Tank container guidance from TT Club

ALL ABOUT THE TANK

TANK CONTAINERS • AN EXCELLENT SAFETY RECORD OVER NEARLY 50 YEARS OF INCREASING USE DOES NOT HAPPEN BY ACCIDENT AND, TT CLUB SAYS, THE LESSONS MUST BE HEEDED

THE EXPLOSION AND fire aboard the containership MSC Flaminia in 2012 had a long-lasting impact on the chemical supply chain, ushering in new provisions for the transport of substances liable to autopolymerisation and highlighting the potentially enormous liability shouldered by shippers and their freight forwarders when offering such goods for transport.

The incident also rang alarm bells in the insurance community, given the high liability that emerged. And, while tank containers have a long and enviable safety record, the fact that the fire started in two tank containers with divinyl benzene has challenged assumptions. Indeed, the International Tank Container Organisation (ITCO) has already raised the issue of a lack of expertise among some shippers and tank container operators, given the loss of corporate memory over the years and also the spread of the business into new areas.

The TT Club, a leading mutual insurer for the chemical supply chain, has also given more attention to the tank container sector and last year held seminars on the topic in order to help foster greater understanding of the tank container for those businesses new to the sector or active on the periphery.

TT Club has now collaborated with a number of experts to produce new guidance on managing risks in the tank container supply chain, published as part of its StopLoss series of loss prevention guides. This new publication is intended to be a practitioner’s good practice guide covering all stakeholders through the tank container transport chain, whether operating, filling, discharging, cleaning or handling tanks.

Informed by typical incidents, the document is structured in such a way that it follows the natural chronology of the transport chain in order to provide ease of access. The publication incorporates several pieces of valuable operational reference material, with references to the applicable regulations, concluding with a 13-point checklist aimed at supporting consistent and successful outcomes for the tank container supply chain.

EMERGING RISKS Through analysis of TT Club’s claims record, it has identified a number of common errors and misconceptions in the use of tank containers, which have the potential to result in the deterioration or total loss of the cargo they contain or damage to the equipment itself.

TT Club’s new guidance begins with a recap on the development of the industry, from the first designs of 1969 through the development of the concept through the 1970s, up to the standard design that is common around the world. While take-up of the tank container was slow to start with, its robust design and durability have made it the safest, most cost-efficient, flexible and environmentally friendly way of transporting bulk liquids, including chemicals, around the globe. Shippers are increasingly recognising the versatility of the tank container and favouring its use over drums and parcel tankers, TT Club says.

More recently, operators have increasingly been incorporating emerging technologies, including tracking solutions to provide greater transparency and improve operational efficiencies, dual-temperature control units, telematics units to assist with temperature control and to monitor and record cargo condition during transport, and ground-level controls to minimise the need for personnel to work on top of the tank. All of these make the business of maintaining the condition of the tank itself more complex.

KEEP THE TANK WORKING TT Club’s guidance runs through the regulations covering construction, periodic testing and use of tank containers, including those specific to pressure vessels. It also looks at the selection of equipment in light of the cargo being shipped, with reference to the portable tank instructions found in the International Maritime Dangerous Goods (IMDG) Code and highlighting in particular those regulated substances to which portable tank instructions T23, T50 and T75 apply.

The guidance then moves on to maintenance and testing. Even the newest and most sophisticated equipment requires maintenance, TT Club notes, and tanks are no exception. It is essential to keep tanks and their equipment in a sound state of repair to ensure the efficient operation of the tank. Indeed, the International Convention for Safe Containers, 1972 (CSC) requires operators to develop and operate a maintenance procedure that describes how the tank will be inspected, examined and maintained. The guidance also highlights paragraph 6.7.2.19 of the IMDG Code, which sets out the requirements under the 2.5-year periodic inspection and test.

An important section of the TT Club guidance deals with corrosion. While the tanks of tank containers are usually manufactured of 304L or 316L austenitic stainless steel that is highly resistant to corrosion, certain cargoes – in particular corrosive substances with a chloride element – do present a risk. The guidance explains how and why corrosion can occur and how pitting corrosion can lead to serious problems.

TANKS IN OPERATION The remainder of the TT Club guidance covers operational issues, beginning with the pre-trip inspection (PTI) and cleaning. The PTI is intended to ensure that the equipment is in a safe condition, in proper working order, fit for purpose and that the frame is in a safe condition and within the specification envelope. The PTI must be carried out before the tank is filled.

The cleaning process is crucial to a tank’s proper condition and it is generally good practice to clean the tank as soon as possible after a cargo is discharged. TT Club warns that water used in the cleaning operation in some parts of the world may contain higher levels of chlorine or other impurities that can lead to damage. In addition, it says, it is important for the operator to exercise due diligence in the selection of the cleaning station: as well as the station’s ability to physically clean the tank, each stakeholder has a responsibility to ensure that the environment is sufficiently protected.

The guidance goes on to consider the loading process and the regulations that govern the use of the tank, depending on the product involved. It also covers the necessary placarding for tanks carrying regulated cargoes, the fitting of customs and security seals, and the completion of the Dangerous Goods Declaration, where required. The guidance also looks in some detail at the requirement for a safety data sheet (SDS).

Other factors that may need to be considered are the use of surge plates or baffles to reduce free surface movement, the handling of temperature-sensitive cargoes, and the hot loading of cargoes that are solid at ambient temperatures.

A section on in-transit instructions covers the IMDG Code requirement for a security plan, and the communication of relevant information along the supply chain, something that was highlighted in the court judgment in the MSC Flaminia case.

The guidance enumerates some of the issues that pertain to the choice of service provider to undertake last-mile delivery before addressing re-heating, if necessary, and the discharge operation. It finishes with the actions that need to be taken in the event of an incident, depending on the nature of the cargo and any injuries to personnel, damage to the tank or impact on the environment that result.

TT Club’s guidance, Managing Risk in the Tank Container Supply Chain, is available as a free download from its website at www.ttclub. com/fileadmin/uploads/tt-club/Documents/ Stop_Loss/TT_StopLoss_22_Tank_Containers_ WEB.pdf.

THE MSC FLAMINIA EXPLOSION (OPPOSITE) HIGHLIGHTED

THE NEED TO ENSURE PROPER USE OF TANK CONTAINERS

AND THE NEED TO PROVIDE INFORMATION ALL ALONG