Therefore, the overriding challenge for the transporters of such substances is to both prevent them from escaping the containment provided by the transport vehicle, whether in liquid or gaseous form, and reverting to a gaseous state, if applicable, during transport. Even so, many chemical transporters continue to rely on outdated coupler technology and ‘open-loop’ systems to connect transfer hoses from the transport vehicle to the storage vessel. Often, this technology involves a technician simply inserting a ‘stabber’ pipe at the transfer point with a pipe wrench. These connections have operational shortcomings that prohibit them from being the best dry-disconnect choice, mainly that they cannot ensure that a leak-free connection has been made or that any residual product will be prevented from remaining in the coupling when disconnected. A better alternative is the ‘closed-loop’ system, which presents significantly less risk that product will remain in the coupler as it is disconnected, lowering the exposure risk to almost zero and resulting in a safer chemical transfer process. There are two main obstacles to getting chemical manufacturers and transporters to

carpeting and wetsuits, to name just a few of many consumer goods that list butadiene as one of their ingredients. At the same time, butadiene is also a chemical that must be handled with care at all times. Butadiene is a colourless, noncorrosive gas with a mild, gasoline-like

must be produced, transported and stored in the safest manner possible, with no risk of physical exposure to technicians or release to the environment. In this article, we will illustrate how advanced dry-disconnect coupler technology can help reduce, or even eliminate, the risk that a chemical release

convert from an open to a closed system of product transfer. The first one involves the “this is the way we’ve always done it” mindset that hampers efforts to convince people to adopt a better way. The second is physical: most of the railcars that transport chemicals are owned and operated by third-party

CLOSE THE LOOP COUPLINGS • CLOSED-LOOP SYSTEMS ARE THE SAFEST WAY TO PREVENT THE SPILLAGE OF CHEMICALS DURING PRODUCT TRANSFER, SAYS OPW’S DAVID MORROW*

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TANKS & LOGISTICS 19

carriers, not the manufacturer. This means that the storage terminal must adapt its operations to meet the needs of each individual railcar. Since the product-transfer connections ‘live’ on the railcars, the challenge is to get users to buy into the benefits of closed-loop systems, thereby making advanced dry-disconnect equipment standard on their fleets. DRY-DISCONNECT SOLUTION Aiding the cause in convincing chemical manufacturers and transporters to upgrade to a closed-loop system is the availability of a comprehensive portfolio of advanced dry-disconnect couplers. The foundation of this portfolio is found in innovative flat-face poppet and double-ball valve designs. These methods of construction help reduce the risk that residual fluid will be trapped within the coupler, lowering the chance that spills will occur and giving the liquid virtually no place to collect, which eases cleaning. Typically, there will be less than 0.5 ml (0.02 ounces) of fluid left on the face seal of the coupler on disconnection. These couplers feature multiple safety interlocks that allow the valve to open and close only through deliberate user action, helping prevent accidental opening. And for

extremely sensitive applications, an optional keyed interface locks out and isolates transfer lines so that only a specific coupler can be used with a corresponding hose or loading arm, preventing cross-contamination. Finally, the couplers are quick and easy to maintain because they have fewer parts, which allows them to be repaired on-site with no time-consuming and costly returns to the manufacturer needed or interpretation of complicated maintenance instructions. CHOICE OF TECHNOLOGY There are three distinct dry-disconnect technologies, each of which offers benefits to companies transporting chemicals. Flat-face poppet dry-disconnects are the most commonly used advanced coupler technology because they feature a rugged design, excellent flow characteristics and heightened product control. The flat-face poppet ensures minimal product loss at disconnection, while the fully interlocked

 COUPLERS MUST BE ROBUST AND WELL ENGINEERED IN ORDER TO AVOID SPILLS AND LEAKAGES BUT MUST ALSO BE EASY FOR WORKERS TO OPERATE, AS THEY CAN BE USED MANY TIMES A DAY

double-safety connection system prevents opening if the coupler is not mated properly. Some models allow closure from both the coupler and adaptor side, which further reduces the risk of retention and spillage of any residual product at disconnection. Many models have been approved for use by the Association of American Railroads (AAR) and Canadian Registration Number (CRN) regulating authorities. Double-ball valve dry-disconnects give the coupler double shut-off reliability, which allows them to deliver the industry’s lowest product-loss rates. Integrated interlocks help eliminate unintentional disconnects that can threaten worker safety and damage the environment. The coupler’s unrestricted flow path creates no turbulence during product transfer for full-flow optimisation. Quick-connect dry-disconnects are extremely user-friendly due to quick, easy connection capabilities and also deliver minimal product loss at disconnection. They have also been designed to be interchangeable with other dry-disconnect models. Optional keyed couplings minimise the risk of product cross-contamination occurring when the same transport vessels are used to ship different chemicals. Hazardous chemicals are indispensable ingredients in many products that are ever-present in our daily lives. At the same time, these chemicals must be handled with extreme care, lest the user or environment become harmed as a result of a leak, spill or catastrophic release. Integral components in the handling of industrial chemicals are the couplers that facilitate connection points between transport vehicles and storage vessels. In this case, the use of advanced dry-disconnect technologies can greatly reduce the risk that hazardous chemicals will leak, drip or nest within the coupler during a transfer operation, resulting in a safer handling process for some of the world’s most significant raw materials. *David Morrow is director of sales for OPW Engineered Systems, based in Ohio and part of Dover Corp’s OPW division; he can be reached at david.morrow@opwglobal.com. For more information go to opw-es.com.

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MODAL SHIFT ACQUISITION • THE SALE OF QUALITY CARRIERS TO CSX PROMISES TO CREATE A MAJOR MULTIMODAL PLAYER IN THE NORTH AMERICAN CHEMICAL LOGISTICS SECTOR CSX CORPORATION HAS agreed to acquire Quality Carriers, the largest specialist chemical tank truck operator in North America, from Quality Distribution for an undisclosed sum. Quality Carriers has some 2,500 drivers and a network of more than 100 company-owned and affiliate terminals and facilities throughout the US, Canada and Mexico; it provides road transport services to many of the leading chemical producers and shippers in North America. “The acquisition of Quality Carriers further demonstrates our commitment to the strategic growth of our business and deepening our relationships with customers,” says James M Foote, president/CEO of CSX. “Our new partnership will provide chemical producers and shippers with a first-of-its-kind multimodal solution that capitalises on the powerful synergies between Quality Carriers’ truck transportation fleet and our costadvantaged rail network. We believe that this new capability will create meaningful long-term value for our company.” After the acquisition, the expectation is that Quality Carriers’ customers will have access to a wider range of cost-effective shipping options, using a combination of rail and trucking networks that will allow those customers to maximise capacity and delivery efficiencies in what Quality Distribution describes as “the first truly integrated trucking and rail offering”. Randy Strutz, president of Quality Carriers, will stay on to lead the business as part of CSX. “Quality Carriers is excited to become

 ACQUIRING THE QC FLEET AND PERSONNEL WILL GIVE CSX A MAJOR PRESENCE IN THE TRUCKING BUSINESS AND COMPLEMENT ITS EXISTING RAIL ACTIVITIES

HCB MONTHLY | JULY/AUGUST 2021

a new and integral part of CSX, which has unparalleled knowledge, experience and presence in the rail-based bulk chemicals transportation space,” he says. “Together, we will be exceptionally positioned to provide our customers – many of which have existing relationships with both CSX and Quality Carriers – with a unique and seamless rail-to-highway offering. We look forward to partnering with CSX and to create a new level of efficiency for bulk chemicals transportation.” BACK TO BOASSO “Transitioning Quality Carriers to CSX is a tremendous positive for all of our key stakeholders, including our drivers, employees, customers and investors,” says Gary Enzor, chairman and CEO of Quality Distribution. “It’s incredibly exciting to see the creation of the CSX/Quality Carriers combination, which has the potential to be a game-changer for our industry. This transaction gives CSX and Quality Carriers

the unique opportunity to offer a powerful combination of truck and rail solutions to customers, with the added benefit of maintaining QC’s headquarters in Tampa.” Quality Distribution’s wholly owned subsidiary Boasso Global, a leader in tank container cleaning and depot services in North America and Europe, will become a standalone entity, based in Tampa, Florida; after that, the Quality Distribution name will be phased out. Enzor will step down from his role, having been appointed CEO in 2007 and chairman in 2013, though he will continue as a member of Boasso Global’s board of directors. Joe Troy, currently CFO, will then become CEO of Boasso Global, working alongside Tony Morsovillo, who will continue in his role of president. Funds advised by Apax Partners, which acquired Quality Distribution in 2015, will continue to be the predominant shareholder of Boasso Global. “We are extremely pleased with this transaction, as Boasso Global can now build on its impressive record of success as a standalone entity,” says Ashish Karandikar of Apax Partners. “We believe the future is bright for both Boasso Global and Quality Carriers.” The transaction is expected to close in the third quarter, subject to regulatory review and customary closing conditions. www.csx.com www.qualitycarriersinc.com www.boassoglobal.com

TANKS & LOGISTICS 21

NEWS BULLETIN

TANKS & LOGISTICS

and managing director of IMT. “With this mobile app, every customer will have roundthe-clock visibility over every asset anywhere in the world right on their mobile device.” IMT is planning to add further features to broaden its smart applications and strengthen its support and service to customers. “With each new app or new feature, we want to give our customers better access to vital data they need to control the supply chain more efficiently and to optimise asset utilisation in the logistics processes,” Drenth adds. www.intermodaltelematics.com RINCHEM GROWS IN KOREA

MOL, NICHICON FIRM PARTNERSHIP

MOL Logistics (MLG) and Nippon Concept (NCC) have agreed to establish a new tank container joint venture. The new company, MOL Logistics (Tank Containers), will deepen MOL Group’s business alliance with NCC, which operates under the Nichicon brand, and expand their partnership in global tank transport. MOL acquired a 15 per cent stake in NCC in 2018 and since then the two have shared overseas offices and business networks. The joint venture will extend this business alliance and, MOL says, further accelerate collaboration in business and cargo transport operations using tank containers. “Specifically, MLG will extensively intensify its agency business on NCC’s behalf, starting in Thailand and other major Asian countries showing tremendous growth in demand for chemical products, such as China and India,” MOL says. “In addition, by leveraging MOL and MLG’s networking capabilities, MLGTC will maximise the synergetic effects of NCC’s know-how and track record in door-to-door international multimodal transport services for liquid cargoes and various types of gas.” www.mol.co.jp www.n-concept.co.jp THIRD FOR MILKYWAY

Milkyway has formally opened its new Liaoning Kingman integrated logistics facility

in north-east China. The site offers a total of 12,000 m2 of warehouse space for all dangerous goods other than Classes 1 and 7, as well as general non-hazardous chemicals. It also provides specific dust-free and temperaturecontrolled zones and a space for small samples. The facility also provides cleaning, maintenance and inspection of tank containers, rail tank cars, IBCs and other containers. The new Kingman facility is Milkyway’s third new logistics site in China and is located on the Liaodong Peninsula, offering easy access to industrial customers in the region. Liaoning is also a vital node in the ‘Belt and Road’ strategy. It is expected to strengthen the petrochemical supply chain based around Xianren Island and covering the three provinces of north-east China. www.mwclg.com IMT KEEPS TABS ON FLEET

Intermodal Telematics (IMT) is expanding its telematics applications with the new IMT Fleets app, which allows customers to have a clear overview of their fleets on a mobile device, with information on location and, depending on the sensors fitted, the temperature and pressure of the cargo. “The IMT Fleets App fits perfectly with IMT’s philosophy of making data efficiently available to our customers and thus making fleet management even more optimised and transparent,” says Dethmer Drenth, founder

Rinchem is close to finalising an expansion of its chemical logistics centre on Pyeongtaek, South Korea. Two new buildings on the campus will offer more than 3,500 pallet positions for goods of Divisions 4.1, 4.2 and 4.3 and will, like the rest of the facility, be optimised for efficiency and safety. Ken Breinholt, president of Rinchem International, says: “We look forward to better serving our customers as we expand our warehouse solutions to meet customer demand. Rinchem is dedicated to global growth as we challenge ourselves to regularly innovate and improve.” The Pyeongtaek site handles both dangerous and non-dangerous goods, with temperaturecontrolled zones and both bonded and non-bonded operations. It can handle Korean dangerous goods classes 3, 4 and 5, and IMDG classes 3, 4, 5, 6.1, 8 and 9. www.rinchem.com ON TIME WITH TALKE

Talke is introducing a time slot booking system at its sites in Germany, as part of a continual process of improving efficiencies in day-to-day operations. The new process, which applies to both deliveries and collections, has already been introduced at its logistics facilities in Hürth, Knapsack and Köln and will be added at the warehouse and container terminal at Hürth very shortly. Talke says the result of the time slot booking system, which is administered through Cargoclix, will be quicker service on site for drivers and forwarding agents, better planning for clients, and a constant overview of the status of

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shipments. All players in the supply chain will also be able to communicate and cooperate online in real time. A new user interface and app is being used to implement the system. www.talke.com VAN MOER BUYS BERTELS

Van Moer Logistics has acquired Bertels International, an Antwerp-based logistics company focusing on the storage and transport of ADR tank containers. Bertels’ 13,000-m2 site on Moerstraat (below) can store 700 teu. The company had revenues of €1.8m in 2020. Owner Peter Bertels expresses his satisfaction with the deal: “The vision of Jo van Moer gave me the confidence that the assets of Bertels International will be integrated in the existing logistic group in the most optimal way. With great pleasure I look forward to the future and growth opportunities of our organisation within Van Moer Logistics.” “With this new base on the right bank, we can offer our customers more efficiency and flexibility in terms of transport and storage possibilities,” adds Jo van Moer. “The 11 trucks of Bertels International are a welcome addition to our transport fleet that is further specialising in tank containers.” Van Moer is now planning to add a heating installation at the Moerstraat site. vanmoer.com

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STRONG AT STOLT

Stolt Tank Containers posted operating revenue of $296.6m for the six months to end May 2021, well up on last year’s figure of $264.6m, though operating profit was up only slightly, rising from $19.7m to $20.5m. The company explains that revenues rose on the back of higher ocean freight rates together with a 9.1 per cent increase in shipment numbers, though this was almost entirely offset by higher fixed costs and a reduction in demurrage and other ancillary revenues as the challenging freight market has negatively impacted these revenue sources in the short term.

Stolt Tank Containers leased in another 2,600 tank containers during its second quarter to help meet this increase in demand and, as Niels G Stolt-Nielsen, CEO of parent company Stolt-Nielsen Ltd, reports, the business continues to set new shipment records on a monthly basis driven by strong demand across a number of regions. www.stolttankcontainers.com MORE SPACE FOR NIJHOF-WASSINK

Nijhof-Wassink has completed construction of new warehouses at its Coevorden site in the Netherlands. Together, total warehouse space at the facility stands at some 17,000 m2. “Even before completion, when doors and lighting still had to be installed, the warehouses were filled with big bags from all over the world. It shows how much we were ready for expansion. Thanks to the hard work of our team in Coevorden and the contractor, the opening could take place before the initial date,” says Bertil Bouwhuis, managing director, chemical logistics at Nijhof-Wassink. Site manager René Guit adds: “After we received approval from our Board of Directors we could start building. Different parties involved switched quickly and that is exactly how we work. We’re always working on continual improvement and we don’t give no for an answer. Thanks to our network and the flexibility of our people, there’s always a solution.” nijhofwassink.com

Issue 6

Summer 2021

TSA

Tank Storage Associa on

Tank storage provides an essential interface between sea, road, rail and pipeline logistics.

Page 10

E XO L U M ’ S E VO L U T I O N AND AMBITIONS FOR THE FUTURE: I N C O N V E R S AT I O N WITH NACHO CASAJUS The quarterly magazine from the Tank Storage Association

Also in this issue, we look at AI technology, the future of DSEAR compliance and changes to red diesel regulations.

TSA

Tank Storage Associa on

Insight is published by the Tank Storage Association, the voice of the UK’s bulk liquid storage sector. To contact the editorial team, please email info@tankstorage.org.uk TSA Insight Team Peter Davidson, Barrie Salmon, Nunzia Florio CONNECT WITH US @UK_TSA Tank Storage Association TSA

CONTACT Tank Storage Association Devonshire Business Centre Works Road Letchworth Garden City Herts. SG6 1GJ United Kingdom Telephone: 01462 488232 www.tankstorage.org.uk

TSA has used reasonable endevours to ensure that the information provided in this magazine is accurate and up to date. TSA disclaims all liability to the maximum extent permitted by law in relation to the magazine and does not give any warranties (including any statutory ones) in relation to its content. Any copying, redistribution or republication of the TSA magazine(s), or the content thereof, for commercial gain is strictly prohibited unless permission is sought in writing from TSA. Claims by advertisers within this magazine are not necessarily those endorsed by TSA. TSA acknowledges all trademarks and licensees.

Peter Davidson Executive Director, TSA Welcome to the summer edition of TSA Insight. As a sector, we have a key role to play in the energy transition and are committed to supporting the UK government as they tackle climate change. This will undoubtedly require unprecedented innovation as well as partnership, significant investment and well-coordinated efforts by government, businesses, supply chains, consumers, and other stakeholders. In this issue of the magazine, we highlight the innovative strategies, efforts and forward-thinking plans of bulk liquid storage, a sector firmly focused on the future and the opportunities of tomorrow. We also explore compliance in a changing world and celebrate the successes of an ever-evolving industry, one which is looking ahead with optimism. I hope you enjoy this new edition of Insight and don’t forget to follow us on Twitter and LinkedIn to keep up to date with all our latest news.

Contents

In focus The TSA’s Conference & Exhibition will return to the Ricoh Arena, Coventry, on Thursday 23 September 2021.

Using AI to see with Clarity HyBird have developed a

Page 10 16

platform which applies AI and computer vision to improve many aspects of the business for the storage sector.

Exolum’s evolution and ambitions for the future: in conversation with Nacho Casajus CLH has recently evolved to

Greenergy’s ongoing commitment to innovation Greenergy has announced a new renewables project that

Oikos is planning further

uses proven technologies to

investment and upgrades as

transform waste tyres into

part of the proposed Oikos

advanced biofuels that can be

Marine South Side Development

blended into transport fuels.

(OMSSD).

In conversation with Ian Travers

reflect its ambitious objectives

Changes to red diesel regulations – maintaining your critical assets

for the future.

Adler and Allan explain why

TSA’s Executive Director,

your approach to red diesel

Peter Davidson.

Exolum in recognition of its international growth and to

Oikos Storage Limited is planning further investment and upgrades to its facility on Canvey Island

Ian Travers, Director of Ian Travers Limited, talks to

Looking to the future of DSEAR compliance

replenishment could shape your

RAS Ltd tell Insight about the

reliability, and performance for

ISOlating the benefits of ISO 9001

future of DSEAR compliance.

the long term.

Reynolds Training Services have

infrastructure’s sustainability,

achieved the prestigious ISO

UM Terminals reports strong demand following rebrand UM Terminals, one of the UK’s leading bulk liquid storage companies, is reporting strong demand as it enters the second half of 2021.

Page 28

9001:2015 Quality Management Systems certification.

News: The Health and Safety Executive has issued a safety alert � ‘Catastrophic failure of marine loading arm’. To know more, visit https://www.hse.gov.uk/ safetybulletins/marine-loadingarm-failure.htm

Online meetings and webinars

TSA’s Annual Review of the UK’s Bulk Liquid Storage Sector is available at www.tankstorage. org.uk/publications

The COVID-19 pandemic has challenged our model of face-toface meetings. To adapt and respond to the current situation, all of the following meetings will take place online. • 20 July 2021: TSA HR Committee • 26 August 2021: TSA Customs & Excise Expert Committee • 7 September 2021: TSA Technical Committee • 5 October 2021: TSA Council • 6 October 2021: TSA SHE Committee For more information on TSA’s meetings, write to info@tankstorage.org.uk

I N S I G H T

M AG AZ I N E

In focus

2021 Tank Storage Conference & Exhibition The Tank Storage Association’s Conference & Exhibition will return to the Ricoh Arena, Coventry, on Thursday 23 September 2021. The TSA Conference & Exhibition is the UK’s leading event for the bulk liquid storage sector. The event provides one of the best opportunities for anyone interested in effective and safe bulk liquid storage operations to come together to share knowledge and network.

exhibition. For those looking to elevate their presence further, sponsorships packages are also available. The 2021 Conference & Exhibition is planned to be an in-person event, subject to any social distancing rules in place in September 2021 and remaining restrictions.

The conference programme will once again feature top keynote speakers from regulators and industry, as well as invited topic sessions and many opportunities for networking.

The TSA looks forward to welcoming members, exhibitors and delegates on 23 September 2021. To stay connected until then, please schedule a call with our conference organisers on 01462 488232 or or by writing to tsa@tankstorage.org.uk. For all the latest news, follow us on LinkedIn and Twitter.

Registration is now open for delegates. Exhibitors can book a stand by visiting the TSA’s website at www. tankstorage.org.uk/conference-

For more information about the event and an agenda, visit https:// tankstorage.org.uk/conferenceexhibition/

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USING AI TO SEE WITH CLARITY “Artiﬁcial intelligence enables computers and machines to mimic the perception, learning, problem-solving, and decision-making capabilities of the human mind.”

HyBird have developed a platform which applies AI and computer vision to improve many aspects of the business for the storage sector.

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n a recent digitalisation insight, Deloitte state that a data-driven approach can potentially reduce annual downtime by 70 percent and bring down unplanned downtime cost to 22 percent. These benefits are clearly convincing, however realising them can prove challenging, especially when new concepts require introducing. Terminologies and technologies often remain foreign to many parts of an organisation meaning gaining acceptance can be slow. As the Artificial Intelligence (AI) knowledge partner for TSA, HyBird wanted to take the opportunity to unravel some of the thinking and terminologies around this important facet of digitalisation and how it is currently being used to increase asset performance in the storage sector.

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One critical aspect of AI relates to the ability of a computer to see, known simply as Computer Vision (CV). The first step of CV is to simply capture light and colour typically using highdefinition cameras. The next step, object recognition, is also relatively straight forward for a human; we have a couple of million years of evolution. For a computer or machine, it is more complex. A machine cannot recognise objects as an instinct, it needs to be taught through a process called machine learning. For example, training a machine to recognise the difference between the two tanks in Figure 1, requires multiple images of storage tanks to be processed by a model which is asked to make a prediction each time. The model then assesses the associated error of each prediction, identifying the Predictions

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to produce an ultra high-fidelity 3D reality model or 3DRM, an example of which is shown below.

Figure 1.: Two very diﬀerent types of tank, easily discernible to human vision

cause and refining the process until and an acceptable level of accuracy is achieved. “Without computer vision, even our smartest machines are blind” Fei Fei Lei, Director Stanford Artiﬁcial Intelligence Laboratory

Computer Vision in the storage sector HyBird have developed a platform which applies AI and computer vision to improve many aspects of the business for the storage sector. Clarity is a new concept for managing everyday operations and maintenance which encompasses many asset workflows including

visual inspections, engineering planning, workplan generation. AI and computer vision are interweaved in the Clarity platform at multiple points in the architecture from image quality inspection to auto recognition of equipment during the P&ID digitalisation process. By scanning billions of 3D spatial data points and cross correlating with 2D image pixels, Clarity can sort and select optimal image quality. The engine, using AI is tasked with combining only the best images, reducing noisy image data and selecting only the best quality images from survey grade laser scans (LiDAR) and visual imagery and videography

Although the generation of a 3DRM is a highly complex task, it is only part of the Clarity platform. The other key components include further use of AI and the integration of workflows within the platform itself. The platform affords the ability to perform inspections consistently across multiple site locations. Our AI can be trained to perform change detection between inspections, by monitoring changes in surface features and through dedicated algorithms it is able to predict corrosion development. The platform has proven to be the natural home for the multitude of IoT sensors which can vastly improve visibility of critical process and asset integrity parameters. For example, Clarity has been customised to incorporate vibration sensor data from sensors on rotating equipment.

3DRM of Greenergy’s Plymouth terminal

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Our Smart P&ID capability digitally transforms plant knowledge management

The high precision of the 3DRM, which has an accuracy of 1.2 mm, has been used to analyse the structure of storage tanks by replacing tilt tests with billion-point 3D tank analysis in less than 1/10th of the time Knowledge management is also improved across a site. Clarity can generate Smart-P&IDs using automated component mapping, ensuring your team has a direct link between your existing P&IDs and your plant’s reality. Locating the actual piece of equipment on the site 3DRM is as simple as a click on the PDF of your smart P&ID. Clarity also integrates seamlessly into EAM systems such as SAP enabling asset registers to be readily exchanged and work orders executed and managed. Clarity has proven to be a great fit with our clients’ needs. The feedback has been very rewarding.

“Greenergy began to work with HyBird in late 2020 to

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explore new technology and explore the options within AI technology. Within the 8 months we have been working with HyBird, we have managed to realise immense beneﬁts from the Clarity platform. It is now a cornerstone of the future of inspection, maintenance, and operations. This will allow us to conduct less manpower intensive inspections and reduce downtime of assets, during inspections” Sean Sexton, Global Head of Technical & Terminals, Greenergy

What are the beneﬁts? The benefits can be classified under five broad themes: Improved Business Continuity • Clients have increased asset availability & reliability • By integrating workflows, they have streamlined work planning & execution (with a reduced workforce)

Increased Knowledge Management • By capturing specific plant knowledge with respect to visuals (and others) through built-in ‘historian’ capability • Enable historical inspections to be readily accessed

Increased Digital Transformation • Clarity has brought the practically of CV & AI to the forefront such that implementation is immediately beneficial

Summary Overall Cost Reduction • Reduce inspection, maintenance, engineering and contractor costs • Minimise scaffolding and access costs Improved Remote Cooperation • By allowing contractors to access Clarity our clients have Increased productivity virtually with 3rd parties • During Covid, they have minimised disruptions with fewer on-site personnel

Clarity is a valuable platform which is proven to improve many aspects of operation and maintenance in the storage sector. The model is best suited to companies who have programs to: • Increasingly work collaboratively yet remotely • Increase operational efficiency • Optimise the time of their staff • Improve plant knowledge management

As we continue to innovate, additional exciting features, such as automated inspection capabilities using robots a mobile app extension using augmented reality (AR) and our own solution to the internal inspection of vessels will further increase the value the platform brings. As a knowledge partner for TSA members, we would be happy to answer any AI, digitalisation and computer visions queries that our fellow members may have and our vibrant team can be contacted on the details below. W - www.hybirdtech.com E - business@hybirdtech.com T - +44 (0) 207 267 7197 M - +44 (0) 787 217 3201

E XO L U M ’ S E VO L U T I O N A N D AMBITIONS FOR THE FUTURE: IN C O N V E R S AT I O N WITH NACHO CASAJÚS

CLH has recently evolved to Exolum in recognition of its international growth and to reﬂect its ambitious objectives for the future.

LH has recently evolved to Exolum in recognition of its international growth and to reflect its ambitious objectives for the future. It has also won an award at the second edition of the UK-Spain Business Awards in March this year. Nacho Casajús, NWE Lead, explores Exolum’s evolution and ambitions in light of the fundamental role of the tank storage sector and associated logistics in enabling the energy transition.

What are Exolum’s ambitions and objectives for the future? Nacho Casajús NWE Lead Exolum

Compañía Logística de Hidrocarburos) is a company with a long history and was originally founded in 1927. In recent years, as part of an important evolution and diversification process, across markets, services and products, the company purchased from the UK government the Government Pipelines and Storage System (GPSS) network - a system of pipelines and storage terminals, managed up to that time by the Ministry of Defence, providing aviation fuel logistics to both RAF stations and civil aviation. This was followed in 2020 by the purchase

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of 11 terminals in the UK from Inter Terminals, also a company with a long history, having been founded in 1929. This year, the CLH Group began operating under the brand name Exolum as part of this diversification process and to reflect the company’s ambitions for the future, particularly in the context of the energy transition. Indeed, this change represents an explicit commitment by the company to both the energy transition and to driving solutions for the future in an efficient, safe and sustainable way, which is at the heart of our strategy. Exolum’s evolution means that, while continuing to perform our traditional business of hydrocarbon transport and storage, we can also progress our capabilities, combine assets, experience and know-how to enable the transition. As we look back to our history, we are proud of the way in which we have been able to succeed and grow over the past 90 years. Looking ahead, Exolum looks forward to another 100 years of success. This will mean adapting infrastructure to be suitable for the new opportunities of the future and creating the solutions that will drive success going forward. Coupled with the need for technology neutral approach that incentivises a whole range of low-carbon technologies, this evolution will enable us to play our part in ensuring that society has access to the products that will be needed. Exolum has also been recognised by the IEA as one of the most efficient logistic companies

in the world, which undoubtedly reflects our focus and ambition for the future. In seizing future opportunities, technology will also play an important role. Throughout our history, we have implemented change through technology, from remote control for pipelines in the 1950s, to data mining and utilisation for our services producing valuable information for our customers. And we want to continue to be recognised as leaders through technology and innovation.

What role will evolving technologies - such as automation, IoT and AI - play in supporting these ambitions? At Exolum, technology has always been at the core of what we do. And we have been pioneers in the automation of our activities which has allowed us to have highly efficient processes that have been key to our ability to adapt to changes and meet the needs of our customers. IoT and AI undoubtedly play an important role in supporting this ambition. Though, it is important to note that, as well as leaders in innovation, we want to be regarded as leaders in safety, efficiency, responsibility and sustainability by our employees and customers alike. For a few years now, we have utilised a ‘Digital HUB’ programme for the coordination of digital initiatives across the business. These initiatives include the use of a new pipeline monitoring system using AI and satellite technology that increases the safety and reliability of

these infrastructures and optimises data analysis. This has enabled us to drive improvement not only in safety and efficiency, but also in the customer experience, thus providing added value to customers. Our digital transformation programme also covers the implementation of predictive maintenance in the management of the logistics network; while AI is being used to improve forecasts of oil product outflows from our facilities. In addition to these innovations, Exolum is developing a new product quality management system and has introduced technological solutions to reduce the risks associated with in-tank sampling operations.

What are the opportunities and challenges that the post-COVID 19 period presents for the industry? The sector has undoubtedly felt the impact of the coronavirus (COVID-19)

pandemic, particularly in light of supply demand balances and market fluctuations. During this time, the industry has shown great resolve and resilience. The pandemic has also forced businesses to work differently, and this has brought both opportunities and challenges. Over the past year, our experienced teams have adapted quickly and swiftly to the restrictions imposed by Covid-19, maintaining our services and responding to what customers expect of us, particularly in terms of a quality service and safety. Needless to say, our commitment to service and safety will continue in a post-Covid-19 environment. Yet, after what has been a challenging year for markets across the globe, I am optimistic that our industry will see increased levels of activity as we emerge from this unprecedented public health crisis.

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We are proud of the way in which we have been able to succeed and grow over the past 90 years. Looking ahead, Exolum looks forward to another 100 years of success.

Looking ahead, there are also big opportunities in the context of the energy transition and decarbonisation where, as a sector, we are uniquely positioned to act by ensuring that demand for products is efficiently met and by adapting infrastructure to meet future societal needs. For the bulk liquid storage industry this will mean being flexible and agile in responding to changes, while remaining safe, sustainable and profitable (and keeping that licence to operate!). At Exolum, we have already recognised this potential and are developing business models related to the possibilities of production, distribution and use of fuels and energy solutions using waste or sustainable raw materials as feedstock. We also have diversification projects in place associated with the energy transition, both in terms of sustainable energy alternatives, such as hydrogen and eco-fuels, and the circular economy. And we have established an entrepreneurship division dedicated to promoting new business opportunities that are committed to the sustainability of the planet. We want to be a player in the future, and we are part of the solution!

This evolution will enable us to play our part in ensuring that society has access to the products that will be needed.

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What kind of policy and industry initiatives will be required to ensure that opportunities can be seized? A stable and predictable regulatory framework, along with a technology neutral approach that incentivises a whole range of low-carbon

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technologies, will be key to enable the sector play its part. Indeed, the energy transition and decarbonisation will encompass a number of solutions, such as e-fuels and sustainable biofuels. In this light, collaboration and dialogue with key decision makers at both national and local level will ensure that we can manage the changes ahead safely and that we don’t lose future opportunities. Some collaboration between the public and private particularly in relation to infant technology might also be needed. Players in the sector will need to be agile and adaptable to change – we cannot stand still!

manager in Torrejón (2006-2007) and as manager of the Operations Control department (2007-2011). In 2011 he became General Manager in Vopak Terquimsa, the joint venture Exolum has with Royal Vopak in Tarragona and Barcelona. In 2016 he rejoined Exolum as commercial director and CEO for the UK, and since the acquisition of

Administration from Instituto Superior de la Energía (ISE), together with a Management Development Program (PDD) from IESE and has extensive experience in operational, executive, strategic and corporate management garnered while holding management positions in both Spain and the UK. Mr. Casajús has successfully transformed

Interterminals he serves as NorthWest Europe Region Lead, overseeing after the UK, Ireland, Germany and the Netherlands. He earned his Master of Science in mining engineering at the Higher Technical School for Mining Engineering (ETSIM) of the Polytechnic University of Madrid and a Master in Energy Business

different business units, defining and implementing long term strategies with a clear focus on sustainability and a strong orientation to results while fostering the growth of the internal teams. For more information, visit www. exolum.com

In this context, it is also important to note that we need the next generation of professionals to be interested and attracted to this vibrant and dynamic industry. Our sector is now evolving and changing, with new and exciting opportunities opening up and more complex services being provided. Against this background, it is important that we share our purpose, innovation capabilities and progressive vision for the future to attract the next generation of talent.

Nacho Casajús – NWE Lead Exolum Nacho leads the North-West Europe Region of the company after a long career at CLH. He joined the company in September 2001 and has held different roles in the Operations teams. He has looked after different terminals in the south of Spain (2001-2006), as a Terminal

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LOOKING TO THE FUTURE OF DSEAR COMPLIANCE

Jenny Hill and Carolyn Nicholls tell Insight about the future of DSEAR compliance.

he Dangerous Substances and E x p l o s i v e Atmospheres Regulations (DSEAR) have been around for some time, and those under the scope of them will be well aware of their requirements; demonstrating how the risks associated with flammable atmospheres are identified and managed. We mustn’t get complacent, though. Industry is

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changing as we begin to move towards the Net Zero goal, regulation is being revisited as we find our feet with Brexit, and more generally, our knowledge and understanding of flammable atmospheres is increasing as more research is undertaken. It is important that operators keep up to date on what it means to be compliant in an ever-changing world. Hazard Identification (HAZID) is the starting point of all risk management activity, and DSEAR compliance is no different. Thorough HAZID will

It is important that operators keep up to date on what it means to be compliant in an ever-changing world. RISK & HAZARD MANAGEMENT

make sure that a site’s Hazardous Area Classification is comprehensive and that it covers the less obvious risks, such as hydrogen leaks from faulty battery rechargers. It will also capture releases that fall outside of the guidance; those from larger hole sizes or gas generation by accidental material mixing. HAZID in DSEAR compliance is something to bear in mind as we set off on the path to Net Zero. There are significant changes on the horizon as hydrogen is to play a key role in meeting our energy targets, and with that comes new challenges in identifying and managing potential flammable and explosive atmospheres. Operators will have to consider hazards that they had not considered before, so identifying any knowledge gaps will be essential. Now is the time to be prepared, to look out for emerging research and guidance in this area from relevant industry bodies and to become familiar with the challenges these changes will bring to industry. We know that DSEAR goes beyond Hazardous Area Classification and onto demonstrating that we have the measures in place to manage our risks. The terms DSEAR and ATEX have previously gone hand in hand as the legal frameworks that require us to make that demonstration. Following Brexit, ATEX is no longer recognised in UK law, but it is important to remember that the

requirements of the ATEX Workplace Directive (99/92/EC) continue to be implemented in the UK by the DSEAR Regulations. The obligations of the operator, to provide a demonstration that the risks associated with explosive atmospheres are managed, remain unaffected but the removal of ATEX from UK law does present a good opportunity to clear up some confusion over Explosion Protection Documents (EPDs). There has sometimes been a misconception that operators require an EPD, as they are a requirement of the ATEX Workplace Directive. However, the DSEAR Regulations do not specifically require an EPD. As long as the organisation can demonstrate that the requirements of the Regulations are met, then they are compliant. The EPD could be felt to be a ‘one size fits all’ approach, but UK law gives us more freedom. That does not mean that a standalone document is not a good idea; having all information in one place (for example in a ‘DSEAR Compliance Report’) is an easier way to demonstrate compliance, particularly on sites not under the scope of other associated regulations (i.e. COMAH). Without the requirement for an EPD, however, COMAH Operators in particular are free from having separate documents with duplicated information; they have the opportunity to provide their demonstration for both DSEAR and COMAH within their Safety Report.

While the requirements of the ATEX Workplace Directive continue to be implemented in the UK by the DSEAR Regulations, equipment certification in line with the ATEX Equipment Directive (94/9/EC) is now no longer recognised. The requirements have been transposed to UK Regulation, meaning that for manufacturers, conformity assessments for equipment must now be carried out by a UK Approved Body. UK type certificates are to be used in place of ATEX Certification and CE labels are to be replaced by UKCA labels (although in most cases, manufacturers are permitted to continue to use CE markings until a transition period ends on 1st January 2022). For the operator, this makes little difference in the short term, as the equipment requirements for the EU and UK equipment certification remain the same. Operators will always have the responsibility to keep their employees safe by identifying and managing their risks. Though the fundamentals of regulation will remain the same, changes in the industrial and political landscapes mean that operators need to adapt and identify how they can continue to fulfil their responsibilities, and DSEAR compliance is no different. Jenny Hill and Carolyn Nicholls enquiries@ras.ltd.uk

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OIKOS STORAGE LIMITED IS PLANNING FURTHER INVESTMENT AND UPGRADES TO ITS FACILITY ON CANVEY ISLAND

Oikos Storage Limited is planning further investment and upgrades to its facility on Canvey Island, as part of the proposed Oikos Marine South Side Development (OMSSD).

ikos Storage Limited, a nationally significant bulk liquid and fuel import and storage facility that has been operating since 1936 is planning further investment and upgrades to its facility on Canvey Island, as part of the proposed Oikos Marine South Side Development (OMSSD).

The OMSSD project forms part of an ongoing investment programme to upgrade and enhance Oikos’ operations, to ensure that the company can continue to set industryleading safety and environmental standards. It will also enable Oikos

to future-proof, and play a vital role in the transition to sustainable biofuels, that will be important as the UK prepares to become net-zero in the coming decades. It is important to ensure that the best use is made of the existing critical piece of national infrastructure that is the Oikos facility. The needsbased case for this project emerges out of a consideration of a number of factors including the significance of the Oikos facility; the significance of the trade handled by Oikos; the changing nature of that trade (including in respect of the increasing development of sustainable liquid fuels); the significance of a flexible, resilient and competitive fuel provision and distribution system; and the recognised significance of the need for the type of infrastructure provided by the Oikos Facility. The nation is increasingly reliant on fuel which is imported into the UK by deep draft sea-going tankers to import terminals like the Oikos Facility. The existing facility plays a critical part in maintaining the UK’s fuel supply system that has capacity in the right location at a key entry point into the largest fuel market within North-West Europe. The OMSSD project consists of the installation of new import and export infrastructure, including new marine loading arms and pipelines on the

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The existing facility plays a critical part in maintaining the UK’s fuel supply system that has capacity in the right location at a key entry point into the largest fuel market within North-West Europe.

existing operational jetties and the construction of around 300,000m3 storage capacity on previously occupied brown field land across the southern part of the facility. Other associated works such as a new workshop, additional road tanker loading facilities, additional on-site parking, an extension to the existing office and off-site ecological mitigation works also form part of the OMSSD. The project is expected to take approximately 24 months to construct. If consent is granted in late 2022 for the project, Oikos would anticipate starting construction in early 2023 and would then expect the OMSSD to be operational between Q4 2024 and Q1 2025. The Oikos facility has a number of significant assets and benefits which are collectively unique. On top of its strategic Thames side location, the facility has existing connections to two nationally significant fuel distribution pipeline networks and modern infrastructure in place to accommodate further product handling infrastructure. The facility has two operational jetties, which can accommodate vessels of up to 55,000 and 120,000 tonnes deadweight respectively. Furthermore, the site includes areas of previously developed but currently vacant land within the operational boundary of the site.

For more information, visit www.oikos.co.uk

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The products Oikos handle are significant and the changing nature of the trade means that facilities like Oikos will continue to be important for UK energy supplies going forward. The UK needs to continue to have a flexible, resilient, competitive and safe fuel supply system that provides capacity where it is required. With Government targets in mind, the OMSSD project is part of Oikos’ plan to future proof the facility so that it can adapt to the changes in fuel markets and facilitate the safe storage and distribution of alternative liquid fuels when they become more widely available and used. This is an investment where Oikos is seeking to ensure resilient fuel supplies for the UK now and also to adapt to support the energy transition to renewable liquid fuels of the future.

The Oikos Marine South Side Development will enable futureprooﬁng of the site by investing in new facilities and infrastructure that will ensure Canvey Island is a leading hub for green and sustainable fuels in the years to come.

Resilience in our critical national infrastructure, in its widest sense, has to be the focus of the UK’s next economic chapter, not least after Covid-19. All too often, the focus is often on downstream and upstream fuel resilience and innovation, but the storage sector has to be a part of the solution and not overlooked. Oikos with its strategic access to the River Thames, is taking this challenge on through significant infrastructure investment at its site that supplies road and aviation (including to Heathrow, Gatwick, Stansted and Luton) fuels across South East England, one of the world’s leading fuel hubs.

Resilience in our critical national infrastructure, in its widest sense, has to be the focus of the UK’s next economic chapter.

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Oikos are proud to be keeping Canvey Island at the heart of the country’s fuel and transport needs as it has done for the last 80 years. The Oikos Marine South Side Development will enable future-proofing of the site by investing in new facilities and infrastructure that will ensure Canvey Island is a leading hub for green and sustainable fuels in the years to come. The proposals have safety by design at their heart and have been rigorously reviewed at every stage. As a facility with an established place on Canvey Island, Oikos plans to continue to work with local communities and stakeholders to ensure that the

development of the best possible proposals. It is encouraging to see the sector increasing its resilience at this point in the economic cycle. Such efforts do need the Government to continue to see the fuel storage sector as critical national infrastructure and to provide the policy and investment certainty over the long-term to ensure the sector is seeing the innovation needed. Oikos Storage Limited operates a nationally significant marine fed oil, fuel and bulk liquid import and storage facility, located on Canvey Island in Essex. For more information, visit https://www.oikos.co.uk/

Oikos are proud to be keeping Canvey Island at the heart of the country’s fuel and transport needs as it has done for the last 80 years.

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CHANGES TO RED DIESEL R E G U L AT I O N S – M A I N TA I N I N G YO U R CRITICAL ASSETS

Mark Griffiths, Head of Business Development at Adler and Allan, explains why your approach to red diesel replenishment could shape your infrastructure’s sustainability, reliability, and performance for the long term.

rom April 2022, many sectors will lose their red diesel fuel tax entitlement, relinquishing the 80% per litre saving it currently delivers. Announced as part of the 2020 budget, the reforms drive forward ambitious UK climate change commitments to promote eco-friendly fuels, improve air quality, and achieve net zero carbon emissions by 2050.

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While the updated legislation is a vital step towards corporate environmental accountability, greener business practices come at a significantly higher price. Companies across the bulk liquid storage industry must now make plans to replace existing plant and machinery reserves with alternative fuel options – such as white diesel, biodiesel or Hydrotreated Vegetable Oil (HVO), a 100% renewable ‘drop in’ diesel substitute – while mitigating risks of downtime and drops in customer service. However, with the correct

in law – and the countdown to compliance has already begun. Enlisting the support of an experienced environmental risk consultant will allow you to shape your ideal solution, investment, and timeline – and avoid productivity breaks, weighty capex commitments, and penalties under more demanding government directives.

Start-to-ﬁnish compliance support strategy and support, the immediate challenges of the red diesel transfer could lead to positive, cost-effective change across your entire operation.

present operations managers with the tricky task of reconciling increased environmental responsibility with already stretched BAU budgets.

So how can bulk liquid storage operators strike the right balance? The answer is to view the red diesel reforms not as a one-off fuel swap, but as a unique opportunity to future-proof assets and rethink your organisation’s overall efficiency, sustainability and green credentials. By taking a big picture view, companies can safeguard operations going forward and get a running start on the UK’s increasingly ambitious targets to reduce global warming. With the Environment Bill expected to come into force later this year, stricter policies will continue to be enshrined

A money-saving shift in mindset Otherwise known as gas oil, red diesel has long provided economical power for fleet vehicles, heavy duty equipment, back-up generators, and more. The jump to pricier, paraffinfree fuels – from 11.14 pence per litre to 57.95 ppl for white diesel – will

The replacement of red diesel involves a specialised sequence of tank cleaning, line flushing, and the uplift of current stores to make way for onward fuel. The success of the procedure – and its make-or-break impact on your end-users – depends on a detailed understanding of your estate, systems, and risk profile. As a first step, an environmental professional will undertake a practical audit of assets to gauge their condition, potential ecological hazards, and the recommended plan for fuel uplift and fulfilment. Key actions are likely to include full tank inspections to assess structural integrity, comprehensive cleaning and removal of red diesel residue to prevent fines, and responsible disposal in line with current compliance guidance.

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Following open dialogue and mutual agreement of your ideal methodology, skilled onsite technicians – trained in the use of all fuel transfer pumps, the handling of hazardous materials, and spill response protocols – will carry out the end-to-end replenishment process with minimal downtime and disruption. Once tanks are degassed and clear of residue, legacy fuel will be removed and disposed of in line with current compliance guidelines. Tailored follow-up consultation will focus on top line business goals and proactive measures to safeguard the ongoing health of your assets and equipment, from possible tank relining to upgraded fuel maintenance and management programmes.

A measured response measurable results

with

Following a government consultation ending in October 2020, the finer details of red diesel reforms are yet to be revealed, but prudent operators will take immediate – yet considered – action. By initiating the planning process now, and aligning with a commercially minded environmental specialist, it is possible to intelligently spread investment and alleviate the financial burden of building a more sustainable business. A professional consultant will support you in pinpointing and prioritising your most critical environmental risks, while – crucially – setting timescales for less urgent requirements, allowing

you to make meaningful changes at a manageable pace. In the HM Treasury consultation document presenting amended tax treatments of red diesel and other rebated fuels, the government shares its vision to ‘provide businesses with a much stronger incentive to improve the energy efficiency of their vehicles and machinery, look for more environmentally friendly alternatives, or just use less fuel’. It also describes the updates as ‘a signal to bulk liquid storage providers to design and sell new alternatives, thereby creating a more competitive market and consequently bringing down the price of these alternatives’. So while bulk liquid storage operators wait for clean fuel costs to fall, they should begin transforming operations one compliant stride at a time. Readying your assets for the move to fossil-free fuels and developing a deeper understanding of your environmental risks and opportunities are sensible places to start. With a trusted partner by your side, you can intelligently analyse assets, unlock efficiencies, and create a fuel maintenance programme that is fit for a sustainable future. A qualified environmental professional will help you tackle the pressing duty of red diesel replacement, make the switch with minimum spend, and navigate your most productive path to lasting compliance.

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News

UM Terminals appoints new Commercial Director One of the UK’s leading bulk liquid storage specialists has appointed an experienced commercial director. Vic Brodrick took up his new role on May 1 having previously worked as a consultant with responsibility for sales strategy. Vic has an extensive background working in senior roles in the oil, aviation and shipping and logistics sectors including spells with Essar Oil, Peel Ports and Peel Airports. UM Terminals recently put in place a new strategic growth plan to build on the substantial investment the business has made into upgrading its facilities and operations. UM Terminals operates out of 8 terminals, strategically located across the UK, handling over 40 different products. It currently has a capacity of over 300,000 cubic metres of bulk liquid storage, but the plan is to grow this to over 400,000 cubic metres. Product solutions include vegetable oils, industrial, food and feed, chemical, fertiliser, fuels, biofuels and base oils. Vic said: “I am delighted to be joining UM Terminals as Commercial

Director. The business is at an exciting stage with an ambitious strategic growth plan. I have also been hugely impressed by the culture, customercentric approach and can-do attitude of the company since I ﬁrst joined as a consultant in November 2019.” Bryan Davies, Managing Director of UM Terminals, said: “Vic’s appointment is an important one for our business and I look forward to continuing to work with him to create and develop a range of exciting customer partnerships. Our strategic plan includes maximising our UK capability, harnessing the assets of the wider UM Group and looking for potential acquisition targets that are a good ﬁt.” The company, which employs 63 people, rebranded from UM Storage to UM Terminals last year to better reflect the range of services the company offers its clients. It is part of the UM Group which has a distinguished history stretching back almost 100 years. For more information, visit https:// www.umgroup.com/divisions/umterminals

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UM TERMINALS REPORTS STRONG DEMAND F O L L OW I N G REBRAND

UM Terminals, one of the UK’s leading bulk liquid storage companies, is reporting strong demand as it enters the second half of 2021.

UM Terminals’ Managing Director, Bryan Davies.

The second pillar involves optimising the assets of the wider UM Group and its network of facilities in Europe and other parts of the world storing molasses but which could be used to store other products.

M Terminals, one of the UK’s leading bulk liquid storage companies, is reporting strong demand as it enters the second half of 2021.

The business says that a combination of commercial confidence returning post-Brexit and the positive effect of a rebrand in September last year has helped drive an influx of new enquiries. The enquiries have come from a combination of major blue-chip organisations and smaller customers seeking solutions to support their requirements for storage. The positive start to the first half of 2021 means that the team at UM Terminals is also on track with the roll out of its own strategic growth plan. The plan, announced to coincide with last year’s rebrand and launch of a new company website, consists of three main pillars. Firstly, to maximise its existing UK capability both in terms of current assets and, where appropriate, expanding existing terminals.

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The third pillar concerns looking for appropriate acquisition targets that would complement the current UM Terminals offer. One of the company’s biggest selling points is its adaptability, a willingness to problem solve customers’ individual requirements where it is possible. This has been demonstrated recently with some of its new clients where the team has carried out major tank modifications to ensure it is able to continue providing best-in-class facilities. This, in turn, requires a focus on partnership, not only with customers and suppliers but also with leading port operators, Peel Ports, Associated British Ports and Port of Bristol where UM Terminals’ tanks are located. Bryan Davies, UM Terminals’ Managing Director, said: “We have been delighted with the progress we have made since undertaking the rebrand of the business and the launch of our new strategic growth plan in September last year.We have been able to secure several prestigious new clients and also continue to grow our relationships with other existing clients. The backbone for this success is undoubtedly the continued investment,

worth many millions of pounds, that we are making in ensuring our facilities are of the highest possible standard. We are also proud of the fact that we have all of the various licences and accreditations that are necessary to be able to store such a diverse range of products”. UM Terminals operates out of 8 terminals, strategically located across the UK, handling over 40 different products for our customers. It currently has a capacity of over 300,000 cubic metres of bulk liquid storage, but the plan is to grow this to over 400,000 cubic metres.

Product solutions include vegetable oils, industrial, food and feed, chemical, fertiliser, fuels, biofuels and base oils.Services include blowing, blending, heating, processing and sampling among others. Other recent key developments have included the appointment of Vic Brodrick as the company’s Commercial Director. Vic, who took up his new role in May, previously worked as a consultant with responsibility for sales strategy. Vic has an extensive background working in senior roles in the oil, aviation and shipping and logistics sectors including spells with

Essar Oil, Peel Ports and Peel Airports. The company’s innovative Client Central Services team has also continued to go from strength to strength, providing customers with a wealth of important information including real-time data to make critical business decisions. Based out of UM Terminals’ Regent Road Terminal in Liverpool, the service integrates all weighbridge and administration from across UM’s 8 terminals. A dedicated portal gives clients instant access to essential weighbridge

Photo credit: UM Terminals

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documentation and current stock levels for each tank. They also have a secure log-in and can access their data 24/7, 365 days a year via a desktop, tablet or mobile device. Further investment in smart working practices and industry-leading technologies is planned over the coming months, benefiting both customers and the UM Terminals’ team. One other interesting development has been the increase in the number of enquiries regarding biofuel storage, a trend the business is monitoring closely in the expectation that the hydrocarbon economy will shrink over the next decade. UM Terminals employs over 50 people, working 364 – sometimes 365 days – of the year meeting its customers’ needs. The company is a key part of today’s UM Group which has a distinguished history stretching back almost 100 years.

UM’s founder, Michael KroyerKeilberg, was involved in bulk liquid storage even earlier than this – he constructed his first tank for the storage of bulk molasses in 1911 at Victoria Dock in Hull. The Group’s other services include the international trading of molasses, the sales and distribution of molasses and the procurement and marketing of vegetable oils for use in the animal feed industry. Bryan Davies added: “When we implemented our strategic growth plan last year we were in the midst of the Coronavirus pandemic and still uncertain about the likely impact of Brexit on our customers. Thanks to the hard work, commitment and dedication of our team, the ongoing investment in our business and the loyalty of our customers, we remain on track with our growth plans and with further innovation and expansion in the pipeline.” For more information, visit www. umterminals.co.uk

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Events

Lubricant Expo will now take place on 6 – 8 September 2022, at Messe Essen, Germany

The inaugural Lubricant Expo will now take place on the 6 – 8 September 2022. In response to unprecedented interest from the industry and key customer groups, we are pleased to announce that Lubricant Expo is now extending to be a 3-day event, expanding in scale and scope to include a larger exhibition hall that will welcome 200+ exhibitors within a bigger area for customers and suppliers to connect. A multi-track conference serving key market sectors with more sessions and speakers will extend over the new 3-day format, offering suppliers and visitors greater time to network, enhance their knowledge and find the solutions they need. The show has already attracted significant interest with support, exhibitors and speakers confirmed from leading organisations. Paul Hooker, Event Director at Lubricant Expo says “We have been delighted

with the response and support from the industry since Lubricant Expo launched. Moving the event to September 2022 means we can now host a larger event, unlocking further opportunities for participants and visitors by creating a bigger exhibition space that can welcome more suppliers and an expected 4000+ visitors from around the world, creating a truly unmissable international event for the lubricant industry.” Lubricant Expo brings together the lubricant community and its customers with a free-to-attend exhibition and conference, providing visitors with the knowledge and suppliersthey need to reduce costs, improve efficiency, progress development and maximise the performance of their products and equipment. To know more, lubricantexpo.com/

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visit

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GREENERGY ’S ONGOING COMMITMENT TO INNOVATION

At the start of 2021, Greenergy announced a new renewables project that uses proven technologies to transform waste tyres into advanced biofuels that can be blended into transport fuels.

ith an ongoing commitment to innovation, Greenergy has grown to be an established supplier and distributor of transportation fuels by consistently providing customers supply resilience and a customer service team who are available 24/7.

As the UK’s only national supplier, Greenergy operates strategic infrastructure in key demand locations, with over 25 supply locations across the country, including nine ownedstock managed terminals on the Thames, Teesside, Clydebank, Cardiff and Plymouth. Through its access to strategic infrastructure, Greenergy has developed unique global supply chains to deliver fuel to its customers.

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Originally founded in the 1990s, Greenergy identified an opportunity to supply low emission diesel because of its significant air quality benefits. This commitment to sustainability remains core to Greenergy as it continues to invest in renewable transport fuels that reduce carbon emissions from transport fuels today. As the world looks to decarbonise the transport sector, the role of petrol and diesel fuels remains until other affordable alternatives are widely adopted. The most effective way to reduce carbon emissions for existing transport fuels comes from the blending of biofuels in petrol and diesel today. With rising biofuel obligations, Greenergy is now able to supply customers with high percentage biodiesel blends such as B20, that include 20% biodiesel over the course of the year compared to standard grade diesel that is up to 7%. This provides a cost-effective and sustainable lower carbon fuel option for existing diesel vehicles, avoiding the need for significant capital outlay.

To meet the needs of its customers, Greenergy has now grown to be the largest manufacturer of wastebased biodiesel in Europe, with two plants in the UK and a third located in Amsterdam. Greenergy continues to expand its manufacturing operations to meet the growing demand for biofuels, with a focus on efficiency and reducing emissions from its own operations.

Recognising the need for further innovation, at the start of 2021, Greenergy announced a new renewables project that uses proven technologies to transform waste tyres into advanced biofuels that can be blended into transport fuels. As part of UK legislation, a growing percentage of biofuel must be classed as development fuel – made from sustainable wastes and residues with a greenhouse gas saving of at least 65%. This project, when complete in 2025, will meet this requirement. Paul Bateson, Chief Operating Office at Greenergy, explained: “We recognise the urgent need to further reduce emissions in the transportation sector. As a leading manufacturer of waste-derived biodiesel that delivers greenhouse gas savings of 81% compared to mineral diesel, we are continuing to invest in the development, production and supply of liquid fuels from renewable sources to help lead our customers through the transition to a lower carbon future.”

For more information, visit www.greenergy.com

For more information, visit https:// www.greenergy.com/

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I N C O N V E R S AT I O N WITH I A N T R AV E R S regulators united and on the same track and signed up to never let that sort of incident occur again. I’m very grateful for all of your hard work over the years. I just wanted to chat to you about

Ian Travers, Director of Ian Travers Limited, talks to TSA’s Executive Director, Peter Davidson

Ian Travers, Director, Ian Travers Limited

Peter is Executive Director at the Tank Storage Association responsible for developing and promoting excellence in risk management in the sector and for leading engagement with key government stakeholders and regulators. Prior to joining TSA Peter was Safety, Commercial and Projects Director at UK Petroleum Industry Association. Peter was a pivotal member of the Buncefield Standards Task Group, the joint industry and regulator body responsible for improving safety in the fuel storage sector. His early career was at ABB as the Regulatory Compliance Manager.

Ian Peter, welcome. Thank you for chatting to me. I’m looking to encourage and promote process safety, particularly with new engineers and people new to process safety so that they see it as an important aspect of their career. I invited you to take part because you’ve been very influential to me. We walked a very dodgy path together following the Buncefield major accident to get industry and

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what brought you to be one of the major influences in UK health and safety high hazard sector? How did you end up here?

Peter A key role in risk management was not what I was expecting. I started out with ABB, very large Swiss/ Swedish engineering company as an automation engineer designing control systems. That’s really where it started, because I was designing control and safety systems for highly regulated industries. Most of my work was in the pharmaceutical sector, but also nuclear - working on many projects at Sellafield. So, there was always this idea of a very detailed commitment to understand the processes to design the software to ensure that we built in inherent safety. And that was where I expected to be now, but then the Buncefield event happened. I had the opportunity to work for a Trade Association, the UK Petroleum Industry Association, UKPIA, to represent the interests of downstream oil, primarily the refineries and a number of terminals. At the time

Ian Travers Limited www.iantravers.co.uk

the sector knew they needed to do more on process safety to implement the findings from the Buncefield Standards Task Group. That’s really why I made the switch. But did I expect to be here? No!

Ian When you were doing that complex technical work with ABB, what was your mindset? Was it that this has got to be right, because there’s no room for error or there could be a catastrophe?

Peter It is very influential. I have always been one of those folks that like things to be written down, very clear and unambiguously. That has really driven me to be noticeably clear about the way in which process safety systems and information should work. The reasons underpinning control system design and guidelines need to be accessible and easily understood. If people understand what the difficulties are, or the challenges associated with a particular process or environment, the more likely it will sink in and they will understand the need for control.

Ian What excites you about your work?

Peter It’s bringing together people from different backgrounds, companies,

and sectors to find common solutions to problems. There are very few problems in our industries that aren’t fixable. It just takes time and commitment from all those involved to try and find a good workable solution. The excitement comes from when you find those solutions, particularly if they are simple, easy to understand and to implement. We have an amazing capacity to unnecessarily overcomplicate safety.

Ian In the last 10 or 15 years, what do you consider the most important improvements in risk management which delivered on the ground benefits?

Ian Does your voice get heard, and are the views of industry taken seriously?

Peter Yes, anyone who’s involved in these discussions, and the work that goes on as part of those discussions must be prepared to put in the effort. When businesses, regulators or trade unions and other stakeholders, see individuals and organisations putting effort into genuinely trying to improve, people do take notice. It would be different if all we did was wave the red flag and complain about everything. I’m pretty sure that regulators know we will be the first to put our hat in the ring to work on guidance development, data gathering or analytics for our sector.

Peter It’s this concept of greater collaboration and communication between businesses, but also with regulators. I don’t think that we had the same relationship with our regulators 15 years ago as we do today. There are peaks and troughs, but we have a far, far more collaborative approach. It isn’t adversarial, either with a regulator or between businesses within a particular sector. There’s a willingness to try and work more closely together to solve some of the problems that we share and a realisation that, anything that happens to one is going to impact us all. Which is clearly what we saw from Buncefield and many other incidents before that.

Ian Do you see a similar collaborative approach outside the UK across Europe?

Peter We have a unique and excellent model here in the UK. I talk to my European colleagues regularly about process safety. I don’t see the same approach and there is far more prescription across Europe. An approach that, provided you follow the standards and tick all the boxes, then that’s all you need to do. There doesn’t seem to be the concept that you need to think out of the box about what could go wrong. I

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think that’s changing slowly. But it is a slow change, even convincing my European colleagues to start sharing common process safety performance indicators has been a challenge that I’ve been battling for five, six years now. And we’ve still not achieved it.

Ian Building on that, do you find companies that operate both in the UK and across Europe can behave in those different modes? Does that influence how they interact with the regulator as well? For instance, more open and connected in the UK, but more circumspect and cautious when talking to their local European regulator?

Peter They will adopt the attitude that’s demanded by the regulator in that geographical region. However, with respect to process safety programmes, and process safety management within those organisations, they tend to adopt a consistent model and standards across all their business areas, regardless of the country they are operating in. From my experience that’s the UK model.

Ian How do you think regulators could improve both in the UK and elsewhere?

Peter Two words, clarity, and consistency. Therefore, I’m a big supporter of initiatives such as the UK Chemical and Downstream Oil Industries Forum, CDOIF. It’s one mechanism that we all have to try and provide that consistency and clarity. We don’t always get it right, but it really does promote understanding between both regulators and duty holders. The regulators have a difficult job which is becoming increasingly more difficult with increased responsibilities such as UK REACH and acting as the new Building Safety regulator. This is a huge draw on resources and expertise. That is why working more collaboratively with industry and other stakeholders is the right way to go.

rely on third parties and consultants, there is no problem with that, but they still have a responsibility for the outcome and approach. This comes back to my point about our capacity to overcomplicate things and why we need to simplify when it’s appropriate. Many of these topics are not difficult, and they shouldn’t be. But unfortunately, sometimes people like to overplay what some of these things mean. We use far too much jargon when we just want to say a simple thing.

Put the shoe on the other foot. What do your colleagues in industry get wrong?

Also, regulators need to understand the challenges businesses face within specialist topics. It’s fantastic having a specialist Inspector going to a site looking in great depth at say functional safety. But inspectors need to take a broad view as well in terms of what’s actually important at a facility in managing the risk appropriately. That may not be a line by line understanding of for instance, IEC 615 11.

Peter

Ian

I see an ever-increasing reliance on third parties and consultants, without sometimes the necessary background knowledge to act as an intelligent customer, for a whole series of important issues such as functional safety, cyber security, human factors. Companies may not have the expertise in-house, they

What’s your big fix – what would you like to see improved?

Ian

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Peter I would like greater recognition by Government that our ways of working and management of risk is something that we should be proud of and that UK Government actively

encourages. I think that would provide the incentive for far more people to become more engaged.

query. The more that we learn to do that, the better we will be at working closely with people.

Ian

Let’s move off the technical issues and share something about you as an individual. What are your hobbies?

What do you think the kind of big advances are going to be in risk management and risk thinking in the next 10 years?

Peter Fortunately, I’m standing in front of my whisky collection. I’m very much into Japanese whisky at the moment. I also still like my cars, my motor racing, of course my dogs and my secret hobby tropical fish! I’ve always admired my dad who’s no longer with us. He was head of instrumentation and control at British Gas. I always remember he had the same outlook as me, which is to make things as simple as you can and try and communicate things as clearly and concisely as you can. I try and live by those rules.

What advice would you give to yourself aged 18?

line experience can influence safety within organisations at all levels.

Peter More and more automation and artificial intelligence, including augmented reality in training and competency. The Coronavirus pandemic has accelerated this trend. There’s no reason why this shouldn’t be. The key point is being an intelligent customer for this technology. If you really don’t understand your fundamental risks, that’s a big worry - I don’t have an issue with automation providing we don’t relinquish our responsibilities to manage those risks.

Ian Ian

recognise that front line workers are just as important, if not more important, than the folks that are designing plant and processes in the office. I hope we are going to see apprenticeships as being far more important in the future. I’d like to see a future in which people with front

Any parting thoughts or insights that I should have maybe raised that you?

Ian Peter thank you. As I anticipated some fantastic insights and thoughts from you. When it comes to process safety, consistency and clarity are key.

Author Ian Travers is a world expert on process safety management, leadership and the establishment and implementation of key performance indicators for major hazard industries. He also holds the Institute of Chemical Engineers’ Franklin Medal for his outstanding contribution to Process Safety. https://www.iantravers.co.uk/

Peter Peter Listen more. There are periods in your life, whether that’s in your personal life or in your business life, when you just need to shut up and listen and think about the response you’re going to give to a particular question or a

We need to have a conversation about the people. We often focus on graduates. When it comes down to safety on the ground, we rely on people who don’t have degrees, but who are nevertheless vital to safe operations. Sometimes we need to

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I S O L AT I N G T H E BENEFITS OF ISO 9001 Service they are working with a trusted quality-conscious company.

Reynolds Training Services have achieved the prestigious ISO 9001:2015 Quality Management Systems certiﬁcation.

t Reynolds Training Services, we are delighted that we have achieved the prestigious ISO 9001:2015 Quality Management Systems certification.

John Reynolds, founder and Managing Director of Reynolds Training, acknowledges: “This accolade is a testimony to the hard work done by our team, and it is a reﬂection of our commitment to continually strive to improve standards. We do this in our own business and, through the courses we oﬀer, we can help make real improvements in standards throughout industry. “We pride ourselves on the quality of development and delivery of our services, all of which has been reinforced by the rigorous assessment process to achieve ISO 9001:2015. Earning and maintaining this not only underpins our quality performance but also our desire to continually improve.” This certification assures customers and partners that when they are working with Reynolds Training

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1 About the ISO 9001:2015 Quality Management Systems certiﬁcation ISO 9001 is the internationally recognized Quality Management System (QMS) standard that is designed to be a powerful business improvement tool. This mark of trust is the world’s quality system of choice with over a million organisations around the globe improving their operations with this management system standard. At Reynolds Training, our ISO 9001 certification helps us to continually monitor and manage quality and identify areas for improvement. As a company, we continue to evolve and adapt in a changing world. We have also striven to continually improve our training delivery, including the assets and resources we utilise. This accolade is a milestone for us, demonstrating our commitment to growth and ongoing improvement, as well as showcasing our assurance that our courses are operating to the highest quality standard.

ISO 9001 demonstrates compliance to internationally recognised standards and is a clear signal to our clients, delegates and stakeholders of our long-term growth and improvement.

2 Continually improve, streamline operations and reduce costs Embedding ISO has driven us to better develop our wider business and management processes and to link this to continuous improvement - which will, ultimately, have farreaching benefits for our learners and their employers.

One of the fundamental aspects of ISO 9001 is focussing on the customers and clients, understanding their requirements and exceeding their expectations. This is reinforced by a continual review and improvement process. This accreditation of our Quality Management Systems endorses the efficiency, productivity and commitment to continual improvement we provide for our clients.

Alongside our ISO accreditation, we have developed (and continue to develop) structured processes to manage career progression

Our learners and their employers will continue to benefit from the quality learning we have developed.

3 Reduce risk

The business benefits of this are selfevident: a well-trained workforce with great career prospects is a happy workforce and a happy workforce is far more engaged, motivated and productive. Everyone wins!

Planning for, mitigating against and managing risk is something that

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we, at Reynolds Training, are passionate about and instil in all of our learners. We believe that all employees - from the management suite to the shop floor - should feel that it is their responsibility to be vigilant about risk. Identifying, preparing-for and avoiding mistakes, accidents (and even surprises) is an essential part of running any successful business, none more so than businesses in the high hazard sector where both process and personal safety are paramount. As the ISO says in its guidelines of requirements for this QMS: “Risk-

based thinking is essential for achieving an eﬀective Quality Management System”.

4 International prestige One of the principal benefits from achieving and maintaining this trust mark is the prestige it grants an organisation. As the leading training provider for the Bulk Liquid Storage Sector, this seal of approval will enable us to drive forward into new markets, working productively with new partners and clients, not only in the UK but around the world; providing them with the benefits of our integrated package of training and competence assessment.

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News

Reynolds Training Services achieves IChemE level 3 apprenticeship qualification approval

TSA’s associate member Reynolds Training Services has had its qualification approved by the Institution of Chemical Engineers (IChemE) – the first level 3 diploma to be approved by IChemE. Approval has been awarded for Reynolds Training Services’ sector leading Bulk Storage Operator Technician level 3 diploma, which is part of a twoyear apprenticeship offering a wider focus on process and occupational safety, human factors and emergency response, aligning these elements with technical operations. The programme is a mix of vocational and academic learning delivered in conjunction with HETA (Humberside Engineering Training Association) at Reynolds Training Services who are based at the CATCH Training facility in Stallingborough, North East Lincolnshire. An apprenticeship is made up of a qualification and a programme of vocational experience. IChemE is licensed by the

Engineering Council to approve either or both of these parts for colleges and training providers delivering an engineering apprenticeship. Having this qualification approved by IChemE provides a new route to technical recognition for the sector, meaning that apprentices can go on to the professional Engineering Technician (EngTech) qualification. The IChemE assessors commended Reynolds Training Services for their outstanding simulation facility of a full-scale tank farm that offers a realistic, professional environment and which provides trainee engineers ample work-based experience in real-world problem-solving and risk assessment for major accident hazards. The assessors also praised the course leaders for teaching the process safety fundamentals at an exceptionally high standard. To know more, visit reynoldstraining.com/

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TSA offers a range of membership beneﬁts, including weekly political and media updates sent directly to your inbox.

Join the voice of the bulk liquid storage sector TSA champions the UK’s bulk liquid storage sector and its role in supporting growth and prosperity. We have several membership levels available for bulk liquid terminals, distribution terminals and hubs, as well as equipment and service suppliers. Join us. Choose your membership at www.tankstorage.org.uk/join-us

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To receive all the latest information, news and guidance, visit www.tankstorage.org.uk/join-us

TSA

Tank Storage Associa on

To ﬁnd out more, write to info@tankstorage.org.uk

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TSA

Tank Storage Associa on

The voice of the bulk liquid storage sector

Tank Storage Association Devonshire Business Centre Works Road Letchworth Garden City Herts. SG6 1GJ United Kingdom www.tankstorage.org.uk

T. +44 (0)1462 488232 Follow us

TS A Insight Magazine - Issue 6

info@tankstorage.org.uk

GREEN INSIDE SUSTAINABILITY • SCHÜTZ HAS TAKEN A BIG STEP FORWARD IN THE USE OF RECYCLATE IN ITS NEW GREEN LAYER IBCS AND DRUMS, OFFERING UN APPROVAL AS PART OF THE DEAL THE IDEA OF re-use and recycling has long been a part of the composite intermediate bulk container (IBC) sector, with many of the leading manufacturers offering global collection and remanufacturing services. One

are produced with 40 per cent high-quality plastic recyclate. This material is generated by Schütz through its worldwide collection and reconditioning programme, the Schütz Ticket Service. Another key feature is that the IBCs of

of those manufacturers, Schütz, has now taken the idea a step further with the launch of its Green Layer IBCs and plastics drums. In the new Schütz Green Layer versions, the eco-balance of both types of packaging has been taken to a new level. In the multi-layer extrusion process, the IBC inner bottles and drum bodies

the Green Layer series also have UN approval.

HCB MONTHLY | JULY/AUGUST 2021

 SCHÜTZ IS LEADING THE WAY IN THE USE OF RECYCLATE IN ITS PACKAGINGS, IMPROVING THE ENVIRONMENTAL FOOTPRINT OF ITS OWN OPERATIONS AND THOSE OF ITS CUSTOMERS

THERE AND BACK Multiple use and recycling, the two factors that sit at the heart of the circular economy, have long been a core concept of Schütz composite IBCs. The entire lifecycle of the packaging is geared towards ensuring maximum environmental friendliness. During reconditioning as part of the Schütz Ticket Service, the inner bottles of collected IBCs are removed from the steel grid and treated in a complex recycling process during which they are ground, cleaned and finally regranulated. Special degassing extruders ensure a low-odour, homogeneous quality. The company uses the HDPE recyclate obtained in a closed cycle: 100 per cent flows back into the internal production of plastic packaging components, including corner protectors and plastic pallets. Depending on the type of pallet, the proportion of recycled material in a remanufactured IBC is between 36 and 55 per cent of the plastics content. With the new Green Layer IBCs, Schütz has increased this proportion even further, taking resource preservation to a new level. For these containers in particular, high-quality recycled material is also used for the production of the inner bottle. The IBC container in the innovative Green Layer design contains 40 per cent recycled material alone. This corresponds to an additional CO2 saving of at least 8 kg per IBC. The recycled HDPE is extruded only into the middle layer of the container: the inner and outer layers are made of virgin HDPE material. This way, Schütz ensures that both the filling product and the environment only come into direct contact with virgin material, making a significant contribution to protecting the quality of the filling product. Equipped with a full-plastic pallet, the total content of recycled plastic in this particular IBC model is as high as 73 per cent. Schütz has also taken care over the design of the new models; the outer layer is completely black, avoiding the colour variations that can occur when recycled material is used. Transparent view stripes allow users to monitor the filling level in the IBC at all times. Schütz also uses multi-layer extrusion for the production of drums, combining

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maximum safety with a maximum content of recycled plastic. The 200-litre F1 tight-head drum and the S-DS1 open-head drums in sizes from 30 to 220 litres are also produced as Green Layer models using the three-layer extrusion blow-moulding process with recycled HDPE in the middle layer. The recycled content here accounts for 40 per cent of the drum body and the entire product range has dangerous goods approvals. TWO-WAY STREET Schütz’s ability to improve the environmental performance of its plastics packagings also supports its customers in achieving their sustainability goals. The new Green Layer packagings also meet future legal requirements for the use of recyclate, defined under the European Green Deal and the EU’s Action Plan for the Circular Economy. While Schütz can help its customers meet their current and future sustainability

obligations, the company also stresses that those companies using its products have an important part to play in the system. In order to ensure a constant supply of IBCs and drums with recycled plastic material, Schütz emphasises how important it is for customers and returners of used industrial packaging to actively cooperate. A corresponding supply security can only be guaranteed if there is a sufficient supply of recyclate from the Schütz Ticket Service. The market launch of the Green Layer products therefore requires close coordination with customers and is initially limited to Europe, where pilot projects have been successfully launched. Future expansion into other regions is possible and intended thanks to the global production network of Schütz with state-of-the-art multilayer extrusion blow moulding equipment. www.schuetz.net

GOOD TO GO RESULTS • GREIF HAS STARTED 2021 WELL, REPORTING RISING DEMAND FOR INDUSTRIAL PACKAGINGS AND IBCS IN PARTICULAR, ALONG WITH AN EXPANDED FOCUS ON SUSTAINABILITY GREIF HAS REPORTED net income of $149.8m for its second fiscal quarter, to the end of March 2021, boosted by a significant book gain on the sale of a large tract of woodland; on an adjusted basis, net income rose by 19 per cent compared to the same period a year earlier, although adjusted EBITDA was down by $4.7m at $176.6m. “Greif delivered a strong second quarter, with solid results across the company and meaningful progress against our strategy,” says Pete Watson, Greif’s president and CEO. “In addition to strong underlying business performance that drove improved earnings and free cash flow, we enhanced colleague

and achieved a notable reduction in our leverage.” Looking ahead, Watson says Greif is now “well positioned to benefit from a growing global economy”. One notable feature of the quarter was production of intermediate bulk containers (IBCs), which reached record volumes in response to strong market demand. In Greif’s global industrial packaging segment, which combines the former Rigid Industrial Packaging & Services and Flexible Products & Services segments, net sales rose by $128.0m to $798.0m, primarily in response to higher volumes as well as higher average sale prices, taking account of increased raw

engagement and customer service levels, advanced our commitment to sustainability

material costs. Gross profit and adjusted EBITDA were also well up.

 GREIF IS MAKING GREAT STRIDES IN IMPROVING ITS OWN SUSTAINABILITY AND THAT OF ITS CUSTOMERS

HCB MONTHLY | JULY/AUGUST 2021

RECYCLED IN RUSSIA In other news, Greif has begun manufacturing GCube EcoBalance™ IBCs at its plant in Kaluga, Russia. The reconditioned IBCs

feature a new bottle with a virgin HDPE inner layer and an outer layer made from a mix of virgin HDPE and post-consumer resin (PCR) derived from recycled used IBCs from a partner facility. GCube EcoBalance IBCs have been made in Italy since late 2019 and the production at Kaluga is the second such line; Greif is now planning to produce them in Germany and Spain and further expansions are being lined up elsewhere in the world. “This was a very rewarding project for the Greif Russia team, and we are pleased that this product is now commercially available in our region,” says Konstantin Chetverikov, quality and technology manager for IBCs at Greif Russia. “Being able to generate our own source of PCR from IBC bottles that might otherwise end up in landfill means we can support customers in achieving their sustainability goals by decreasing raw material consumption and reducing CO2 emission into the atmosphere. It is also a significant step towards advancing our own circular economy principles.” The GCube EcoBalance IBC is part of a broader EcoBalance line that includes plastics drums and other containers made using PCR. These products help support many of Greif’s customers – and Greif itself – in achieving their sustainability goals, including reducing carbon emissions and energy consumption and diverting waste from landfill. www.greif.com

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BACK AND FORTH CIRCULAR ECONOMY • THE IBC CONCEPT LENDS ITSELF TO RE-USE AND REMANUFACTURING. SCHOELLER ALLIBERT EXPLORES THE ROLE OF RETURNABLE PLASTICS PACKAGING IN THE CHEMICALS SECTOR “THE CHEMICAL SECTOR, which relies on effective stockholding and volume, is only as effective as its weakest link,” notes Noel Lynott, country sales manager at Schoeller Allibert UK. “Investigating the unique needs of our customers in the chemical supply industry, there is huge opportunity for businesses to rethink established norms of logistics. For example, many businesses are still relying on wooden dollies, pallets and containers despite rapidly rising costs. Others are setting strong sustainability goals in terms of chemical sourcing and waste disposal but are not thinking about their handling and storage processes to support their sustainability strategy.” Scholler Allibert, which has long been in the business of designing and developing sustainable containers, dollies and peripherals for the chemical supply chain, is well placed to play a part in the move away from traditional packagings thanks to its birds-eye view of the chemicals sector and

its consequent awareness of trends that help its product development process. “It’s no secret that the chemical sector is under rapidly growing pressure to deliver in volume, margin and sustainability,” Lynott adds. “At Schoeller Allibert UK, we have developed a range of containers specifically designed to meet the needs of chemical suppliers, and there’s never been a better time to explore the possibilities. The chemical sector is ready for a returnable and recoverable revolution in the same way that food processors and retailers have embraced it.” HERE’S THE SOLUTION “Our ChemiFlow® IBC is a prime example of exactly where handling, storage and logistics can play into a wider sustainability and

 IT IS A SIMPLE MATTER TO SWITCH TO RETURNABLE PACKAGING, SCHOELLER ALLIBERT SAYS

process strategy,” Lynott continues. “Built with safety, security and traceability at the forefront, the UN-approved 100 per cent plastic containers integrate seamlessly with digital tracking and automation tools. Handling safety is, of course, a top priority for the chemical sector, and we have introduced a number of innovations that enhance operator safety, reduce waste from spillages and make logistical transparency simple and effective.” The business has also developed Combo Excelsior®, a foldable IBC designed for international logistics. The innovative design can be erected and folded by a single operator with simple setup and an efficient discharge zone that connects to every common valve on the market. Combo Excelsior offers chemical suppliers exemplary strength, durability and space efficiency; its double wall structure enables a 1,500 kg unit load, and a stacking load of 8,000 kg (four stacked on one). “The chemical sector is currently aiming to match speed and accuracy with sustainability for a real competitive edge,” Lynott concludes. “Returnable packaging is a solution that for many might fly under the radar due to how deceptively simple the concept is. By switching outdated handling equipment and containers for durable plastic that’s hard to break but easy to repair, chemical suppliers aren’t just getting longer lifespans for equipment – they’re getting a more effective and sustainable supply chain.” www.schoellerallibert.com

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NEWS BULLETIN

INDUSTRIAL PACKAGING

MAUSER’S ENVIRONMENTAL MOVES

Mauser Packaging Solutions, through its joint venture NCG-Maider, has acquired Global Tank, expanding its packaging portfolio and services in the Italian market. Global Tank operates a reconditioning and washing plant near Milan, handling plastics and steel drums and IBCs and recycling HDPE plastics. Alfonso Albanese and Carmela Cecere, the former owners of Global Tank, will join Mauser’s management team in Italy. “We are confident that the strengths of both companies are a great benefit for both partners and our customers,” Albanese says. “This unification will maximise our advantage in the market as we share best practices and know how. We are very proud to further expand our presence in the Italian market and for even better servicing of our customers.” “This acquisition expands on our footprint in Italy and will allow us to better serve our

HCB MONTHLY | JULY/AUGUST 2021

customer base for collections and supply of reconditioned packaging,” adds Michael Steubing, president of International Packaging at Mauser. “The unification of both companies’ strengths and synergies will prove to be a great benefit for our partners and customers.” Mauser Packaging Solutions is also making moves in terms of sustainability. Its plant in Gebze, Turkey has received a Zero Waste Certificate, recognising its efforts to reduce, prevent and recycle waste. The certificate was awarded by Turkey’s Ministry of Environment and Urban Planning under the Zero Waste regulation, introduced in 2019 with the goal of protecting the environment, human health, and natural resources. The waste management approach focuses on the prevention of waste, efficient usage of resources, establishment of an effective collection system, and recycling of waste. In order to receive this certificate, the Gebze facility was evaluated by the Provincial

Directorate of Environment and Urbanisation to ensure that all criteria for zero waste were met. The facility provided evidence of waste classification by type, proper waste removal, and implementation of employee environmental trainings, among other items. Mauser’s plants at Suzano and Taubate in Brazil have meanwhile been similarly recognised through the award of the 2020 ‘Outstanding Environmental Preservation’ certificate and Green Sea from the São Paulo-based Jornal do Meio Ambiente. The award is given to those companies with up-to-date environmental licences, zero environmental infractions and superior achievement in preserving the environment; Mauser says it is the only industrial packaging company to have been recognised in this way. www.mauserpackaging.com MJ CONSOLIDATES IN DENMARK

MJ Plastics has acquired Dansk Emballage, which reconditions IBCs, drums and jerrycans for the food and chemical industries. MJ already owns Emballage Vaskeriet and this deal makes it the largest supplier of recycled industrial packagings in Denmark. Brian Lind, former owner of Dansk Emballage, will remain with the company as factory manager. “I am very excited to welcome Brian Lind and Dansk Emballage to our team. We immediately begin the work of jointly implementing our strategy of delivering sustainable packaging solutions to our customers,” says Martin Schack Staffeldt, CEO and co-owner of MJ Plastics (left). “The combination of our strengths will create great value for our customers. We feel obliged to continue to expand our presence in the Danish market and to provide the best customer service and offer the market’s most comprehensive product range.” mjplastics.dk

INDUSTRIAL PACKAGING 69

SMALL STUFF FROM SCHÜTZ

Schütz has expanded its Ecobulk IBC range with the launch of the 560-litre Ecobulk MX 560. The new unit has a lower height than standard IBCs and is aimed at applications where smaller containers are an advantage, while retaining the high levels of quality seen on the rest of the Ecobulk range. The MX 560 combines optimum filling volume with a compact design on Schütz’s proven bottom group, which is the same as the one used on MX IBCs with 820-, 1,000- and 1,250-litre capacities, making them fully compatible. Schütz says the MX 560 is easy to handle in day-to-day operations, especially in comparison with metal containers or drums. “With its reduced capacity and optimum footprint, the new Schütz IBC offers lower capital tie-up and shorter storage times for products with a slow turnover,” the company adds. www.schuetz.net GREIF MOVES ONWARDS

Greif has expanded its flexible IBC range with the introduction of the new MAPGuard line, enhanced with modified atmosphere packaging (MAP) technology. Developed to protect the integrity of the products inside, MAPGuard is a recommended solution for producers, processors and distributors of dried food, ground nuts, bio/organic foods, seeds and chemicals where issues such as mould, insect infestation and rancidity can occur during storage and transport. The MAPGuard FIBCs are designed to operate with a range of special liners and feature a rapid gas flushing and vacuuming system enabling customers to modify the internal atmosphere of the FIBC. “Typically used in consumer and small-size packaging and due to its technical complexity, the MAP technology was implemented in industrial (FIBC) packaging to a much lesser degree,” explains Juan Bernal, global product manager at Greif. “As a result, Greif initiated an extensive research project followed by rigorous testing using Greif ’s technical know-how and expertise, to ultimately create the MAPGuard product line; a simple to use and reliable solution.”

Greif says the MAPGuard FIBC can help extend and control product shelf life, while being able to handle and transport large volumes of product. It is also equipped with a safe and easy-to-use atmospheric test point and is available through Greif ’s well established network of representatives. Meanwhile, Greif has been working on its executive succession plan. Ole Rosgaard, currently senior-vice president of Greif and group president of its Global Industrial Packaging division, has been elected to succeed Pete Watson as president/CEO as from 1 February 2022. Rosgaard will serve as COO until then. Watson is to retire and will take the role of executive chairman, replacing Michael Gasser, who has served as chairman since 1994 but is not standing for re-election. “I am excited and humbled by this opportunity, and I thank the Board for its confidence in me,” Rosgaard says. “I have worked closely with Pete the last six years and share his enthusiasm about our company’s bright future. I look forward to leading Greif ’s incredibly talented and diverse global team toward our vision of becoming the best

performing customer service company in the world as we continue to grow and create value for our customers and shareholders.” Watson has spent six years as president/ CEO of Greif; honouring his record, Gasser says: “Pete exemplifies servant leadership and embodies the values of The Greif Way. He has driven a laser focus on customer service excellence, powered by a team-first approach, throughout the enterprise. Under his leadership, Greif successfully completed an in-depth transformation initiative enhancing the Company’s performance; delivered organic growth through strategic investments in the Global Industrial Packaging and Paper Packaging businesses; successfully acquired and integrated Caraustar Industries; and advanced our sustainability strategy. In summary, Pete has led with humility, authenticity and care for the well-being of our colleagues, our customers and our planet. We thank Pete for his outstanding leadership over his twenty-two year career at Greif and for his tireless contributions and accomplishments the last six years.” www.greif.com

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CLOSE UP REPORT • THE GLOBAL PANDEMIC HAS AFFECTED THE PETROCHEMICAL SUPPLY CHAIN ALL AROUND THE WORLD. GPCA’S LEARNINGS ARE RELEVANT TO ALL PLAYERS THE COVID-19 PANDEMIC of the past 15 months has demonstrated the acute importance of collaboration to build more agile, resilient and responsive supply chains. That was the message given loud and clear by industry leaders speaking at the 12th Gulf Petrochemicals and Chemicals Association (GPCA) Supply Chain Conference, which was held virtually this past 26 and 27 May. More than 1,300 people attended the event, representing some 450 companies from 62 countries. They heard from senior executives from across the chemical and petrochemical value chain, including logistics service providers and shipping operators, who urged them to capitalise on the lessons learned during the pandemic and act on them in the future, whether that be the need to collaborate more closely with the regulators, their customers and strategic partners, to drive better supply chain visibility and invest in digitisation, to build their workforce capabilities, or to focus on sustainability in the supply chain. In the keynote address to the conference, Hamad Alterkait, chairman of Kuwait-based PIC, encouraged chemical leaders to engage in supply chain collaboration even with their competitors and keep their inventory in close customer proximity to improve their reliability and better serve their end markets. He told attendees at the virtual event: “Regional chemical producers must diversify their supply base even if it means incurring higher costs in order to cushion the impact from any future crisis. Companies must also explore out-of-

 PIC CHAIRMAN HAMAD ALTERKAIT WAS FIRM THAT THE CHEMICAL INDUSTRY MUST LOOK AT NEW WAYS OF WORKING

HCB MONTHLY | JULY/AUGUST 2021

the-box supply chain solutions, using different scenarios, which may aid in addressing important challenges at a critical time.” Echoing Alterkait’s remarks on the importance of collaboration were Hosam Al-Zamil, vice-president of global supply chain

“REGIONAL CHEMICAL PRODUCERS MUST DIVERSIFY THEIR SUPPLY BASE IN ORDER TO CUSHION THE IMPACT FROM ANY FUTURE CRISIS”

at SABIC; Ahmed Abdulla Al-Salahi, CCO of Q-Chem; and Ahmed Al-Katheeri, senior vice-president of supply chain management at Borouge. In the conference’s inaugural panel on the future of chemical supply chains they agreed that the Covid-19 pandemic was a test to the resilience of chemical supply chains, as it demonstrated that the world is one global community. “The future will not be the moving of our products; it will be the moving of data which will help enable responsiveness and agility and drive customer centricity to stay competitive. However, we cannot achieve this by working in silos. The chemical industry is just one part of the supply chain and we must work together to build a more resilient future,” Al-Katheeri stressed. RESULTS CONFIRMED A recent GPCA survey confirms the insights shared by speakers. It found that chemical supply chain operations have been the single most impacted business function within downstream organisations in the Gulf Cooperation Council (GCC) countries in the past 15 months as a result of the Covid-19 pandemic. In the path to recovery, chemical companies must focus on supply chain digitisation, sustainability, trade facilitation and regulatory engagement. Within these trends, carbon neutrality, Artificial Intelligence (AI) and Machine Learning (ML) will be the key segments to focus on to drive the greatest impact on businesses’ supply chains today, the survey found. Dr Abdulwahab Al-Sadoun, secretary general of GPCA, comments: “I was pleased to welcome the regional and global chemical industry to the virtual edition of the 12th GPCA Supply Chain Conference and gain first-hand insight into the challenges associated with the pandemic on their chemical supply chain and operations. The audience was left with a message of positivity on what’s to come next and provided with a range of practical tips on how to address the uncertainty and any new crisis in the future. I hope delegates enjoyed attending the event and thank all our sponsors and partners for making this edition possible.” www.gpcasupplychain.com

COURSES & CONFERENCES 71

CONFERENCE DIARY The ongoing global Covid-19 pandemic has caused 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.

AUGUST ChemEdge August 10-13, San Antonio Conference for the North American chemical distribution sector www.nacd.com/education-meetings/ meetings/2021-chemedge/ PPC Fall Meeting August 23-25, Lake Tahoe, CA Bi-annual meeting of the Petroleum Packaging Council www.ppcouncil.org/upcoming-meetings.php CVSA Annual Conference August 29-Sept 2, Wilmington, DE Annual meeting of the Commercial Vehicle Safety Alliance www.cvsa.org/eventpage/events/cvsaannual-conference-and-exhibition/ CV Show August 31-Sept 2, Birmingham Annual commercial vehicle exhibition https://cvshow.com/ NISTM August 31-Sept 2, Orlando National Institute for Storage Tank Management’s 23rd annual international aboveground storage tank conference and trade show www.nistm.org

SEPTEMBER Intermodal South America September 1-3, São Paulo 26th annual international exhibition on intermodal logistics, cargo transport and international trade www.intermodal.com.br/en Megatrans September 8-10, Melbourne Biennial trade show for the freight sector in Australia and internationally www.megatrans.com.au International Transport & Logistics Week (SITL) September 13-15, Paris Annual transport event, including hybrid and in-person conferences and workshops www.sitl.eu/en-gb.html

Labelmaster DG Symposium September 13-24, virtual 16th annual Dangerous Goods Symposium hosted by Labelmaster’s DG Exchange www.labelmaster.com/symposium ChemUK 2021 September 15-16, Birmingham Supply chain expo and conference for the UK chemical industry www.chemicalukexpo.com Hazardous Areas Conference September 15-16, Brisbane Eighth conference on operations and equipment in hazardous areas www.events.idc-online.com/upcomingconferences/hazardous-areas-conferencebrisbane-australia Gastech 2021 September 21-23, Dubai International conference and trade show for the LNG and LPG industries www.gastechevent.com 2+2 Logistics and Innovation September 21-24, 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/ Hazards Asia Pacific September 21-22, virtual Annual process safety conference www.icheme.org/career/events/hazards-asiapacific/ Virginia Hazmat Conference September 21-24, Newport News 38th annual networking and training meeting sponsored by the Virginia Association of Hazardous Materials Response Specialists www.virginiahazmat.org/annual-hazmatconference/ TSA Conference & Exhibition September 23, Coventry 20th annual meeting of the UK Tank Storage Association www.tankstorage.org.uk/conference-exhibition/ Liquid Gas Europe Congress September 28-30, online

Europe’s biggest event for the regional and global LPG sectors www.liquidgaseurope.eu/lge-e-congress FachPack 2021 September 28-31, Nuremberg Biennial exhibition on the packaging process chain www.fachpack.de/en DGAC Members Conference September 29-30, virtual Annual conference of the Dangerous Goods Advisory Council www.dgac.org/dgac-meetings-0

OCTOBER ILTA October 4-6, Houston 40th annual operating conference and trade show of the International Liquid Terminals Association www.ilta.org EPCA Annual Meeting October 5-7, virtual 55th annual meeting of the European Petrochemical Association www.epca.eu AFPM Security Conference October 5-6, Houston Conference on security at fuel refining and petrochemical plants www.afpm.org/events/292d4a0000075d Hazardex 2021 & PPTEx October 6-7, Harrogate Conference and exhibition on hazardous area operations and personal protective technology www.hazardex-event.co.uk ECTA Responsible Care Workshop October 7, Brussels Update on Responsible Care implementation in European chemical transport https://ecta.com/product/ecta-responsiblecare-training-workshop-2021/ IATA World Cargo Symposium October 12-14, Istanbul 14th global conference on air cargo www.iata.org/events/wcs/pages/index.aspx

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GET TOGETHER PREVIEW • REGISTRATION IS NOW OPEN FOR CHEMUK 2021, THE UK’S NATIONAL EXPO FOR THE BROAD CHEMICAL SECTOR, DUE TO TAKE PLACE ON 15 AND 16 SEPTEMBER CHEMUK 2021 IS the only large-scale trade show that brings together the UK’s chemical processing, product formulation and chemicalusing industries and will this year offer a much-needed two-day opportunity for business networking, intelligence gathering, innovation showcasing and supply chain sourcing. Following the show’s successful launch in Harrogate in 2019, event organiser UK Industry Events took the decision to move the show to the largest industrial event space in the UK, the National Exhibition Centre (NEC) just outside Birmingham, to facilitate the huge industry demand. Founder and managing director Ian Stone says: “ChemUK has doubled in size in terms of the number of exhibitors and stands. We had 170 in 2019 and this year we’ve got 350-plus. What you can draw from that is a massive appetite among suppliers and partners in the chemical industry to be part of ChemUK.” ChemUK 2021 will provide visitors with a diverse and impressive showcase of the latest

developments in plant, equipment, technology, materials and services that can help the industry drive product innovation, plant and process performance, supply chain fulfilment, and safety and compliance levels. As an illustration, the organisers offer some of the highest profile exhibitors this year, including ABB, Anton Paar, Atlas Copco, Brenntag UK, BTC UK, Busch (UK) Ltd, Calgavin, Dachser, DEKRA UK, Edwards Vacuum, Emerson, Endress+Hauser, George Fischer Sales, Grundfos Pumps, HRS Heat Exchangers, IMCD, Labtex, Monarch Chemicals, Siemens, Tradebe Chemicals, VEGA Controls, Univar Solutions, Siemens and many, many more. LET’S GET TALKING The ChemUK expo is accompanied by a wide-ranging speaker programme, with more than 150 contributors offering more than 40 hours of free-to-attend sessions. They will offer expert intelligence, case studies, best practice and technological insights to inspire

attendees and assist with investment decisions in taking operations to the next level. The conference sessions will feature contributions from more than 25 trade and technical organisations, four government departments and agencies, several centres of research and technology transfer, and an exciting cross-section of leading chemical suppliers, technology partners, and specialist service providers and consultants. In particular, as a gathering for the UK industry, the conference will take a look at the impact of the Brexit process and what it means for the chemical sector, along with wider global pressures and trends, the challenges they present and the opportunities they offer. Among those confirmed to speak are Tim Doggett, recently appointed as chief executive of the Chemical Business Association (CBA), along with its membership manager Dr Karen Harvey; Stephen Elliott, chief executive of the Chemical Industries Association (CIA); and leading executives from BASF UK & Ireland and Brenntag Essentials. An interesting perspective will be given by Dr Richard Daniels, director of the Chemicals Regulation Division at the Health & Safety Executive (HSE), who will look at the challenges and opportunities posed for a chemicals regulator after Brexit. The ChemUK speaker programme, as well as the wider show floor, includes a wealth of downstream chemical user ‘sector-specific’ focus with association and federation keynotes confirmed from the likes of Solvents Industry Association (SIA), British Pest Control Association (BPCA), Paint Research Association (PRA), UK Lubricants Association (UKLA), British Coating Federation (BCF), British Adhesives & Sealants Association (BASA), Cosmetics Cluster UK, Oil & Colour Chemists’ Association (OCCA), Paper Industry Technical Association (PITA) and others. LET’S GET DIGITAL A key theme of this year’s ChemUK will be the transition to digitised operations. A host of top speakers, including a feature panel session, together with leading suppliers and industry partners across the show floor will address

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COURSES & CONFERENCES 73

the digital ‘connected industry’ agenda for the chemicals sector and how it can transition to Industry 4.0 and digitally focused operational models. Attendees will be able to learn more about this topic from some of the exhibitors, including Gambica, Accenture, ABB, Siemens, Yokogawa, AVTPUMP, Emerson Automation Solutions, A3D, Endress+Hauser, Pepperl+Fuchs, VEGA Controls, Univar Solutions, Carbis Loadtec, Samson Controls, MHT Technology, Etatron, TSA, Method Cyber Security, PACT and others. Gambica, the UK Trade Association for Instrumentation, Control, Automation and Laboratory Technology, will host a panel session on the digitisation of the UK process industries, where experts from the world of digitisation and process automation will give their view of the current landscape and what the future holds, along with their estimate of



THE FUTURE IS COMING No event these days can ignore the insistent drive for sustainability and the development of a circular economy, and ChemUK will be no exception. Caroline Raine, associate director

the chemical sector can save the polar bears and turtles”. Other presenters in this session will look at the decarbonisation of industrial clusters, with a case study of the Humber cluster; the role of Responsible Care in the circular economy; and implications for specific industry sectors, including adhesives and paints. That session will be followed by discussions on the transition to bio-based chemicals, which provide one avenue to decarbonisation by moving away from fossil fuel feedstocks. Yorkshire and the Humber’s innovation cluster, BioVale, promotes this new, bio-based economy and helps enterprises profit from its highgrowth, future-proofed business opportunities. As host for this session, BioVale has brought together speakers who represent both academia and industry to explore the current capabilities, successes, opportunities and challenges of transitioning to bio-based chemicals.

where the UK industry sits on that journey. Process innovation, improvement and intensification will also take centre stage, reflecting current pressures to optimise plant efficiencies, improve process quality and energy efficiency, and deliver cost reductions. Discussions will cover data-driven

of the National Chemical Emergency Centre (NCEC), will look at the European Commission’s Chemical Strategy for Sustainability and what it means in practice for the UK’s chemicals sector, while Dr Dana Heldt of the Knowledge Transfer Network (KTN) will challenge attendees to think: “How

This article provides just a brief overview of what attendees can expect from ChemUK 2021 – but there is plenty more. A full speaker listing and exhibitor details can be found on the event’s website, www.chemicalexpo. com, where attendees can also register for a free badge.

COVID RESTRICTIONS MAY WELL MAKE THIS YEAR’S CHEMUK LOOK DIFFERENT TO THE 2019 EVENT BUT IT WILL STILL DELIVER GREAT CONTENT FOR ATTENDEES

manufacturing, pump technology, valve and vacuum solutions, control technologies, heat and mass transfer, mixing and separation technologies and other topics. Speakers for this session will come from the British Valve & Actuator Association (BVAA), Gambica, the Palo Alto Research Center (PARC), the Process Intensification Network (PIN) and other groups.

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INCIDENT LOG ROAD/RAIL/AIR INCIDENTS Date

Location

5/5/21

Vehicle Type

Substance

Details

Source

Satara, road tanker oxygen Maharashtra, India

Road tanker suffered leak of medical oxygen on Pune-Bengaluru NH; tanker appeared to have been overloaded at Navi Mumbai in frantic rush to get oxygen to hospitals treating Covid-19 patients; leak patched

Times of India

5/5/21

Harbanspura, road tanker gasoline Punjab, Pakistan

Road tanker caught fire at filling station in Lahore suburb; fire spread rapidly, consuming several cars, the tanker and the filling station; bystanders fled, with no injuries reported

Urdu Point

6/5/21

Kannur, road tanker LPG Kerala, India

LPG tanker from Mangaluru overturned, leaking gas; fire services sprayed water to prevent ignition; nearby residents urged to evacuate during response; IOC personnel plugged leak, transferred remaining LPG

Times of India

6/5/21

nr Morrison, road tanker unknown Colorado, US

Highway 285 closed for several hours after tank truck overturned; cab detached from trailer, fell into ditch; driver killed in crash; cause of incident and nature of load not specified

CBS

8/5/21

Gill, road tanker LPG Punjab, India

LPG tanker heading for Ludhiana overturned in village after swerving to avoid combine harvester in road; tanker had 16 tonnes LPG but no leak was reported; villagers advised to switch off lights to prevent ignition

Times of India

9/5/21

Dubai, road tanker flammables UAE

Road tanker caught fire after collision with private vehicle on Sheikh Mohammed bin Zayed Road; both vehicles were gutted in blaze; three people suffered minor injuries

MENA FN

10/5/21 Hidcote, road tanker chemicals KZN, South Africa

Road tanker with unidentified flammable chemicals collided with bus on N3 highway; several other vehicles involved; tanker caught fire, which spread to other vehicles; at least 7 people killed, many injured

Times Live

11/5/21 Sabattus, truck explosives Maine, US

Truck carrying blasting explosive was forced into median on I-95 by another vehicle that cut it off; cargo was not impacted by the crash; driver unhurt

15/5/21 Albert Lea, freight train Minnesota, US

hydrochloric acid

28 cars of 50-car UP train derailed near Goose Lake; one tank car with hydrochloric acid found to be leaking; public advised to avoid area during response; UP crews cleared track; investigation underway

WCCO

16/5/21 Sibley, freight train Iowa, US

ammonium nitrate

47 cars of UP train derailed in small town, with several cars catching fire; train said to be hauling fertiliser, ammonium nitrate; 5-mile evacuation zone imposed; no explosions reported; investigation underway

19/5/21 nr Kathore Morr, road tanker oil Sindh, Pakistan

Road tanker parked outside restaurant on Super Highway caught fire; blaze spread to three more trucks, nearby shop; several fire crews spent five hours battling blaze; police had to be called to disperse crowds

The Int’l News

22/5/21 Kano, road tanker gasoline Nigeria

More than 70 people were injured by explosion at filling station during delivery of 60,000 litres gasoline; reports suggest fire crews had dealt with initial blaze when an employee opened a manlid, causing explosion

This Day

24/5/21 Onyinanufu, road tanker gasoline Ashanti, Ghana

Road tanker from Kumasi to Tepi, said to be speeding, crashed and overturned in small village; tanker exploded on impact, spreading fire that destroyed half the village; at least three people killed, many injured

Graphic Online

25/5/21 Alimosho, road tanker diesel Lagos, Nigeria

Road tanker with diesel burst into flames, exploded after driver lost control at high speed; thought that brakes failed prior to crash; locals fled, responders brought fire under control with no loss of life or major damage

Vanguard

29/5/21 Cliffdale, road tanker LPG KZN, South Africa

One man killed, another injured by explosion during cleaning of LPG tanker; man that died was in tanker when the blast happened; police investigating incident

IOL

MARINE/INLAND WATERWAY INCIDENTS Date

Location

Vessel

Substance

Details

Source

2/5/21 off Chile Berge Yotei soy

Bulk carrier (63,000 dwt, 2020) with cargo of soy from Argentina for New Zealand, suffered explosion, fire in hold; crew evidently managed to stabilise vessel, which headed for Talcahuano; no injuries or pollution

FleetMon

20/5/21 off Colombo, Sri Lanka

Fire broke out aboard containership (2,743 teu, 2021) at anchorage; container with nitric acid had been leaking but prevented from discharge at earlier port calls; thought that acid mixed with other chemicals; vessel sank

Splash 247

21/5/21 off Sakhalin, Kang Shun bunker fuel Russia

COSCO-owned bulker (55,600 dwt, 2004), laden with coal, spilled up to one tonne of fuel oil to sea after collision with bunker barge at Boshnyakovo anchorage; response team deployed to contain, clean up spill

Splash 247

27/5/21 off Imabari, Shikoku, Japan

Product tanker (3,480 dwt, 2016) collided with ro-ro Byakko, which later sank after losing stability; three of ro-ro crew were lost; tanker suffered heavy hull damage, anchored nearby; no report of pollution

FleetMon

Fire broke out in cargo of scrap metal during loading of general cargoship (3,430 dwt, 1989) at Landskrona; fire teams sook six hours to extinguish blaze; vessel apparently not badly damaged

FleetMon

X-Press nitric acid Pearl

Ulsan — Pioneer

31/5/21 Landskrona, Salar scrap Sweden

HCB MONTHLY | JULY/AUGUST 2021

SAFETY 75

MISCELLANEOUS INCIDENTS Date

Location

Plant Type

Details

Source

25/4/21 Egbe-Idimu, pipeline oil Lagos, Nigeria

Fire broke out on NNPC pipeline in Idowu-Egba area, thought to have been as a result of illegal activities by pipeline vandals; not clear if it was a crude oil or product line; nearby residents ran for safety as blaze took hold

Vanguard

1/5/21

Kuala Langat, Selangor, Malaysia

oleochemical crude oil plant

One killed, three injured when fire broke out in two crude oil (crude palm oil?) tanks at Emery Oleochemicals plant in Telok Panglima Garang industrial area; both tanks were badly damaged; cause unknown

NST

2/5/21

nr Qom, Iran

chemical unknown plant

Fire broke out at Movaledan chemical plant, cause unknown; two firefighters injured in series of explosions as they worked to prevent blaze from reaching tanks with alcohol

2/5/21

Brunswick, port Georgia, US

wood pellets

Explosion, massive fire at Logistec wood pellet storage warehouse at Port of Brunswick; building partially collapsed; fire burned through the night; thought to have been caused by self-heating of stored material

Maritime Executive

5/5/21

Lucknow, UP, India

oxygen oxygen refilling plant

Three killed, five injured by explosion during refilling of cylinders with medical oxygen; roof of plant blown off by blast; police suspect defect in one cylinder; facility working fast to deal with Covid-19 surge

NDTV

9/5/21

Homs, oil refinery crude oil Syria

Fire broke out in distillation unit at Homs refinery after leak in crude oil pump; four firefighters suffered from smoke inhalation but no other injuries; three other distillation units at refinery continued operating

SANA

10/5/21 Burgan, oilfield crude oil Kuwait

Two workers injured when blaze erupted at Great Burgan Field in south-eastern Kuwait; cause of fire not known; injured men were taken to nearby hospital and stabilised

11/5/21 Iwaki, Fukushima, Japan

chemical zinc dust plant

Fire broke out at Sakai Chemical Industry plant, reportedly in unit producing zinc dust; nearby residents urged to shelter in place in case of toxic fumes; four workers hospitalised with injuries

The Mainichi

15/5/21 Delmas 32, Haiti

propane propane filling plant

Propane gas station exploded in ball of flame, injuring many people, with one unconfirmed fatality; many nearby shops and businesses damaged; fire crews managed to prevent the blaze from spreading further

Haiti Libre

20/5/21 Ottawa, pipeline natural gas Ontario, Canada

Rupture on underground gas main damaged roadway, prompted widespread evacuation in Hunt Club district; Hydro Ottawa cut off supplies, affecting more than 2,000 homes, for safety reasons while line was repaired

CBC

23/5/21 Isfahan, Iran

At least nine people injured by blast at Sepahan Nargostar Chemical Industries plant, which manufactures industrial explosives; authorities said cause was unclear and is being investigated

AFP

At least two killed, several more injured by explosion of gas cylinder at welding workshop; blast ignited more cylinders on truck parked to deliver them for repair; fire crews unable to reach the site quickly

Vanguard

26/5/21 Dongning, office explosives Heilongjiang, China building

At least eight people killed by explosion that ripped through an office building; preliminary investigation found the building was being illegally used to manufacture mining explosives

ANI

26/5/21 Limay, Bataan, arsenal chemicals Philippines

Two killed, two more injured by blast at military facility at arsenal of Department of National Defense, thought to have happened as workers were mixing chemicals to make primers for bullets

Xinhua

28/5/21 nr Larissa, distillery alcohol Greece

Eight people injured by explosion in still at ouzo distillery; site’s fire suppression system credited with preventing widespread fire; other workers had fire extinguished by the time fire crews arrived

Greek Reporter

29/5/21 Newell, oil refinery oil W Virginia, US

Fire broke out in processing unit at Ergon refinery, with locals reporting an initial explosion; employees initiated controlled shutdown; no injuries reported; cause of fire under investigation; plant produces base oils

Ergon

3/6/21

Riga, Latvia

chemical chemicals plant

Explosion at Grindeks pharmaceutical plant during distillation involving a highly flammable chemical; drum of the chemical exploded in production building, according to authorities

LSM.LV

4/6/21

Cacak, Moravica, Serbia

munitions ammunition factory

Series of explosions in ammunition depot at Sloboda factory; police sealed off the area, evacuated nearby residents; fire burned through the weekend before investigators could access the site

ABC News

8/6/21

Klyuziv, pipeline natural gas Ukraine

Explosion on 500-mm (20-inch) gas pipeline in Ivano-Frakivsk region; no injuries reported; gas supplies to locals unaffected; damaged part of line isolated for repairs; cause not clear

112.UA

9/6/21

Shihezi, Xinjiang, China

chemical siloxane plant

Fire broke out in packaging workshop of Xinjiang West Hesheng Silicon Industry plant, 15 km outside Shihezi City; heavy smoke over area; fire quickly controlled with no casualties; reactor explosion identified

Jimu News

9/6/21

Gresik, E Java, Indonesia

engineering methanol works

Five workers killed by explosion at PT Citra Adi Sarana factory in industrial estate, reportedly during the welding of cylinders; blast said to have happened when they were checking sensor on methanol tank

Medcom

chemical plant

Eight people killed, three injured by leak of methyl formate at plant identified only as handling chemicals; thought that leak happened as workers unloaded shipment of the product from a vehicle

chemical explosives plant

24/5/21 Azare, workshop Bauchi, Nigeria

11/6/21 Guiyang, Guizhou, China

Substance

gas cylinders

methyl formate

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SHINE A LIGHT PPE • INDUSTRIAL FACILITIES HAVE A DUTY TO PROTECT THEIR WORKERS. WHERE INTRINSICALLY SAFE EQUIPMENT IS NEEDED, THAT MUST INCLUDE EFFECTIVE LIGHTING

INDUSTRIAL FACILITIES WITH potentially hazardous areas must protect their employees by providing a safe working environment and the personal protective equipment (PPE) necessary for them to do their job. But, says Princeton Tec, many companies fail to supply important lighting tools such as headlamps. The lack of suitable lighting can lead to

throughout the plant, particularly in confined or restricted spaces. At sites with flammable gases, vapours, liquids, materials or dusts on the premises or in the air, having a headlamp that does not generate a spark is critical. However, while headlamps are part of the kit needed to minimise exposure to hazards,

serious and even deadly accidents. As a tool, headlamps are essential when hands-free lighting is required in low-light areas for a wide range of tasks, such as operating and maintaining machinery or assessing its condition. Headlamps are also necessary for safe, efficient personnel movement

they are often not included in corporate budgets for PPE. This leaves workers to buy their own headlamps from industry supply or hardware stores. If they are going for the cheapest option, those headlamps may well not be safe for use in hazardous areas and any resulting accident could open the company

HCB MONTHLY | JULY/AUGUST 2021

up to potential liability. An increasing number of industrial safety officers are beginning to realise this risk and are specifying headlamps as part of the company’s PPE budget. “It is safer for industrial plants to provide suitable headlamps upfront rather than leaving it up to employees to make their own purchases,” says Scott Colarusso, general manager and co-owner of New Jersey-based fire safety equipment supplier All Hands Fire Equipment & Training. “However, department approval of only intrinsically safe product would handle the issue. Preventing even one serious injury, fire, or explosion would pay for any implementation.” SAFE AND SHINY When companies supply intrinsically safe headlamps, which are specifically designed not to be a source of ignition in hazardous zones, workers are protected from serious, even potentially lethal accidents wherever they need to go in the plant. Essentially, everyone is covered, and the chance of mishap eliminated.

SAFETY 77

“Without safety certified headlamps appropriate for the application, industrial facilities are exposed to potential liability if an incident occurs. By supplying workers with headlamps that are rated for any hazardous environment [that could be encountered in the plant], companies can prevent the problem,” says Colarusso. Headlamps enhance personnel safety and efficiency since wherever they look the lighting goes with them, leaving their hands free. With multiple beam modes, these devices are designed to be easily operable even when workers wear heavy gloves. Typically, the units are waterproof and chemically resistant, ready for use in rugged surroundings, which may include getting thrown into a truck toolbox. The devices must also provide ample light for sufficient ‘burn time’ to last an entire work shift without a change of batteries. Across a range of industries, however, typical headlamps can be a dangerous source of ignition if workers unwittingly enter a hazardous area or are exposed to flammable materials or conditions. The US Occupational Safety and Health Administration (OSHA) recently issued a standard for construction work in confined spaces (Subpart AA of 29 CFR 1926); this recognises that such spaces can present physical and atmospheric hazards that can be avoided if recognised and addressed prior to entry. It is designed to eliminate potentially deadly hazards by requiring employers to determine what kinds of spaces their workers are in; what hazards could be there; and how those hazards should be made safe (including the use of headlamps, flashlights, and other lighting equipment that carry the proper safety ratings). Therefore, in production, processing or maintenance settings where the environment is inherently volatile, headlamps should carry the proper certification for various classes, divisions and groups of materials. When a

 EMPLOYEES NEED TO BE ABLE TO SEE PROPERLY AND SHOULD NOT BE LEFT TO BUY THEIR OWN LAMPS, WHICH MAY NOT BE INTRINSICALLY SAFE AND LEAVE THEM OPEN TO HAZARDS

“HEADLAMPS ARE ESSENTIAL WHEN HANDS-FREE LIGHTING IS REQUIRED IN LOWLIGHT AREAS”

potentially dangerous, industrial chemicals and solvents. The latest models also offer anti-static properties and safety features, such as a mechanical locking mechanism that requires a tool to open the battery compartment. This prevents users from inadvertently opening the battery housing in a hazardous environment, which could not only result in electric shock but also potentially ignition or explosion.

HERE’S THE OPTION As one example in the industry, the intrinsically safe Vizz II headlamp from Princeton Tec, meets the requirements (Classes I, II, III; Divisions 1,2; and Groups A-G). Trenton, New Jersey-based Princeton Tec is a producer of ETL and UL-approved lighting products and manufactures headlamps that meet strict global safety requirements. “Whether for OSHA, Zone 0, or state standards, intrinsically safe products like the Vizz II headlamp help industrial safety officials ensure that all the bases are covered. So, there is nothing from the lighting that could spark a potential fire or explosion in a work environment,” says John Navarro, a purchasing agent for CWR Wholesale Distribution, a supplier to various industries including automotive, consumer electronics, oil and gas, and marine. Previously, Navarro was a nationally registered paramedic and certified New Jersey state hazardous material technician. Because headlamps can be dropped or bumped in industrial settings, it is also important that the equipment is designed to reliably withstand rough handling.

THE PLACE TO GO “Many of our corporate customers specify Princeton Tec headlamps and lighting products due to the reliability, longevity, price point, and made in USA production,” says Navarro. “When intrinsically safe equipment matters, it is essentially the gold standard.” According to Navarro, among CWR Wholesale Distribution’s wide range of industrial customers, the motivation for budgeting and supplying intrinsically safe headlamps and lighting as PPE is to prevent potential liability. “With an intrinsically safe headlamp, you are meeting the standard and enabling employees to work in the safest possible conditions with the most up-to-date equipment,” he says. “Now the technology is at a better price point than it was five years ago, so it is affordable for corporate safety budgets.” Many of Navarro’s industrial customers are willing to spend a little more for higher rated, compliant, intrinsically safe headlamps. “Our industrial customers want to know their plant personnel can safely use their intrinsically safe headlamps anywhere. Safety committees do not want to worry about where personnel may use the units, if it is safe to use under hazardous conditions,” concludes Navarro. While industrial manufacturing, processing and maintenance carries some inherent risk, industrial plants seeking to improve safety can do so by providing workers with ultra-safe

In response, some manufacturers like Princeton Tec now make headlamps with durable thermoplastic material designed to withstand drops and rough handling. The units not only provide up to 10 hours of light without a battery change but also have superior resistance to common,

headlamps that ensure compliance. As the need for industrial safety only grows along with stricter regulation, facilities will increasingly make headlamps a mandatory part of any PPE budget or safety programme to minimise operational risk and liability. princetontec.com

headlamp is rated for all these options, it essentially means it is certified as safe for use in most hazardous environments.

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WHERE IN THE WORLD INTERNATIONAL • CHEMTREC IS CELEBRATING ITS 50TH ANNIVERSARY THIS YEAR WITH A NEW GUIDE TO HELP EXPORTERS STAY COMPLIANT WITH LOCAL REGULATIONS AROUND THE WORLD MANY COUNTRIES HAVE adopted the UN’s Globally Harmonised System of classification and labelling of chemicals (GHS) as the basis for their safety data sheet (SDS) and product and package labelling regulations, but there is still a wide variety of regulations in place around the world. Companies exporting dangerous goods need to be aware of those regulations so they can prepare their consignments properly to avoid snags in the supply chain and added costs. To help them, Chemtrec has come up with a new guide to emergency response compliance, providing advice on best practice and guidance for businesses exporting goods around the world. Created in partnership with international regulatory experts Denehurst Chemical Safety, the guide covers both the international transport regulations, which aim to prevent and mitigate any incidents that happen during the transport of chemicals, and the supply regulations, which aim to protect the end users of chemicals and which are more locally oriented. The guide provides key information on country-specific transport and supply requirements in a number of countries, including China, South Korea, Australia, Brazil and Mexico, simplifying often complex

regulations and international lithium battery test summary requirements.

regulations and providing the emergency response telephone numbers needed in order to comply. It highlights how, where and why to display emergency numbers, and who must be available to take the call, as well as considering wider regulatory requirements including Chinese hazardous chemical

DO THE RIGHT THING “Failure to comply with international transport and supply regulations can leave companies financially and reputationally exposed,” says Christopher Brown, interim chief executive of Chemtrec. “Wherever you are in the world and

HCB MONTHLY | JULY/AUGUST 2021

“REGULATIONS REQUIRE AN EMERGENCY TELEPHONE NUMBER ON DOCUMENTS, LABELS AND PLACARDS”

whatever mode of transport you are using, our comprehensive new guide simplifies complex requirements such as the International Maritime Dangerous Goods (IMDG) Code and International Civil Aviation Organisation (ICAO) Technical Instructions, as well as highlighting the specific regulations that require you to have an emergency response telephone number on shipping documents, labels and vehicle placards in a number of international countries. “While not mandated, displaying our numbers properly not only supports compliance but will also help avoid any delays to your supply chain,” Brown adds. The launch of the guide is being supported with a series of webinars to help businesses understand the regulations and how they impact the supply chain. It will also help customers understand how Chemtrec can help manage risks to people, the environment, business operations and reputation. The guide is also a reflection of the wider role of Chemtrec, which offers round-theclock multilingual assistance, support and expertise to help its clients manage any incidents in the movement and supply of chemicals and other dangerous goods. “When incidents do occur, it’s Chemtrec‘s priority to ensure employees, first responders and the general public are protected, and the environmental impact of the incident is minimised,” Chemtrec says. “From reducing/ lessening operational and environmental risk to staying compliant and protecting their investments, Chemtrec’s skill and expertise in dealing with the unexpected is invaluable to organisations the world over.” Established in 1971 by the Manufacuring Chemists’ Association (MCA) – now the Chemical Manufacturers Association – to provide chemical-specific information to emergency responders, Chemtrec now has some 30,000 public and private sector organisations as clients and offices in all major regions of the world. The new Emergency Response Guide can be downloaded free of charge from the Chemtrec website at www.chemtrec.com/erguide.

SAFETY 79

FOOT ON THE LADDER LOADING ARMS • USERS NEED TO ENSURE THAT EVEN HARDTO-REACH PARTS OF MARINE ARMS ARE INSPECTED AND MAINTAINED, HSE SAYS, FOLLOWING A RECENT INCIDENT THE UK HEALTH & Safety Executive (HSE) has issued a safety alert following an investigation into the collapse of a marine loading arm (MLA) that narrowly missed causing a serious incident. During that investigation, HSE found that not all components were being suitably inspected and maintained. In particular, in this incident, there was a problem on the top pivot joint, which had been missed because of difficulties in accessing that part of the arm. The lack of lubrication of this greased joint presents a serious risk of the joint failing, with the potential for the complete collapse of the MLA. This could cause serious injury or even a fatality, along with damage to process equipment or pipework and a subsequent loss of containment. HSE says that anyone using or servicing MLAs should check, review and identify inspection and maintenance work as required by the manufacturer and industry guidance. A plan should be developed to address how the work will be conducted, including accessing

those parts that are difficult to reach, and that plan must be completed. Records should be kept and outstanding actions should be followed up. WHAT WENT WRONG In the incident under review, the 8-inch nominal bore, hydraulically operated MLA had been in service for 11 years and had been regularly maintained by various recognised industry contractors. It had a rigid link pantograph balancing system with independent primary and secondary counterweights linked to the inboard and outboard arms. The MLA failed as it was being manoeuvred towards a ship manifold for connection. A section of the MLA fell backwards onto a

 ANY FAILURE OF A LOADING ARM HAS THE POTENTIAL TO CAUSE INJURY, DAMAGE TO THE FACILITY AND EXTENSIVE POLLUTION OF THE SITE AND NEARBY WATERS

jetty handrail, narrowly missing live plant and pipework. The immediate cause of the failure was from corrosion of the bearing that led to a complete fracture, emanating from the circumference. The underlying causes were inadequate inspection and maintenance practices which had led to the corrosion. There was no convenient means of accessing the pivot pin for inspection and maintenance. As a result, it had not been lubricated during servicing by several different contractors. HSE has reviewed MLA designs and suggests that the problem of accessing all parts during maintenance may not be specific to one manufacturer. HSE’s safety alert includes a call for action along the plan-do-check-act process. Following the planning stage, users are urged to inspect structural components such as the pivot pin and seals, ensuring they are in good condition, as soon as practicable. In light of that inspection, the inspection and maintenance programme should be updated to ensure that it is suitable and sufficient, and capable of detecting and remedying any foreseeable deterioration before it results in unacceptable risk. Users also need to check that any maintenance work has been undertaken satisfactorily and that all risks are being adequately controlled. A clear, detailed and accurate record of the work should be made, highlighting any servicing requirements that are not carried out, along with a judgment about the potential impact. Users then need to learn from what they have found, taking action as necessary, and implement any remedial action to address issues that have emerged. They should also review industry good practice and manufacturer’s guidance as well as inspection and maintenance plans periodically to see if they need updating. HSE’s safety alert, available at www.hse. gov.uk/safetybulletins/marine-loading-armfailure.htm, also includes references to relevant legal documents and industry guidance.

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PRESIDENT TRUMP’S POLICY of pursuing a light regulatory touch, with the aim of reducing the burden on American business, was undoubtedly good for many corporations and was probably a vote-winner, but for those in the hazardous materials world – and especially those working internationally – it did cause some problems. Not only did the US become significantly out of step with international regulations, but safety-critical rulemakings were also held up. Nor was it good news for the various agencies of the US Department of Transportation (DOT), which had to cope with a new focus in the oversight of the rulemaking

on Safe Transportation of Hazardous Articles’ (COSTHA) online Annual Forum this past April heard, that has certainly been the case – even if it is not totally clear yet how the new approach will look in detail. The Pipeline and Hazardous Materials Safety Administration (PHMSA) has a lot of catching up to do before it can embark on new rulemakings, and there are other developments in the pipeline. TO COME FROM PHMSA It was left to Shane Kelley, director of the Standards and Rulemaking Division of PHMSA’s Office of Hazardous Materials Safety (OHMS) to bring COSTHA attendees up to

to get the HM-224I rulemaking to a final rule. This is designed to enhance the safe transport of lithium batteries by air and is, in effect, already being observed after an interim final rule was issued in March 2019. PHMSA’s task, Kelley said, is to close out the rulemaking. The next priority is HM-215P, the biennial update to maintain the US Hazardous Materials Regulations (HMR) in harmonisation with international rules. HM-215P will bring the US into line with the amendments introduced from the start of 2021, certainly as far as the air transport regulations are concerned, though the International Maritime Dangerous Goods (IMDG) Code’s latest amendment, 40-20, will only become mandatory on 1 January 2022. PHMSA is keenly aware that the last biennial update, HM-215O, was more than a year late taking effect and does not want a repeat of that delay; Kelley noted that PHMSA is aiming to bring the process back to a timeline that harmonises more closely with international changes and that the new leadership at the agency is receptive to the idea. He also said

process. As a result, new regulatory activity became sclerotic and failed to address some emerging hazards, especially those relating to new fuels and new energy storage concepts. With the change in administration in DC in January this year, it was expected that things would change and, as delegates to the Council

speed with the latest activity. He noted that the politically appointed leadership is still settling in and that there are also some new faces working at PHMSA, so it may take some time to get fully back up to speed. For this year, PHMSA has three main priorities. The first – and perhaps simplest – is

that HM-215P “is in good shape” and that industry should see some action “soon”. There should be few surprises for industry in HM-215P; Kelley pulled out some highlights. There is a new classification for Category A infectious waste; updates to ISO cylinder manufacturing and testing standards (as ever);

THE RULES TO FOLLOW USA • COSTHA’S 2021 ANNUAL FORUM HEARD FROM LEADERS IN DOMESTIC HAZMAT REGULATION, COMING TO TERMS WITH THE CHANGE IN LEADERSHIP IN THE WHITE HOUSE

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REGULATIONS 81

new entries in the organic peroxide table (ditto); an expansion of the existing options for the transport of ‘large robust’ articles, such as refrigerating machines; and revised shipping paper requirements for damaged/defective lithium batteries. Aside from that, there is a “lot of upkeep and maintenance”, Kelley said, though these may include some important changes for those affected. After HM-215P, the next priority is HM-265, which addresses coordination and collaboration with the other modal agencies under DOT and which is also expected to relieve the regulatory burden by avoiding duplicate or conflicting responsibilities; a notice of proposed rulemaking (NPRM) is expected after the NPRM for HM-215P and Kelley said he is “looking forward to feedback” from industry. There are a number of other rulemakings under development, including an advanced notice of proposed rulemaking (ANPRM) under HM-265A, which will supplement HM-265 with some initiatives for regulatory reform. Other ongoing projects include HM-233G, which will incorporate some outstanding special permits into HMR, and HM-219D, designed to respond to petitions from industry, especially as regards the reduction of the regulatory burden. Separately, HM-250A will update HMR to align with the International Atomic Energy Agency’s (IAEA) transport standards, and HM-257A will look to streamline the approval of energetic substances in transport. MORE TO SEE Meanwhile, PHMSA has also been asked to take another look at a couple of rulemakings that were completed during 2020, although Kelley said the agency does not see a need for more action on HM-251D, which deals with the vapour pressure of unrefined petroleum (crude oil) and withdraws an ANPRM issued in January 2017 following further research. HM-264, which is permits the transport of

review. This move follows an executive order from President Biden regarding the new administration’s environmental expectations. PHMSA’s Standards and Rulemaking Division clearly has a lot on its plate right now, and Kelley included in his presentation a reminder – or a plea, even – that petitions for rulemaking and applications for special permits must provide at a minimum the information required by the relevant parts of HMR. Those applications deemed to be substantial may need additional information. Kelley also addressed how PHMSA has worked during the Covid-19 pandemic and the measures it has put in place to help the country keep moving. The agency is working in a fully virtual environment but has focused on improving customer service and increasing stakeholder communication and outreach. It has also issued a number of enforcement discretions and guidance to help industry keep vital goods moving – including hand sanitisers and disinfectant products – and to provide extensions of deadlines for training, packaging retesting, cylinder requalification and other issues. PHMSA has also reviewed home testing kits for compliance with HMR and worked to facilitate the shipment of vaccines. The impact of the Covid-19 pandemic has also dominated the agenda of the Federal Motor Carrier Safety Administration (FMCSA) over the past year, reported transportation specialist James Simmons. It has issued a series of waivers and enforcement discretions, all listed on a dedicated page on the FMCSA website. At the time of the COSTHA Annual

Forum, FMCSA had also extended the Emergency Declaration relating to the health emergency through to the end of May 2021, adding in a new provision covering vaccines and related material. [This was subsequently extended again to 31 August 2021.] Simmons also mentioned ongoing work to identify undeclared hazardous materials and the ‘Check the Box’ initiative, which had been referred to earlier in the session on misdeclared and undeclared cargo (HCB June 2021, page 48). FMCSA has put in place an email so that undeclared shipments can be reported at the roadside and there is more information on the website https:// checkthebox.dot.gov/check-the-box. While undeclared hazmat is a major worry, Simmons reported on other matters of concern to FMCSA. These include compliance investigation and inspections, the accuracy of hazardous materials data and information in the supply chain, and hazmat training. Expect more in these areas at next year’s COSTHA Annual Forum, if not before. BOX CHECKING EXERCISE Before then, Aaron Mitchell, director of outreach and enforcement at PHMSA, and transportation specialist Joanna Luu came back to the Check the Box initiative, which is a DOT-wide campaign, in the framework of best management practice. During an earlier presentation, Mike Wentz of American Airlines highlighted the risks posed by thermal runaway in lithium batteries but, Mitchell and Luu said, it is not just lithium batteries that

LNG in bulk in rail tank cars, is however under

 PHMSA IS TO TAKE ANOTHER LOOK AT THE TRANSPORT OF LNG BY RAIL TO TAKE INTO ACCOUNT ENVIRONMENTAL CONSIDERATIONS

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are the problem. Despite that, they reported on a container being transported by rail, with no declared hazardous materials, that caught fire in Houston in 2017 when a 55-gallon drums with lithium batteries went into thermal runaway and exploded. Express carriers seem particularly at risk: the presentation mentioned four UPS employees who were injured in Dallas in 2014 when unmarked boxes containing small inner packages of sulphuric acid leaked, and three FedEx employees were injured in Jackson, Mississippi in 2013 when an unmarked packaging containing oxidising liquids was punctured during handling. In Anderson, California in 2008, a box of undeclared fire extinguishers leaked at a UPS sorting facility, injuring three employees. Indeed, Mitchell and Luu said, each year there are around 1,500 transport incidents involving undeclared hazardous materials, involving a diverse array of hazardous materials; these can cause serious safety consequences for transport workers, emergency responders and the general public. They urged everyone to ‘Check the Box’ before shipping. Undeclared hazmat is also a top priority for the US Coast Guard (USCG), as Dr Amy Parker, lead chemical engineer, reported. In this area it is active in the multimodal Undeclared Hazmat Working Group, along with PHMSA and the

 ALL THE FEDERAL AGENCIES ARE FINDING ISSUES WITH UNDECLARED HAZMAT AND HAVE BEGUN WORKING MORE CLOSELY TOGETHER TO ADDRESS THE PROBLEM

US Postal Service (USPS), which is looking at inspection trends and incidents, as well as coordinating policy development with the aim of creating a unified outreach and training strategy. Better education of shippers – including informal shippers – is key to achieving compliance, Parker said. Among other major objectives at USCG, the agency is reviewing compliance with HMR in the ferry sector, looking at policies and regulations for the storage of ammonium nitrate and certain other dangerous goods at

designated waterfront facilities, and dedicating more time in the field on outreach and education, both with industry and USCG units. As with misdeclared cargo, there is a cross-agency Ammonium Nitrate Working Group that is coordinating the government’s approach to the safe transport and storage of ammonium nitrate. HOME AND AWAY Parker, who was accompanied by her colleague Hillary Sadoff, also mentioned the collaborative work being undertaken with USCG’s Office of Commercial Vessel Compliance (CG-CVC). In particular, that work involves a review and update of the Marine Safety Manual (MSM), Volume II, Section F on the Carriage of Hazardous Materials. It also includes an evaluation of the impact of special permits and approvals on USCG’s inspection programmes, for instance in the use of special permits for specific vessels and dedicated routes. Parker and Sadoff are also providing subject matter expertise on the IMDG and International Maritime Solid Bulk Cargoes (IMSBC) Codes in the update of the Alternative Compliance Program. It is also USCG’s role to represent US interests at the International Maritime Organisation (IMO). Parker noted that the IMSBC Code’s Editorial & Technical (E&T) Group met virtually in mid-January, and the IMDG Code’s E&T Group did the same in mid-March. The work done at those meetings will feed into the discussions of the Subcommittee on Carriage of Cargoes and Containers (CCC), although its seventh session has now been postponed until 6 to 10

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REGULATIONS 83

September. Its agenda has also been reduced, pointing to a reduced number of amendments, and that session will also be held virtually. A joint E&T Group for both Codes will meet virtually immediately after the CCC session. Returning to domestic matters, hazmat programme specialist Vinny Desiderio explained the role of the US Postal Inspection Services’ (USPIS) hazmat programme, which is “to protect the US Postal Service and its employees, customers, business partners and infrastructure from threats posed by undeclared and improperly prepared dangerous goods in the mail”, of which there is more than there used to be, given the rise in internet shopping. That increase is reflected in the extent of enforcement activity in recent years. Annual civil penalty requests numbered less than 100 until the 2018 fiscal year, when 318 requests

were made, rising to 948 in 2020. That has been matched by increasingly aggressive civil penalties, which totalled some $340,000 in 2018, rising to almost $4m last year. Penalties represent the stick in enforcement activity but USPS has also been increasing its outreach and education activity, including a tutorial on the packaging and labelling required for hazmat in domestic mail available on the USPS website (www.uspsdelivers.com). There was also an update to USPS Publication 52, which deals with hazardous, restricted and perishable mail, published in July 2020. This includes changes to the provisions for limited quantities shipped under the ORM-D provisions and to the positioning of labels on adjacent sides of a package. USPS is now looking at the position of electronic nicotine delivery systems (e-cigarettes) in the mail, given the restrictions included in the

Preventing Online Sales of E-Cigarettes to Children (PACT) Act. Guidance was published in April 2021, indicating how shippers should address the current requirements. As might be expected, USPS has also had to look at new supply chains arising from the response to the Covid-19 pandemic, including the shipment of hand sanitisers and Covid test kits. Approvals have been issued to address both products. It remains to be seen whether the pandemic will persist long enough to prevent the 2022 COSTHA Annual Forum from taking place in person; the Council did well with the organisation of the 2021 event but many regular attendees will be itching to get back to a physical event. Given the presentations given this year, there will certainly be plenty to talk about. www.costha.com

COMMUNICATION BREAKDOWN OSHA • MAJOR CHANGES ARE BEING PLANNED FOR THE US HAZARD COMMUNICATION STANDARD. NOT ALL IN INDUSTRY ARE HAPPY WITH THE PROPOSALS THE US OCCUPATIONAL Safety and Health Administration (OSHA) issued a notice of proposed rulemaking (NPRM) this past 16 February, aiming to update the Hazard Communication Standard (HCS) to align with the seventh revised edition of the UN Globally Harmonised System of Classification and Labelling of Chemicals (GHS). The rulemaking also aims to address some issues that arose during the implementation of the 2012 update of HCS and to better align with other federal agencies and international trading partners. The proposed modifications to the standard include revised criteria for classification of certain health and physical hazards, revised provisions for updating labels, new labelling provisions for small containers, technical

amendments related to the contents of safety data sheets (SDSs), and related revisions to definitions of terms used in the standard. OSHA says it has preliminary determined that the proposed revisions “will enhance the effectiveness of the HCS by ensuring employees are appropriately apprised of the chemical hazards to which they may be exposed, thus reducing the incidence of chemical-related occupational illnesses and injuries”. HCS was first introduced in 1983, specifically to cover the chemical manufacturing industry. OSHA always envisaged that it would require periodic updates; these included a broadening of its scope to cover all industries where employees could be exposed to hazardous

chemicals and a major review for comprehensibility, undertaken in 1994. Since 2012, HCS has been aligned with GHS, then at its third revision, and it has subsequently been updated in line with amendments to GHS. Those amendments that appeared in the seventh revised edition of GHS, which this NPRM addresses, include revised criteria for the categorisation of flammable gases within Category 1; miscellaneous amendments intended to clarify the definitions of some health hazard classes; additional guidance regarding the coverage of section 14 of the SDS (which is non-mandatory under the HCS); and a new example in Annex 7 addressing labelling of small packages with fold-out labels. OSHA is also proposing to include some amendments included in the eighth revised edition of GHS. WORK TO BE DONE In total, the proposed changes are extremely extensive and will have a very significant impact on industry. The National Association of Chemical Distributors (NACD) responded to the NPRM with a lengthy comment, highlighting the burden the HCS revision will have on its members. “Chemical distributors serve a critical role in the middle of the supply chain, and most of these companies have large numbers of suppliers, products, and customers,” said NACD president/CEO Eric R Byer. “Changing SDSs and labels for hundreds or even thousands of chemical products is a major undertaking for these companies.” To illustrate the extent of that undertaking, one NACD member has estimated that it would need to review 10,000 SDSs and update 4,000 of them. OSHA has calculated that each review should take 0.7 hours, which gives a figure of 16 months of dedicated work for this company. Further, NACD says, “some of the proposed changes are not necessary for harmonisation and would create excessive burdens for chemical manufacturers and distributors while adding needless complexity and liability to the system”. Moreover, those changes would not offer any comparable improvement in worker protection. In general, NACD feels that updating HCS in line with the biennial revision of GHS is not necessary and is unduly burdensome; most of

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its members favour either a four-yearly cycle or revisions only when there are significant changes. In addition, it has urged OSHA to provide as much advance notice and transparency as possible, with a running list of anticipated changes and more outreach to the regulated community on the status and timeframe for changes to HCS. CONFLICTING STANDARDS More specifically, NACD has identified some problems with OSHA’s proposals. For one, a new definition of ‘bulk shipment’ would conflict with the existing definition of ‘bulk packaging’ in the Hazardous Materials Regulations (HMR) for transport, particularly in their treatment of intermediate bulk containers (IBCs); if not corrected, this will cause unnecessary confusion and problems in training. NACD urges OSHA to copy the

 OSHA’S PROPOSALS, IF ENACTED, WILL CAUSE IMMENSE PROBLEMS AND A LOT OF WORK FOR CHEMICAL DISTRIBUTORS, PARTICULARLY THOSE HANDLING A WIDE RANGE OF PRODUCTS

definition of ‘bulk packaging’ that has long been used in HMR. Further confusion stems from the proposal to add a new paragraph (f)(5)(ii) to require that the label for bulk shipments may be on the intermediate container or may be transmitted along with other electronic documentation so that it is immediately available to workers in printed form at the consignee. NACD feels this is unnecessary; a DOT placard is always suitable for shipment and the receiver will have the product’s SDS before the goods arrive, and which provides far more information than the label. In addition, NACD highlights the difference in HMR between hazardous materials being ‘marked’ and ‘labelled’. It recommends OSHA amend its proposed (f)(5)(ii) so as to avoid confusion about the meaning of ‘the label’. It also recommends additional wording to

importing material from foreign suppliers with different or non-existent standards. OSHA is proposing to define ‘released for shipment’ as ‘a chemical that has been packaged and labeled in the manner in which it will be distributed or sold’. NACD believes this is not only potentially confusing but altogether unnecessary. In addition, the update to paragraph (f)(11) requires the ‘date chemical is released for shipment’ to be included on the HCS label. In part, this is to allow goods to move even after changes to the chemical hazards have been advised. This might seem helpful but, NACD says, will in practice be logistically complex and unfeasible in some market segments. For a start, it would require new labels to be produced for each shipment or even individual container, despite OSHA’s intention that products would not need to be relabelled.

address the location of HCS labels and DOT labels on a package. The proposed definition of ‘combustible dust’ does not match that used by the National Fire Protection Association (NFPA) and, in NACD’s opinion, is “far too broad”. Consistency is required, not least for those distributors

Sending new labels separately for every individual container also raises safety concerns. Most customers of chemical distributors do not want to be in the relabelling business, nor should they be. If these customers receive new labels for each container, they may assume they are required

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to attach them. The ergonomic impact of removing a load of 50-pound bags from a pallet would be substantial. It is unlikely a receiver of a palletised load will be able to break down the pallet, label and reassemble the pallet without a back injury, other ergonomic injury, or chemical exposure from unnecessary handling. In addition, if a customer opts to apply the labels, there is no guarantee they will apply the labels to the correct containers. This could subject all parties in the supply chain, including chemical distributors, to liability if products are relabelled incorrectly. The pharmaceutical industry provides an example of the need for strict label control. Pharmaceutical products have tight label reconciliation processes, so sending separate electronic or print labels is

 NACD WANTS TO SEE THE HAZCOMM STANDARD ALIGNED WITH OTHER EXISTING PROVISIONS, INCLUDING THE DEFINITIONS OF BULK CONTAINER AND (ABOVE) OF COMBUSTIBLE DUST, TO MAKE COMPLIANCE AND TRAINING EASIER

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a non-starter. All pharmaceutical products would need to be relabelled in-house prior to shipment. LABELS AND SHEETS OSHA proposes several changes to the labelling requirements, many of which are editorial, clarifying or organisational. It also proposes significant updates to the precautionary statements in every hazard class and category and to require prioritisation of certain statements related to medical response. These are, NACD says, “massive changes” that could require many companies to relabel all their products, involving extensive software updates. Those changes are possible but will take more time than OSHA anticipates, NACD says. OSHA is also considering moving to the precautionary statements agreed for the eighth revised edition of GHS, a move that NACD says makes sense. However, the transition will take a few years. NACD is also concerned that changes to the HCS label will require the addition of further information, making it even harder to read than it is at the moment. To enhance worker safety,

labels need to be as user friendly as possible, NACD says. If there is too much data on the label, users may not be able to identify quickly the most essential information. The SDS provides the comprehensive information that will be the main resource if someone is hurt. OSHA is proposing to require the address and telephone number shown on the SDS to be domestic, which will be a significant change for some foreign suppliers and importers. If the supplier cannot provide a US address and phone number, these will have to be provided by the importer, which would then assume liability for all the information. NACD agrees it would be helpful to have this requirement in HCS so that it can be used to prove to a foreign supplier that it is needed, but it also notes that the similar requirement in Canada’s Workplace Hazardous Materials Information System (WHMIS) results in every imported item being relabelled, causing a compliance burden and risks of exposure. THE REACH ROUTE Of major concern to NACD is a proposal to add a requirement in Section 2 of the SDS to

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include “any hazards associated with a change in the chemical’s physical form under normal conditions of use” and identification of hazards that “result from a chemical reaction”. This requirement, similar to that already in force in Europe, would create an “impossible situation” for chemical manufacturers and distributors in the US, NACD says. Its members sell to widely differing markets and there is no way to ascertain all the different “normal conditions” of use. “Determining downstream hazards is outside the scope of the HCS responsibilities for a distributor or producer,” NACD reasons, as HCS applies only to the workplace. Any chemical that can be mixed with other chemicals could have an extensive list of hazards that “result from a chemical reaction”, NACD also notes. The intent of this proposal seems to be to cover those products meant to undergo a specific reaction as part of their use, rather than at general use chemicals. These are already identified in other sections of the SDS. Moreover, liability concerns with attempting to comply with the requirement could generate a lot of work for lawyers with no enhancement of worker safety. NACD urges OSHA to withdraw this proposed change, which is sees as a significant expansion of the scope of HCS. OSHA is also considering whether the chemical name and concentration of all classified chemicals – not just those classified as ‘health hazards’ – must be indicated in Section 3 of the SDS. Again, this is similar to the REACH Regulation in the EU. NACD has

concerns about this too, saying that the hazards should be determined on the basis of the mixture, not on the individual substances it contains. “While the additional concentration information could be helpful in accurately classifying some mixtures, the expansion could become too burdensome and result in the generation of an infinite amount of additional paper that would not ultimately enhance worker safety,” NACD says. Also, these hazards are covered in a general manner in other Sections of the SDS so no change is warranted for Section 3. OSHA also proposes to update the physical properties list. NACD is concerned about changing this list and does not believe it will advance worker safety. “As individuals look at SDSs and labels, they are accustomed to quickly identifying the information they need. The more lists such as this are changed, the more people need to relearn and make adjustments. Changes like this that do not add value or enhance safety should be dropped,” NACD says. OTHER ISSUES As part of the NPRM, OSHA has invited comments on the use of electronic labelling for chemical packagings. This concept, NACD says, has both advantages and disadvantages. It could be a practical way to address difficulties in labelling small packages and could also be of great use to emergency responders, particularly if it were to apply to SDSs as well as to labels. On the other hand, some companies have concerns about the use

of mobile phones in chemical facilities and there are also technological challenges and the need for a standard format. “If OSHA pursues electronic labelling, this would absolutely need to be optional rather than mandatory; and, with the possible exception of small packages, hard copy labels should also be required as a back-up in case of network failures,” NACD says. NACD sees a problem in the NPRM, which expects industry to comply with the changes on a fairly short timeframe. It is planned that the changes will be effective 60 days after publication of the final rule, with entities evaluating substances given one year to comply after that date and those evaluating mixtures two years. NACD believes this is inadequate, given the massive changes being proposed for labels and SDSs. In fact, if OSHA adopts the provisions in the eighth revised edition of GHS, several years will be needed to achieve full compliance. “NACD members’ software vendors estimate that the programming changes to comply with [Section 2] alone could take several months. If other label organisational changes will be made, such as with the medical information, this will only increase time needed for compliance. This will pose a major problem as some companies are still struggling with HCS 2012 changes,” NACD says. It believes a more realistic timeline would be 18 months for substances and three years for mixtures, with this applying only to original chemical producers; those further down the supply chain, such as chemical distributors, should be given another year to comply. This would mirror an enforcement discretion issued by OSHA in the wake of the 2012 revision to HCS, which saw distributors left with very little time to produce their own SDSs and labels. “A similar situation will certainly occur with the current revision unless OSHA adopts a staggered approach based on position in the supply chain,” NACD says. NACD was not the only entity to comment on the NPRM; indeed, such was the extent of the proposals that OSHA extended the period for submitting public comments by 30 days to 19 May; that was followed by a public hearing. OSHA will now take those comments into account in the formulation of a final rule.

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TO THE POINT MULTIMODAL • THE JOINT MEETING OF RID/ADR/ADN EXPERTS WRAPPED UP SEVERAL AMENDMENTS AT ITS SPRING SESSION, MANY OF THEM ADDRESSING URGENT SAFETY ISSUES THE JOINT MEETING of the RID Committee of Experts and the Working Party on the Transport of Dangerous Goods (WP15) of the UN Economic Commission for Europe held its spring session in Bern, Switzerland from 15 to 19 March 2021, in a hybrid format with both in-person and online attendance. The joint meeting’s main task is to ensure the maximum possible degree of harmonisation between the regulations that govern the transport of dangerous goods by rail (RID),

maintenance and inspection of the various means of containment. The spring session was chaired by Claude Pfauvadel (France) with Silvia Garcia Wolfrum (Spain) as vice-chair. It was attended by representatives of 25 countries (including the US), the European Commission, the EU Agency for Railways (ERA), the Organisation for Cooperation between Railways (OSJD) and 16 non-governmental organisations.

road (ADR) and inland waterway (ADN) in Europe and, increasingly, elsewhere around the globe. While it is charged also with aligning the modal regulations with the UN Model Regulations insofar as possible, it concentrates in particular on the rules for the design, construction,

TANKS MATTERS As is usual, those papers relating to tanks were passed to the Working Group on Tanks, which met in virtual form for the first three days of the session under the chairmanship of Arne Bale (UK), with Kees de Putter (Netherlands) acting as secretary. The Working Group did not

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consider proposals relating to the inspection and certification of tanks, which were dealt with by a separate informal working group and by the Joint Meeting in plenary. The Working Group on Tanks continued with its discussions on safety in the design and use of extra-large tank containers; while these have so far been used in in-plant applications and very specific overland transport, where strict construction and operational standards have been observed, there is concern that, should they been adopted more widely, specific safety considerations will have to be taken into account. The Working Group supported the development of a definition for ‘extra-large tank-container’, as any specific requirements included in the regulations will need to be closely defined. However, it proved impossible to settle on such a definition as there needs to

 THE WORKING GROUP ON TANKS CONTINUED DELIBERATION OF EXTRA-LARGE TANK CONTAINERS (ABOVE) AND ALSO LOOKED AGAIN AT THE TRANSPORT OF LNG IN TANKS (OPPOSITE)

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be more clarity on the criteria for distinguishing such containers, including not only their capacity but also their maximum gross weight and/or external dimensions. Pending the adoption of specific requirements, and the possibility of other large tanks already being in existence, it was felt sensible to include a new transitional measure, which was approved by the Joint Meeting at a new 1.6.4.56: Tank-containers constructed before 1 July 2023 in accordance with the requirements in force up to 31 December 2022, but which do not conform to the requirements of 6.8.2.2.4 second paragraph applicable from 1 January 2023 may still be used. That transitional provision reflects a new paragraph proposed to specify the use of manhole covers with a test pressure of not less than 4 bar on extra-large tank containers, certainly for liquids and possibly also for solids in the molten state. It was decided to keep the text in square brackets pending the development of specific criteria for these tank containers. The draft text, which appears in the right-hand column of 6.8.2.2.4, reads: [These openings for tank-containers with [a capacity of more than 40 000 litres / a gross weight of more than 36 000 kg] intended for the carriage of [liquids] / [substances in the liquid state] which are not divided by partitions or surge plates into sections of not more than 7 500 litres capacity shall be provided with closures designed for a test pressure of at least 0.4 MPa (4 bar). Hinged dome covers for these tankcontainers with a test pressure of more than 0.6 MPa (6 bar) shall not be permitted.]

The UK proposed amendments to clarify inspection periods in Chapters 6.8, 6.10 and 6.12, which would also harmonise with the terms used in Chapter 6.7. These amendments, which were agreed by the Working Group and adopted in plenary, are editorial in nature, involving the replacement of text such as “at least every” by “no later than”. The UK also proposed textual amendments in 6.8.2.1.23, which concerns welding and the inspection of welds. Again, these proposals were adopted, resulting in the relocation of the final sentence in the first sub-paragraph to the end of the second sub-paragraph, and the addition of a new sub-paragraph before the final paragraph: Welds made during repairs or alterations shall be assessed as above and in accordance with the non-destructive tests specified in the relevant standard(s) referenced in 6.8.2.6.2. A proposal to add a to reference to 6.8.2.1.23 in the third column of the table in 6.8.2.6.2 against standard EN 12972:2018 has been provisionally accepted, with the reference currently in square brackets. The Netherlands and the International Union of Wagon Keepers (UIP) returned to the topic of dry-break couplings, proposing a new footnote to 6.8.2.2.2. However, no consensus could be reached and this matter will be dealt with again at the autumn session of the Joint Meeting. UIP and Poland returned to the issue of the three-month leeway provided for an intermediate inspection, with a question on what is allowed during this period following

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the due date? Some experts were of the opinion that the tank could be used as usual, while others stated that the tank could be carried and emptied, but only if it had been filled before the due date. No consensus was reached other than the topic would benefit from discussion in the plenary. This will take place at the autumn session. Germany had been investigating the safety of ‘liquid ring’ pumps as used on vacuumoperated waste tanks used to carry flammable substances; testing had found risks if the supply of water to the pump is insufficient and Germany proposed the design should be checked against ISO 80079. Several experts observed that there have been no reported incidents involving these pumps. There were other questions about the possibility of future standards that would have to be taken into account, the cost and availability of the pumps, and the possible need for sensors to check the water flow to the pump. Germany will work on provisions to be inserted in 6.10.3.8 and will come back to the topic at a future session. The Netherlands followed up on discussion at the autumn 2020 session of the Working Group on Tanks, where it had offered a proposal to include a clear requirement for the vapour phase of LNG tanks to be equipped with an automatic closing valve. On tanks for refrigerated liquefied gases such as LNG, these lines are actively used during loading and discharge to regulate the pressure in the tank and the valves are open during handling; from a safety point of view it is critical that the valves should close automatically in the case of an emergency, the Netherlands stressed. It offered revised text for 6.8.3.2 and 6.8.3.2.7 as well as a transitional measure. Most experts on the Working Group expressed support in principle for the proposals but it was pointed out that refrigerated liquefied hydrogen may need a different approach and that Chapter 6.7

group was proposed, although it is evident that the issue is urgent and some provisions need to be worked up and adopted in time to be included in the 2023 editions of RID and ADR. The Netherlands and the European Industrial Gases Association (EIGA) were invited to organise an intersessional working group and report back at the autumn session. A new Chapter 6.9 had been adopted into the UN Model Regulations this past December, addressing portable tanks with shells manufactured from fibre-reinforced plastics (FRP). Such tanks have been covered for some time in RID/ADR but it was felt that the UN text represents a considerable improvement and

should be taken into RID/ADR. However, the International Tank Container Organisation (ITCO) urged that this should be deferred as, in its opinion, the UN text does not adequately address the resilience of FRP tanks. Some within the Working Group supported ITCO’s position, others felt that the UN text already offers high safety factors. It was agreed that the Ad hoc Working Group on the Harmonisation of RID/ADR/ADN with the UN Model Regulations should decide on the matter; meanwhile, ITCO was invited to raise its concerns at the July session of the UN Sub-committee on the Transport of Dangerous Goods (TDG). The Working Group on Tanks was also presented with a number of other papers for discussion and possible future action. These included the filling degree for substances carried at and above 50˚C; clarification of the requirements for the application of standards in Chapter 6.2; the thickness of partitions and surge plates in 6.8.2.1.20; the inspection of tanks that have missed the timeframe for their scheduled inspection; and the use of pump/exhauster units for vacuum-operated waste tanks.

should also be addressed. An ad hoc working

 OTHER TANK ISSUES TO BE DISCUSSED INCLUDED THE USE OF FRP TANKS (TOP) AND THE PERIODIC AND INTERMEDIATE INSPECTION OF TANKS

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INSPECTION AND CERTIFICATION The UK provided an update on the ongoing work of the intersessional informal working group on the inspection and certification of tanks (the ‘London group’), which had met in mid-December on a virtual platform under the

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chairmanship of Steve Gillingham (UK). It was attended by representatives of 17 countries, EIGA and UIP. Since the previous meeting, a survey had been circulated to all RID and ADR states, which delivered a clear result: in addition to inspection bodies being approved according to the ISO/IEC system of accreditation, inspection bodies should, as an alternative (and at the discretion of the competent authority under ADR) also be allowed to be approved on a temporary basis according to national provisions until the end of a transition period sufficient for those inspection bodies to be approved according to the ISO/IEC system. The survey results also supported opposition to the use of Type C inspection bodies, or to limit their activities to certain well defined functions. Most who spoke on the topic did not consider Type C inspection bodies to be sufficiently independent of the parties involved. Belgium, the Netherlands and UIP tabled a series of comments on the entry-into-service verification for tank-wagons in 6.8.1.5.5, which included the conclusions of discussions at the RID Committee of Experts’ standing working group. These were supportive of the idea, provided the verification would only be required on an occasional rather than on a systematic basis. This was agreed and 6.8.1.5.5 amended accordingly. Further amendments were made to ensure the use of an appropriate inspection body, and a footnote was added to make it clear that in the case of tank wagons the applicable requirements are satisfied if a vehicle authorisation is received from ERA. Switzerland suggested the development of an explanatory document with a list of fundamental principles on the work on the inspection and certification of tanks, including a summary of the main changes and an overview of authorised activities. The Joint Meeting welcomed that initiative and invited

of inspection bodies, the Joint Meeting endorsed in principle the transitional measures proposed by the UK, pending a final decision at the autumn session. Germany stressed the need to clarify the mutual recognition of inspection bodies during the transitional period. The London Group was scheduled to meet again in early June to pursue outstanding items and to establish some formal proposals for discussion by the Joint Meeting at its autumn session.

submission of a first draft to the informal working group for consideration. It was agreed to resume discussion on the explanatory document during the autumn session. Taking into account that some countries have still to take actions to develop and align their national systems with the future system

manufactured from two parts joined together and in column (5) “31 December 2023, for cylinders without a liner, manufactured from two parts joined together” is inserted. In 6.2.5.4.2, at the end of the sentence “(see also EN 1975:1999 + A1:2003)” is replaced by “(see also EN ISO 7866:2012 + A1:2020)”.

STANDARDS As ever, there were plenty of amendments proposed to take account of new and revised standards published by the International Standardisation Organisation (ISO) and/or the European Committee for Standardisation (CEN). The Working Group on Standards had met on 4 February to consider submissions from CEN and EIGA and its recommendations were passed on to the Joint Meeting, which adopted several amendments. In the table in 6.2.4.1, under “for design and construction”: - For EN ISO 7866:2012 + AC:2014, “Until further notice” becomes “between 1 January 2015 and 31 December 2024” - A new row is added immediately after, for EN ISO 7866:2012 + A1:2020 - For EN 12245:2002, and EN 12245:2009 + A1:2011, a new Note is added in column (2): [This standard shall not be used for gases classified as LPG]; and in column (5) the following text is inserted: [31 December 2023, for cylinders for LPG] - For EN ISO 11118:2015, “Until further notice” becomes “between 1 January 2017 and 31 December 2024” - A new row is added immediately after, for EN ISO 11118:2015 + A1:2020 - For EN 14427:2004 + A1:2005, column (2), a new Note is added: This standard shall not be used for cylinders without a liner,

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There are also several updates in the list of standards in 6.8.4: EN ISO 17640:2010 is updated to EN ISO 17640:2018 EN ISO 17638:2009 is updated to EN ISO 17638:2016 EN 1711:2000 is replaced by EN ISO 17643:2015 EN 14127:2011 is replaced by EN ISO 16809:2019 “EN ISO 23278:2009 – Magnetic particle testing of welds. Acceptance levels” is replaced by “EN ISO 23278:2015 – Non-destructive testing of welds – Magnetic particle testing. Acceptance levels”. This is reflected also in the paragraph following the table. On a UK initiative, a new Note was added to 1.1.5: A standard provides details on how to meet the provisions of RID/ADR/ADN and may include requirements in addition to those set out in RID/ADR/ADN. The UK will submit a proposal for a similar text to be added in the UN Model Regulations. EIGA also proposed some amendments so as to clarify the requirements for the protection of valves on gas cylinders, following

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up on changes already agreed at the previous session. In 4.1.6.8, paragraph (b), “or guards” is added after “protected by caps” and in paragraph (c) “or guards” is replaced by “or permanent protection attachments”. In addition, there are a number of changes to the standards referenced in the Table 1 of 4.1.6.15, applicable to 4.1.6.8. PROPOSALS FOR AMENDMENT There were a number of pending issues that needed to be cleared up before discussion carried on to new proposals. Germany arrived with a revised proposal on the carriage of polymerising wastes; while for non-wastes it is relatively straightforward for the producer or shipper to determine the substance’s properties and the stabilisation or temperature control needed to safely move it, this is not the case for wastes, where the properties are highly variable and quite often

 AS EVER, THERE WERE SEVERAL CHANGES TO THE STANDARDS RELATING TO GAS CYLINDERS, AS WELL AS SOME TEXTUAL CHANGES ON VALVE PROTECTION

unknown. Germany had proposed to establish an appropriate legal basis for the transport of polymerising wastes by means of a new special provision. This time the proposal was adopted, with some further modification and with the proviso that it does not obviate the consignor’s responsibilities to provide the data required for the transport document. The requirement is contained in a new special provision 676: For the carriage of packages containing polymerizing substances the provisions of special provision 386 <(ADR:), in conjunction with 7.1.7.3, 7.1.7.4, 5.4.1.1.15 and 5.4.1.2.3.1,> need not be applied, when carried for disposal or recycling provided the following conditions are met: (a) before loading an examination has shown that there is no significant deviation between the outside temperature of the package and the ambient temperature; (b) the carriage is effected within a period of not more than 24 hours from that examination; (c) t he packages are protected from direct sunlight and from the impact of other sources of heat (e.g. additional loads that are being carried above ambient temperature) during carriage;

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(d) the ambient temperatures during the carriage are below 45 °C; (e) w agons/vehicles and containers are adequately ventilated; (f) the substances are packed in packages with a maximum capacity of 1000 litres. In assessing the substances for carriage under the conditions of this special provision, additional measures to prevent dangerous polymerization may be considered, for example the addition of inhibitors. Special provision 676 is assigned to all UN numbers to which special provision 386 is already assigned. Spain proposed modifying the name and description of UN 2426 Ammonium nitrate, liquid (hot concentrated solution) to align with that used in the UN Model Regulations and the International Maritime Dangerous Goods (IMDG) Code. A note from Sweden indicated that it felt the harmonisation of the provisions was a job for the TDG Subcommittee and was concerned that, if RID/ ADR merely copied over the UN text it could

provision 644, stating “The solution does not contain more than 93% ammonium nitrate”. Spain was invited to take the matter to the TDG Sub-committee to look at the maximum temperature and water content of UN 2426 to clarify the need to include common requirements into the UN Model Regulations. Another paper from Spain proposed revision of special provision 593, which is not fully aligned with the provisions of 5.5.3, making it difficult to apply. SP 593 is assigned to a number of refrigerated liquefied gases, including UN 1913 Neon, 1951 Argon, 1963 Helium, 1970 Krypton, 1977 Nitrogen, 2591 Xenon, 3136 Trifluoromethane and 3158 Gas, nos, when used for the purposes of cooling goods. The provision was introduced in 2001 as a way of carrying out the transport over short distances of small amounts of biological products such as specimens, samples and vaccines. In particular, it addressed the need to carry non-dangerous goods in veterinary applications. However, there is nothing to state that SP 593

alter the scope of the entry. After some discussion, it was decided to accede to Spain’s proposals. This involves the deletion of the words “in a concentration of more than 80% but not more than 93%” from the proper shipping name of UN 2426, and the insertion of a new second indent in special

cannot be used in relation to dangerous goods, although in such cases there is a conflict with the packaging requirements in packing instruction P203(6). Spain felt that it should be made clear that SP 593 is only applicable to gases used for cooling non-dangerous goods; alternatively, it could be deleted altogether.

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The Joint Meeting, as a compromise, agreed a revision of SP 593 to read: This gas, when used for cooling goods not fulfilling the criteria of any class, e.g. medical or biological specimens, if contained in double wall receptacles which comply with the provisions of packing instruction P203, paragraph (6) for open cryogenic receptacles of 4.1.4.1 <(ADN:) of ADR>, is not subject to the requirements of RID/ADR/ADN except as specified in 5.5.3. Meanwhile, Spain said it would take the matter to the TDG Sub-committee for further consideration. Following up on comments made at the previous session, Switzerland came back with the desired solution to its problem of the placarding and labelling of engines and machinery (UN 3528 and 3530). Special provision 363, paragraph (j) provides instructions for the labelling and placarding of such articles with more than 60 litres of fuel but, as Switzerland pointed out, this suggests that once enough of that fuel has

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been used to take the contents below 60 litres, the labels and placards should be removed. This is an onerous task to be given to individuals who will not necessarily have had appropriate training. A simple enough solution was proposed and adopted, in the form of a Note to SP 363(j):

forthcoming session of the Ad hoc Working Group on the Harmonisation of RID/ADR/ADN with the UN Model Regulations, which was due to meet later in April (a report on which will be included in next month’s HCB). Portugal followed up on its work to reorganise the definitions in 1.2.1 by removing

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THE VERY SPECIFIC PROVISIONS IN ADN HAVE RAISED SOME CONFUSION OVER TERMINOLOGY AND DEFINITIONS, WHICH NEEDED TO BE DEALT WITH

On engines and machinery with a capacity of more than 450 l but containing 60 l of liquid fuel or less, labelling and placarding compliant with the above requirements is permitted. Returning to a topic it had introduced at the autumn 2019 session, Spain proposed to align the name and description for UN 1012 Butylene in RID/ADR with that in the UN Model Regulations. Spain had already had success with the TDG Sub-committee, which last year had adopted its proposal to insert a new special provision 398 to state that the entry applies to butylenes, its isomers and mixtures thereof (but not to UN 1055 isobutylene). Spain proposed changes to RID/ADR to copy that text. The Joint Meeting welcomed the proposals and agreed to consider the subject at the

all listed abbreviations and acronyms and placing them in a new 1.2.3. This was adopted by the Joint Meeting. The secretariat advised the Joint Meeting of discussions by the ADN Safety Committee at its session in January 2021 on the subject of definitions. ADN has a particular problem with ‘CMR’, which is defined with reference to the Convention on the Contract for the International Carriage of Goods by Road. However, in ADN terms, ‘CMR’ is used to indicate those substances that have long-term health effects in terms of carcinogenicity, mutagenicity and reproductive toxicity. ADN suggest using that definition in 1.2.1 and placing references to the Convention as footnotes where relevant throughout the text. The ADN Safety Committee also proposed the inclusion of definitions for ‘N1, N2, N3’ (those substances that, for carriage on tank vessels, are classified as hazardous to the aquatic environment), ‘Floater’ and ‘Sinker’. The secretariat was asked to prepare a formal proposal on these definitions for discussion at the next session. The second part of this two-part report on the spring Joint Meeting in next month’s HCB will cover new proposals for amendment, electronic freight documentation and other matters.

96 BACK PAGE

NOT OTHERWISE SPECIFIED COOKING WITH GAS We love a good headline here on the Back Page, we do. This one certainly caught our eye: “Four die in Uttar Pradesh village after inhaling toxic gas released by dung cakes”. For a start, what are dung cakes? We imagined something along the lines of Eccles cakes, a very tasty item from Lancashire that appears to contain rabbit droppings (actually currants) in a sweet pastry case. But no, rather more sensibly, in rural parts of India they are widely used as a fuel for cooking food and consist of dried cow or buffalo dung, formed by hand into usefully sized ‘cakes’. On the upside, dung cakes are a fine example of the circular economy, taking readily available waste material and turning into fuel – biofuel, in fact. They are cheap, locally sourced and reduce the pressure on wood resources. On the downside, they contribute to air pollution, releasing up to four times more volatile organic compounds than burning wood. They can also release more toxic polycyclic aromatic compounds. And it appears that this was the case in the incident being reported by the Press Trust of India. Four men were overcome by fumes while working in the basement of a cement store, also used for drying dung cakes, in the village of Rajpur Kesaria. The four included a man, his two sons and their servant. UNSAFE AND INSANE

fear or panic in other people”. All fireworks that explode, shoot into the air or “move erratically along the ground” are illegal. Fines are hefty for those who are found in breach of the rules. So, when the Los Angeles police received a tip-off about an illegal cache of fireworks at a home in June, they took it very seriously indeed. LAPD officers found more than 5,000 lb (that’s around 2.3 tonnes in real money) of “commercial-grade” fireworks on pallets at the property and decided to move it to trailers parked in the alleyway behind the home for removal and disposal. There were also what police described as “improvised explosive devices”; these were loaded onto a specialised containment truck for detonation. Reporters at the scene, invited along by the police, said that as this operation was in process, one of the Bomb Squad officers moved away from the trailer, yelling “Fire in the hole!!” just before the trailer exploded. The blast injured 16 people, including nine LAPD officers and one from ATF. Even the reporter in a helicopter filming the event from above said he felt the blast. The top of the truck was blown two blocks away, smashing some poor unsuspecting homeowner’s roof. Clearly, the outcome was rather different to what was expected and locals were left wondering whether it was entirely a good idea to dispose of the explosives in a residential

They take fireworks seriously in California. In fact, their use is bound up by plenty of legislation. For instance, it is legal for individuals to buy only “safe and sane” fireworks from licensed retailers from 28 June to 6 July; it is also illegal to discharge fireworks “with the intent of creating chaos,

neighbourhood, certainly without alerting the neighbours beforehand. One man was taken into custody on suspicion of possession of destructive devices, possession of fireworks and child endangerment. Meanwile, LAPD and ATF are trying to figure out what exactly went wrong.

HCB MONTHLY | JULY/AUGUST 2021

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HCB Magazine July/August 2021

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