Tank Containers Managing Risk in the Tank Container Supply Chain CONTENTS

Tank containers Managing risk in the tank container supply chain CONTENTS

1. Introduction 3 2. Tank overview and development 3 3. Regulation and standards 4 4. Equipment selection 4 5. Maintenance and testing 6 6. Corrosion 7 7. Pre-trip inspections and cleaning 8 8. Loading cargo into a tank 10 9. In transit instructions 13 9.1 Security 13 10 Final mile delivery 14 11 . Actions in the event of an accident 15 Thirteen point checklist 16 Glossary of terms 18

Acknowledgements The information contained in this StopLoss brieﬁng has been formulated from the TT Club’s experience. However, the Club would also like to thank: ITCO, ETS Consulting, Brookes Bell LLP, Triton International Limited, Brown Gavalas + Fromm LLP and Suttons Group Limited for their assistance in the drafting of this brieﬁng.

StopLoss series StopLoss brieﬁngs are developed on a broad range of topics that give rise to recurring problems. They seek to provide a straightforward summary of an issue, essential good practice advice and, where applicable, sources of further information. The complete series and further information is available at www.ttclub.com/lossprevention and printed copies are available from the TT Club’s Regional Centres.

Disclaimer The information contained in this brieﬁng has been compiled from various sources. Neither TT Club nor the contributors accept responsibility for loss or damage which may arise from reliance on the information contained herein.

Copyright © Through Transport Mutual Services (UK) Ltd 2020. All rights reserved. Users of this brieﬁng may reproduce or transmit it verbatim only. Any other use, including derivative guidance based on this brieﬁng, in any form or by any means is subject to prior permission in writing from Through Transport Mutual Services (UK) Ltd. Managing risk in the tank container supply chain The intermodal transport of bulk liquid and solid cargoes can present operational challenges for all stakeholders in the transport chain.

1. Introduction tank transport chain whether operating, protected within a steel frame. Tanks filling, discharging or handling tanks. are often thought to carry dangerous The portable tank is an intermodal cargo The document is structured in such a goods alone. transport unit (CTU) used for the way that it follows the natural chronology transport of liquids, gases and powders of the transport chain. However, this perception is far from the as bulk cargo. Whilst sections of this text whole truth and as can be seen below, may be applicable to the operation of The IMO / ILO / UN ECE Code of the term “tank” can cover a number of road tank-vehicles, rail tank-wagons, practice for packing cargo transport containment designs intended to non-metallic tanks and intermediate bulk units (CTU Code) 1 is mentioned transport all sorts of bulk liquids, carriers (IBCs) used for transport, the throughout this document. Chapter 2 of powders, granules and liquefied gases; focus here is the UN portable tank, the CTU Code defines various functional tank containers are a type of tank. notably the International Organization for stakeholders in the modern supply chain Standardization (ISO) tank container. whilst Chapter 4 provides details of the Various bodies have defined tanks, tank For ease of reference, the term “tank” responsibilities for each. containers and portable tanks (see will be used to apply to portable tanks, glossary of terms), and it is worth UN portable tanks, intermodal portable In addition to the guidance and information considering how they relate to each other. tanks and tank containers, unless contained within this document, all specifically noted. stakeholders need to be aware of Dangerous goods regulations refer to national, regional and international portable tanks but generally refer to UN Through the analysis of TT Club’s claims regulations concerning the preparation portable tanks and tank containers experience there are a number of and transport of certain commodities. manufactured to ISO 1496-3 2. common errors and misconceptions, which can result in the deterioration or 2. Tanks This guide will concentrate on the most total loss of the cargo and damage to significant designs which are generally the equipment itself. 2.1 Tank overview 20 ft intermodal loading units designed In the freight container industry, the term to carry pressurised liquids or liquefied This document is intended to be a “tank” usually refers to a 20 ft tank gases. However, the text will include practitioner’s good practice guide container consisting of a stainless-steel some information and details relevant to covering all stakeholders through the pressure vessel supported and other designs.

Tank divisions

TANK

Rail Road Portable Non-metalic IBCs Tank-wagons Tank-wagons Tanks Tanks

UN Portable Intermodal Tanks Portable Tanks

Tank Swap-tanks Containers

1 https://www.unece.org/ﬁleadmin/DAM/trans/doc/2014/wp24/CTU_Code_January_2014.pdf 2 https://www.iso.org/obp/ui/#iso:std:iso:1496:-3:ed-5:v1:en

Tank Containers 3 2.2 Tank containers There are currently understood to be in • An approved pressure vessel code (in The first design of the tank dates back excess of 650,000 tanks in the global most instances ASME VIII Div.1) to 1969 and developments of that fleet, and the fleet continues to grow year design through the 1970s resulted in the on year. Swap tanks are regional (mainly • IMDG Code (or similar modal specific general design and structure which we European) CTUs that are used on short dangerous goods regulations) 4. see in today’s fleets. sea, rail and road transport modes and are typically 7.15 or 7.85 metres long, 2,5 or Tanks used for international transport Tanks are built to the same exacting 2.55 metres wide and 2.67 metres high. including a maritime leg must comply standards as other Series 1 ISO or with the CSC, which requires that before European Committee for The volume capacity is larger accordingly, approval for construction is given, Standardization (CEN) freight containers and can carry up to 36,000 litres. prototype testing is carried out to ensure and, with a few exceptions, can be compliance with the Convention. Swap handled in exactly the same way as all Tanks constructed to transport dangerous tanks may not need to comply with this intermodal freight containers. They are goods are usually constructed to meet regulation if it is to be carried on land- suitable for transport by all surface the requirements of IMDG but may also based transport modes (road and rail). modes. Both dangerous goods and have approval for a variety of regulations Tanks should also fully comply with the non-regulated goods (hazardous and including but not limited to ADR, RID 6.7 requirements of the Transports non-hazardous cargoes) can be and CFR4 94. Internationaux Routiers (TIR) Convention 5 transported in tanks. and specific transport mode requirements 2.3 Tank development such as the Union Internationale des Due to its robust design and durability Whilst the tank remains largely chemins (UIC) Code (railway) 6. the tank has become recognised as the unchanged over the years, there are safest, most cost efficient, flexible and emerging technologies, which are being Tank pressure vessels are required to: environmentally friendly means of increasingly used across the industry. transporting bulk liquids and chemicals Global Positioning System (GPS) tracking • undergo weld non-destructive tests globally. The tank’s multimodality allows solutions are being implemented to (usually radiographic) and a hydrostatic seamless transfer between road, rail and provide greater transparency to test on completion of construction sea. Shippers are increasingly operators, owners and lessors improving recognising the versatility of the tank operational efficiencies. • undergo testing every 2.5 years and and favouring its use over traditional 5 years. Failure to pass these tests parcel tankers and drums. Dual temperature control units are results in the portable tank no longer available to provide electrical heating being approved for the carriage of A tank is a pressure vessel, and cooling in transit, providing back-up dangerous goods manufactured in stainless-steel, carbon systems where particularly sensitive steel or a composite material depending cargoes are concerned. Telematics • adhere to ISO 1496-3 – Series 1 on its intended use and is positioned solutions are available to assist with freight containers – specification and within a steel frame which meets ISO, heating control and to monitor and record testing – Part 3: Tank containers for CEN and International Convention for severe shocks during transit, which may liquids, gases and pressurised dry bulk Safe Containers (CSC) standards 3, assist in providing an evidential audit trail which may be: throughout the transit period. • adhere to EN 1432 Swap bodies Swap tanks, dimensions, requirements, • surrounded by an insulation layer Manufacturers also continue to seek to test methods, operating conditions (usually rock wool or glass wool fibre incorporate solutions and controls for block) and a protective outer layer ground level operation, thus minimising 4. Equipment selection ordinarily constructed from the need for personnel to be present on polyurethane and aluminium and/or top of the tank. In this section, we will explore the various glass reinforced plastic (GRP), or options available and considerations to 3. Regulation and standards be taken when selecting the most • protected by a steel sunshield appropriate tank for the shipment of Several areas of the tank industry are cargo. The selection of the correct A standard 20ft ISO tank is 6.05 metres standardised or regulated. Regulations equipment is of importance and will be long, 2.438 metres wide and 2.6 metres include: determined by the volume, mass and high. The volume capacity of a standard characteristics of the cargo to be shipped, tank generally ranges from 14,000 litres • The International Convention for Safe the nature of the journey, and the required to 26,000 litres. Containers, 1972 (CSC) as amended transport temperature for the cargo.

3 http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Convention-for-Safe-Containers-(CSC).aspx 4 International Maritime Dangerous Goods Code (IMDG Code) The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) The Regulation concerning the International Carriage of Dangerous Goods by Rail (RID) Code of Federal Regulations Title 49 (CFR49) - https://www.asme.org/mwg-internal/de5fs23hu73ds/progress?id=SES93HiOH14_Hou0G3Gw1F3cVs2VM1rEXOKBqDImpbU,&dl 5 https://www.unece.org/tir/welcome.html 6 https://uic.org/

4 Tank Containers Many of the chemicals shipped globally Extract from Table IMDG 4.2.5.2.6 – Portable tank instructions are classified as dangerous goods and will fall under the relevant modal regulations. Portable Minimum Minimum Bottom tank shell thickness test pressure opening For example, under the IMDG Code, instruction (reference steel) (bar) requirements portable tank instructions specify the T1 See 6.7.2.4.2 1.5 2 closures requirements applicable for a tank when used for the carriage of specific T2 See 6.7.2.4.2 1.5 3 closures substances. The Dangerous Goods List T3 See 6.7.2.4.2 2.65 2 closures (DGL) in Chapter 3.2 of the IMDG Code defines the tank instruction required for T4 See 6.7.2.4.2 2.65 3 closures each substance that may be transported. T5 See 6.7.2.4.2 2.65 Prohibited Portable tank instructions T 1to T22 specify the applicable minimum test pressure, the T6 See 6.7.2.4.2 4 2 closures minimum shell thickness, the pressure- T7 See 6.7.2.4.2 4 3 closures relief and bottom opening requirements. In practice most tanks for general T8 See 6.7.2.4.2 4 Prohibited purpose use are constructed to T11. T9 6mm 4 Prohibited

Portable tank instructions T1 to T22 are T10 6mm 4 Prohibited generally used for the carriage of T11 See 6.7.2.4.2 6 3 closures dangerous cargoes (liquids and solids) of Class 1 and Class 3 through to Class 9 T12 See 6.7.2.4.2 6 3 closures except Class 7, and non-hazardous bulk T13 6mm 6 Prohibited liquid cargoes. Some bulk solid cargoes are also shipped in tanks. T14 6mm 6 Prohibited T15 See 6.7.2.4.2 10 3 closures Tanks under codes T23, T50 and T75 are more specialised in nature and are T16 See 6.7.2.4.2 10 3 closures frequently designed for the carriage of a T17 6mm 10 3 closures specific intended cargo. T18 6mm 10 3 closures T23 portable tank instruction applies to T19 6mm 10 Prohibited self-reactive substances of Class 4.1 and organic peroxides of Class 5.2. The T20 8mm 10 Prohibited minimum test pressure is 4 bar, other T21 10mm 10 Prohibited specifications such as the shell thickness, pressure relief requirements T22 10mm 10 Prohibited and bottom openings are specific to certain cargo types.

T50 tank instructions apply to the carriage of non-refrigerated liqueﬁed gases and chemicals under pressure.

T75 tank instructions apply to the carriage of refrigerated liqueﬁed gases and chemicals under pressure.

For T50 and T75 tank instructions, the specification of the tank must meet the criteria for the intended cargo to be carried. The minimum test pressures vary from 7 bar to 43 bar; there are also cargo specific stipulations concerning openings below the liquid level, maximum fill ratio and pressure relief requirements.

When a given portable tank instruction is speciﬁed for an intended dangerous cargo, tanks which possess higher minimum test pressures, greater shell thicknesses, more stringent bottom opening, and pressure relief device arrangements may be used. The table below provides a guide as to which tanks

Tank Containers 5 are appropriate for the carriage of are no exception. Under the CTU Code, regulations. This will include the particular substances. the CTU operator (in this instance maintenance and refurbishment of generally the tank owner or a leasing valves and the reseating of hatches. It is necessary to refer to the table in company) is responsible for providing a IMDG at 4.2.5.2.5 to determine CTU that is fit for purpose. Additionally, tanks are required to be additional tank instructions. It should not subjected to a periodic inspection and be assumed that the next higher tank It is essential to keep the equipment in test every 5 years and an intermediate instruction meets the requirements. a sound state of repair to ensure the inspection and test every 2.5 years. As a efficient operation of the tank. Containers guide, the requirements of the For example, the table shows the used for international transport must inspections are set out below. alternatives for T10 are T14, T19, T20 or comply with the CSC with regard to T22 and excludes the use of T11, T12, keeping the container safe. Improper IMDG 6.7.2.19 T13, T15, T16, T17, T18 and T21. maintenance can cause inconvenient The intermediate 2.5 year periodic downtime, costly consequential repairs inspection and test shall at least include: In addition to the items covered under and potential loss of cargo. Establishing the tank instructions below, a tank owner a preventative maintenance schedule • An internal and external examination of must consider the compatibility of the can prove extremely valuable. the tank and its fittings with due regard tank material with the substance (cargo) to the substances intended to be carried, to be transported, especially the Under the CSC, CTU operators are noting that the internal examination resistance of the tank material to required to develop and operate a can be waivered for product-dedicated chemical attack. Corrosive substances maintenance system that describes how equipment at the discretion of the with a chloride content are not the container will be inspected, independent inspection authority compatible with stainless steel and examined and maintained. This scheme might require a special tank lined with should cover the frame of the tank, plus • A leakproofness test chemical resistant material. its connection to the pressure vessel and the prevention of the loss of portable • A check of the satisfactory operation of 5. Maintenance and testing tank service items. all service equipment

Why run the risk of equipment The maintenance of the pressure vessel • Sheathing, thermal insulation shall be breakdown? and service items must comply with the removed only to the extent required for Even the newest, most sophisticated approved pressure vessel regulations reliable appraisal of the condition of equipment requires maintenance; tanks and the relevant modal speciﬁc the tank

Determination of the appropriate tank instruction

Portable tank Portable tank instruction also permitted instruction speciﬁed T2 T3 T4 T5 T6 T7 T8 T9 T10 T11 T12 T13 T14 T15 T16 T17 T18 T19 T20 T21 T22 T23

T1 G G G G G G G G G G G G G G G G G G G GG T2 G G G G G G G G G G G G G G G G GG T3 G G G G G G G G G G G G G G G G G G G T4 G G G G G G G G G G G G G G G GG T5 G G G G G T6 G G G G G G G G G G G G G G GG T7 G G G G G G G G G G G G G GG T8 G G G G G G GG T9 G G G G G GG T10 G G G G T11 G G G G G G G G G GG T12 G G G G G G T13 G G G G G T14 G G G T15 G G G G G GG T16 G G G G T17 G G G GG T18 G G G T19 G G T20 G T21 G T22 T23

6 Tank Containers The 5 year periodic inspection and test The chromium within the stainless-steel When the classification is carried out for shall at least include: forms an oxide layer of protection, the transport of dangerous goods, which is only a few atoms thick, it is this corrosive substances are tested against • An internal and external examination alone which resists corrosion. It should a criterion of causing severe damage be highlighted, however, that this when in contact with living tissue and in • A hydraulic pressure test passive layer can be susceptible to the event of leakage are capable of damage and attack. damaging or destroying other goods, or • Sheathing and thermal insulation shall means of transport. Substances under be removed only to the extent required There are six primary types of corrosion: Class 8 also include those which form a for reliable appraisal of the condition of corrosive liquid only in the presence of the tank • Pitting corrosion – Local disruption of water, or which produce corrosive vapour the passive layer or mist in the presence of natural • When the shell and equipment have moisture of the air. For the purposes of been pressure-tested separately, a • Crevice corrosion – A localised attack classification under the IMDG code, leakproofness test of the assembly on a metal surface at, or immediately substances identified in Packing Groups shall be undertaken adjacent to, the gap or crevice between I and II are not tested against their two joining surfaces corrosivity towards the stainless steel IMDG 6.7.2.19.6 shell of the tank. A tank may not be filled and offered for • General corrosion/attack – Aggressive carriage after the date of expiry of the chemical corrosion Corrosive substances assigned to last 5 year or 2.5 year periodic Packing Group III demonstrate corrosion inspection and test. However, a tank • Stress corrosion cracking – Tensile that does not damage living tissue to full filled prior to the date of expiry of the stress, temperature and corrosive skin thickness but does exhibit a last periodic inspection and test may be species corrosion rate on either steel or carried for a period not to exceed three aluminium surfaces exceeding 6.25 mm months beyond the date of expiry. • Inter-granular corrosion – Sensitisation per year at a test temperature of 55°C when tested on both materials. IMDG6.7.2.19.7 • Galvanic corrosion – Dissimilar On occasion exceptional inspections will metal corrosion 6.3 How vulnerable is the passive be required, where for instance a tank layer to damage/corrosion? shows evidence of damage, corrosion, Corrosion should be a primary concern Stainless steel is only “stainless” when the leakage or other conditions which for tank owners and operators. Whilst surface oxidises with chromium and other indicate a deficiency which could affect tanks are generally constructed from elements to develop a protective film that the integrity of the tank. The extent of stainless steel and are thus resistant to resists further oxidation. This protected the exceptional inspection and test shall staining and corrosion, the carriage of oxide film is considered a passive surface. depend on the amount of damage or certain cargoes or certain cleaning and To passivate stainless steel, a minimum deterioration of the tank. It shall, maintenance operations can lead to of 10. 5-12% chromium is needed. however, include at least the 2.5 year corrosion and pitting. What might initially inspection and test. appear to be minor surface pitting; might Once the passive layer is breached, the be developing under the surface into local area becomes active. This results in For tanks not covered by the CSC, areas of catastrophic corrosion. the formation of a corrosion cell which this requirement would include the then drives the corrosion further owing tank frame. 6.2 Corrosive substances to the surrounding material remaining Class 8 cargoes (corrosive substances) passive (in this way, pit). Damage can 6. Corrosion with chloride content are the generally be caused by the following: predominant challenge where corrosion 6.1 General of tanks is concerned. All substances in • Exposure to aggressive halide ions The pressure vessel of the tank is this class are more or less destructive on (chloride and fluoride) typically constructed of stainless steel, metals and textiles. basic grades of which contain a • Contamination (free iron ions) minimum of 10.5% chromium by mass. Chloride content might apply to many It is the chromium which provides substances, including non-regulated • Physical damage stainless steel with its corrosion substances. For example, sea water can resistant properties by formation of an be corrosive to stainless steel. • Low oxygen environments adherent oxide layer. Substances that are compatible at low temperatures might be corrosive at high • Under-deposit corrosion 304L and 316L grades of stainless temperatures. steel, which are commonly used in the It should be noted that in an oxygen rich construction of tanks, are classes of There are various corrosion compatibility environment, in the absence of pitting, “austenitic” stainless steel. Stainless charts and data available to enable the passive layer can self-repair. steel resists many mineral acids, such as assessment of the substance prior to nitric acid and concentrated sulphuric filling the tank. Care should be Pitting resistance equivalent numbers acid. It has an excellent general taken to ensure that the current condition (PREN) are a theoretical way of corrosion resistance against a wide of the steel is well understood, as such comparing the pitting corrosion resistance range of chemicals that would otherwise charts will benchmark on the basis that of various types of stainless steels, corrode normal carbon steel. the steel is in new and perfect condition. based on their chemical compositions.

Tank Containers 7 The PREN (or PRE) numbers are useful for ranking and comparing the different grades, but cannot be used to predict whether a particular grade will be suitable for a given application, where pitting corrosion may be a hazard.

304L grade stainless steel has PREN of 18.

316L grade stainless steel has PREN of around 25.

Example of a corrosion pit. Visual inspection of the pit provides no information To resist sea water continuously, a about the damage to the subsurface PREN of around 40 is required.

Pitting is most commonly effected by contamination and the presence of halides (such as chlorides). The greater the PREN, the more resistant to halides the stainless steel will be. However, after long periods of exposure to cleaning regimes, aggressive chemicals, sediments and the general rigours of transport, the stainless steel of tanks will become depleted of the beneﬁcial chromium at the surface resulting in decreased passivity. The passivity is easily monitored and can be restored by passivating or, pickling and passivating, in solutions containing nitric acid. If the surface has become pitted over time, then this often needs to be mechanically removed by grinding as the geometry of pits can limit oxygen at the surface, making passivation difﬁcult.

7. Pre-trip inspections and cleaning

Pitting corrosion. Complex interaction of ionic species during pit formation. 7.1 Pre-trip inspection Note the concentration of chloride ions within the pit The objective of the pre-trip inspection (PTI) carried out on every tank prior to ﬁlling with cargo is to ensure:

PTI: Is the equipment in • that the equipment is in a safe a safe condition, proper condition, in proper working order working order and ﬁt for purpose? • that it is ﬁt for purpose

• that the tank frame is visually in a safe condition and that the frame is within the ISO or CEN speciﬁcation envelope; and that the correct components have been installed and are sufﬁcient to withstand the rigours associated with the carriage of the given cargo

7.2 Cleaning After the carriage of dangerous goods, the applicable regulations continue to apply until the tank is cleaned.

There may be the need to transport the tank in empty dirty condition to a location where a suitable cleaning station exists.

8 Tank Containers It is generally good practice to ensure that • UN number • Caustic wash the tank is cleaned as soon as practicably possible following the carriage of cargo. • Proper shipping name • Steam purge Operators should be mindful that a cargo can change its composition if and • Technical name – both to meet the • Solvent pre-solve diesel spin when air or humidity are introduced regulatory requirements for certain especially following discharge. dangerous goods, or for non- • Pickling dangerous goods if it is not clear from Operators should be mindful that water the substance name. The cleaning station should maintain a used in the cleaning process in some database of known cargoes and therefore parts of the world will contain differing • The presence of inert gas or if the tank be in a position to recommend the levels of chlorine and or impurities which is under pressure. required cleaning method in order to clean can “damage” the tank during the the tank. Some of the more challenging cleaning process itself. • The presence of substance residue if cargoes to clean are not necessarily the over 5 litres. most dangerous. Seemingly innocuous The European Federation of Tank cargoes, such as milk, are inherently Cleaning Organisations (EFTCO) defines Virtually any conceivable cargo type can challenging as are more obvious cargoes ‘clean’ in the following way: be cleaned providing the necessary such as inks and dyes. facilities are available. The key criteria “A tank shall be described as clean when for success in this context are: Many shippers have developed extensive there are no visible traces or odour of the lists of banned prior cargoes; those last product or cleaning agent following • The correct identification and which are known even in very small an inspection from the man-lids.” communication of the last carried cargo quantities to compromise the quality of their cargo. The motivation is to mitigate It is important that the CTU operator • The correct instructions identified and the risk of contamination as a result of performs due diligence when selecting passed to the cleaning station. carriage in the tank. Such practices can a service provider where cleaning is provide additional procedural challenges concerned. As well as the cleaning • Any additional relevant information for the tank operator who must also station’s ability to physically clean the passed to the cleaning station consider banned prior cargoes as a part tank, there are ethical sourcing and regarding prior carried cargoes. of the PTI and prior to allocating a tank environmental considerations. Each to be loaded. stakeholder has a corporate social • Heeding expert recommendation from responsibility to ensure where possible the cleaning station. Inevitably, a more intensive clean process that the environment is sufficiently will attract an additional premium in protected. The processing of excess cargo and tank terms of both financial cost and the time washings is dependent on the capability required. Following the cleaning process For example, does the cleaning station of the cleaning facility and national where appropriate the tank must be have a sufficient effluent process system environmental waste disposal licences. dried internally to ensure no water and a licence, as well as a means of remains in the tank prior to the loading disposing of the remnant cargo? Some levels of cleaning may also require process recognising that some cargoes personnel to enter the tank and manually are more sensitive than others. In some The availability of a suitable cleaning inspect. This requires special safety cases cargoes can be rendered out of station should be taken into account procedures including the issue of a tank specification due to high moisture content prior to a cargo being accepted for entry certificate (see also paragraph measured in parts per million (PPM); the transport. It should be appreciated that 11.4 of this document). margins for error are very small. not all cargoes will be able to be processed by an individual cleaning Certain types of tank can give rise to Once the tank has been cleaned the station. Checks should be made to verify additional challenges through the cleaning station should issue a cleaning the cleaning station’s: cleaning process. Inevitably tanks fitted certificate (a cleanliness certificate can with surge/baffle plates have a greater also be requested but this would be • Permits, licences and environmental internal surface area to clean due to the made out by an independent inspection requirements additional internal structure. Moreover, company to confirm the level of the areas where the baffle plates are cleanliness of the tank – this would • Range of substances licenced and fixed in place provide excellent locations normally involve the inspector entering equipped to clean for stubborn cargo remnants to reside. the tank to confirm the condition of the barrel). • Quality and safety records Examples of common wash instructions: The cleaning certificate will vary in form • Commercial arrangements • Cold water wash globally, noting that there are regional recognised standards such as the The operator should report the following • Detergent wash European Cleaning Document (ECD) 7 information to the cleaning station which is often issued by European regarding the last carried cargo: • Chemical rinse Federation of Tank Cleaning

7 https://www.eftco.org/eftco-cleaning-document/explanation-and-guidance

Tank Containers 9 Organisation (EFTCO) approved 8.2 Pre-checks rail limitations in any country passed cleaning stations. Other documents are Given the complexities of the modern through during the planned transport used globally such as the ITCO ACC day supply chain the shipper or the Cleanliness Certificate 8. freight forwarder could be performing • Close the man lids and valves, and the functions of the packer. Under the secure the fastenings Such standards set the benchmark for CTU Code, the packer is responsible for the services to be provided but also ensuring that: • Close any compartments fitted and seek to address and clarify the liability securely fasten to prevent any risk of of the cleaning station in the event of a • the tank has been checked and verified opening during transport. Be aware loss post clean. The primary as fit and clean for use before loading that a compartment breaking open in requirement is for the tank to be clean, commences transit can be extremely dangerous dry and odour free. and cause high consequence damage • the tank is safe to use Once the cleaning process is complete • Where IMDG regulated cargoes are the placards and markings on the tank • a banned prior cargo has not been concerned, affix the applicable should be removed. After it has cooled shipped in the tank that may be placards and markings so as to prevent a vacuum forming, incompatible with the planned valves and fittings may be secured and consignment • Where appropriate affix Customs and the tank made ready for the next security seals to valves and entry assignment. • the cargo has been correctly points to ensure that they cannot be prepared in terms of temperature and opened during transport The cleaning certificate does not treatments where applicable; and guarantee that the tank is safe to enter. Loading facilities will vary in their levels Problems can occur for example with 8.3 Packing/filling of sophistication in terms of the rubber lined tanks which can hold Under the CTU Code the Consignor is equipment used to fill tanks. product even after the tank has been responsible for providing all information thoroughly cleaned thus creating a required for the proper filling of the The filling process should be appropriate hostile environment which may not subject cargo. The packer (loader) is to the consignment and tank packing support life. In particular, be alert to responsible for ensuring that the instruction. When filling, it is important enclosed space risks 9. transport and packing instructions are that the filled tank does not present a adhered to and that the cargo is risk to those involved with handling and Once the certificate has been signed sufficiently “secured”, such as all valves transporting it, or to members of the and the tank has left the premises of the fully closed. general public. Therefore, it is essential cleaning station, it is difficult to establish that liquids are not allowed to surge any liability on the part of the cleaning General good practice regarding loading: uncontrollably resulting in the tank station in the event of a post clean loss. becoming unstable (see also section 8.4). • Ensure that the cargo is loaded In dangerous goods regulations such as 8. Loading cargo into a tank according to any consignor’s guidelines the IMDG Code at chapter 4.2.1.9.6; which may be available for that calculations are given for the degree of 8.1 General particular substance filling, however, these calculations are The process of loading cargoes into a just as valid for non-regulated liquids. tank will be influenced by the • Ensure that the tank is not over or Therefore, no tank should be overfilled classification and the characteristics of under filled by volume according to (which may over pressurise the barrel or the cargo being shipped. The shipper/ the degree of filling assigned by the cause spillages), or under filled (which consignor is responsible for the IMDG dangerous goods list tank may increase the instability of the tank classification of the cargo under the provision (TP) unless fitted with baffles or sub-divided applicable regulations. into compartments). • Tanks shall not be offered for transport The classification of the cargo will with a degree of filling for liquids On completion of loading the IMDG prescribe under the applicable having a viscosity less than 2,680 Dangerous Goods Declaration should be regulations as to how it should be stored, mm²/s at 20°C, or at the maximum completed including, where applicable, a handled, loaded and treated during temperature of the substance during “Shipper’s Declaration” and a transit. It is important to maintain transport in the case of a heated “Container/Vehicle Packing Certificate”. compliance with such requirements substance, of more than 20% but less relating to loading cargo into a tank. than 80% unless the shell is divided, by Example of a shipper’s declaration: partitions or surge plates, into sections Of course, not all cargoes shipped in of not more than 7,500 L capacity I hereby declare that the contents of this tanks are dangerous, for example many consignment are fully and accurately food grade cargoes are shipped • Ensure that the gross mass of the described below by the proper shipping globally. In terms of equipment selection, loaded tank does not exceed the name, and are classified, marked and these cargoes require dedicated food maximum permissible operating gross labelled/ placarded and are in all grade tanks. mass of the container or any road or respects in proper condition for transport

8 https://www.international-tank-container.org/storage/uploads/ACC09-2017-A4.pdf 9 https: //www.ttclub.com/loss-prevention/publications/stop-loss/stop-loss -19-conﬁned-spaces-managing-the-risk-of-entering-cargo-transport-tanks -1 45295/

10 Tank Containers according to the applicable national and to which the tank is exposed to. During 8.5 Safety Data Sheet (SDS) international governmental regulations. extreme manoeuvres (sudden turning, A safety data sheet is a document starting or stopping) the tank and that lists information relating to Example of a container/vehicle carrying vehicle can become so unstable occupational safety and health for the packing certificate declaration: that they can severely affect the driving use of various substances and products. characteristics of the transport vehicle This forms a non-mandatory widely I hereby declare that the goods described which may result in the vehicle turning used system for cataloguing information above have been packed/ loaded into the over. A sub-design of tank are baffle on chemicals, chemical compounds, container/ vehicle identified above in tanks, which are designed to reduce and chemical mixtures. accordance with the applicable provisions. product surge, thus reducing the risk of turn overs, and used for smaller/larger An SDS is a document created for This must be completed and signed for transport loads. Baffle or surge plates substances or mixtures containing a all container/ vehicle loads by the are installed within the barrel to wide range of information on the person responsible for packing. compartmentalise the load space to a composition, physical, chemical, health maximum of 7,500 litres each. A standard and environmental effects of the All tanks being transported internationally 26,000 litre tank would, therefore, require substance or mixture and on the safe by sea are subject to SOLAS that three sets of baffle/surge plates. usage, storage and disposal of the requires that a Verified Gross Mass products along with spill-handling (VGM) is provided by the shipper to the To mitigate the effects of free surface procedures. ship’s master and the terminal before it movement, the IMDG Code stipulates can be loaded. SOLAS 10 also prohibits minimum and maximum permissible fill An SDS for a substance is not primarily the loading of any container where the levels for tanks. Where lower volumes of intended for use by the general VGM or actual gross mass is greater cargo are to be shipped, either consumer, focusing instead on the than the maximum operational gross specialised low capacity tanks or tanks hazards of working with the material in mass of the container 11. fitted with surge plates are required. an occupational setting. There is also a duty to properly label substances on the 8.4 Free surface movement Generally, tank containers should have a basis of physico-chemical, health, or (liquid surge) minimum fill capacity of 80% by volume. environmental risk. The free surface effect is a mechanism Where the tank is being shipped in which can cause a tank to become empty dirty condition the tank should Some countries impose an explicit duty unstable and refers to the tendency of not be transported with more than 20% of care that each SDS be regularly liquids to move in response to the forces by volume. updated, usually every three to five

10 International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended 11 https://www.ttclub.com/loss-prevention/container-weighing/

Tank Containers 11 must be shipped immediately following the completion of packing, and the cargo is known not to cool quickly, there may be requirements for additional notations and markings on the tank to remain compliant with the applicable regulations and to ensure other stakeholders are aware of the potential dangers.

Tanks being packed/filled with a hot cargo that is to be released from the packing facility for transport in a liquid state at a temperature at or above Mitigating the risks of liquid surge with a baffled tank 100°C or in a solid state at or above 240°C shall be marked on both sides and each end with a special elevated years. However, when new information diligence checks on cargoes to ensure, temperature marking as below. becomes available, an SDS must be as far as is practicable, that the revised without delay. information they are receiving is accurate Elevated temperature carriage mark and appropriate. A dangerous goods Substances which are not classified as advisor may be able to ascertain whether dangerous goods are referred to as non- the information provided within the SDS M m in m im regulated (or commonly non-dangerous is reasonable and correctly classified. A 0 u 5 m 2 or non-hazardous goods). Non-regulated knowledge of the cargo may also be n d io im s e does not mean that the substance is useful so that prior incidents involving n n e s im io free of danger or hazard. the same cargo can be referenced for d n 2 m u 5 any recommendations made as a result 0 im m in m The format of the SDS is specified by of the incidents regarding the storage, M the Globally Harmonized System of handling and transport. Classification and Labelling of Chemicals (GHS) 12. Where the applicable sections of the Minimum dimension 250mm SDS are incomplete, the information is The GHS stipulates that the SDS should inconsistent or the tank operator has follow a standard 16 section format and doubts, then concerns should be raised 9. In transit instructions detail all of the characteristics of the with the shipper and/ or consignor prior cargo under various different sections. All to the cargo being packed. 9.1 Security of the sections are of importance but the The IMDG Code requires a security plan four sections of particular importance in 8.6 Temperature sensitive cargoes designed to prevent misuse of high the context of this document are: Some cargoes are temperature sensitive consequence dangerous goods in a and require either temperature- terrorist event. Section 2 – Hazard identification controlled tanks or chemical stabilisation This section includes the label elements when being shipped. Shippers must National authorities might also apply that should accompany the cargo. undertake due diligence to establish additional security provisions. such requirements and ensure that Section 6 – Accidental release measures suitable tanks are requested, and High consequence dangerous goods are Of particular importance to those provided, for the defined by the Code as those which transporting or handling the tank where consignment to ensure safe transport. have a potential for misuse in a terrorist there is an incident that results in a Where such cargoes are concerned incident and which may, as a result, release of the cargo. there is a requirement that the shipper produce serious consequences such as forwards accurate information and any mass casualties or mass destruction. Section 7 – Handling and storage regulatory requirements onto all Precautions for safe handling and the stakeholders in the transport chain. The table in the IMDG Code at 1.4.3.1 conditions for safe storage include provides an indicative list of these (not incompatible substances and 8.7 Hot loading Class 7). segregation. Certain cargoes become solid at ambient temperatures and therefore are required Notwithstanding the Code’s provisions Section 14 – Transport information to be packed into the tank at an elevated for high consequence dangerous goods, UN number and proper shipping name, temperature. Once packed, the cargo will operators are recommended to consider plus transport classes and packing groups. cool and likely solidify during transport. developing a security plan to ensure the Care must be taken by tank operators to safekeeping of all tanks and substances Tank operators require that consignors ensure that the loading temperature is transported. Not least to ensure secure provide up to date SDSs for the known along with the rate at which the processes, depots, transport contractors consignments, and in turn undertake due cargo cools and solidifies. If the cargo and shipping routes are considered.

12 https://www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html

12 Tank Containers 9.2 Chain of communication documents are obtained. The SDS will 10. Final mile delivery Each stakeholder in the transport chain take prominence through the booking has a responsibility to pass sufficient acceptance and the Dangerous Goods 10.1 Collecting the tank for delivery and relevant information regarding the Declaration (DGD) will be pivotal in Operators should undertake due cargo and transport requirement to stowage planning. diligence 13 when appointing a haulier or stakeholders so that safety in the third-party service provide. transport chain and the integrity of the It should be highlighted that ensuring cargo is maintained. Careful scrutiny of the correct classification and SDS are At the time the tank is collected from the the instructions at each stage is obtained is not always sufficient. Of the destination port or depot for delivery to fundamental to the successful shipment many documents which may accompany the consignee, the following checks of cargoes in tanks. a dangerous goods shipment, the DGD should be carried out by the trained and is the critical document in terms of qualified collecting driver, regardless of The shipper is responsible for ensuring information being communicated to the whether the inland haulage is arranged that the cargo is correctly described and shipping line. This document is prepared by the carrier or the consignee: classified and to notify the packer (who by the consignor or shipper thus certifying may be a freight forwarder) of any that the dangerous goods being shipped • Visual check that the tank appears specific instructions in relation to the have been packaged, labelled and structurally sound pending shipment. declared in accordance with the applicable regulations. It is this document rather than • The areas and structures around the The bulk liquid transport chain can be the SDS upon which the shipping line will discharge valve are free of apparent complex especially where international rely in determining the ship stowage plan. impact damage. shipments are concerned. Each stakeholder in the transport chain • There are no apparent leaks 9.3 In the event of a loss has a duty of care and obligation to warn When incidents arise, it is often due to other stakeholders of any known dangers • The security seal remains intact and simple instructions not being passed concerning the cargo being shipped, displays the correct seal number between the various stakeholders, especially where these characteristics highlighting the need for accuracy in may not be immediately apparent. • The temperature gauge on the tank data, instructions and documentation. reflects the details in the transport Ambiguity or poorly worded notations documentation (where applicable) Where dangerous goods are concerned can also be an attributing factor. Where it is imperative to ensure that the cargo instructions appear to be less than • All handles on the discharge valve is correctly identified, classified and certain, the relevant stakeholder should remain in the fully closed position declared and the relevant supporting seek clarification prior to proceeding.

13 https://www.ttclub.com/loss-prevention/publications/stop-loss/stop-loss-21-due-diligence-to-increase-safety-and-security-151227/

Tank Containers 13 • The correct chassis/ low loader is used The type of heating applied will depend The consignee must monitor the and all twist locks are engaged. on the sensitivity of the cargo to be discharge to ensure that the negative heated and the urgency to achieve a pressure inside the tank barrel remains • The required cargo placards are liquefied state. The coils are designed at tolerable levels. displayed and securely fitted to be plugged into different heat sources. Applying hot water into the The consignee should have a means in In some countries, additional coils provides a sensitive increase in place to determine and verify the volume consideration may have to be given to temperature. Applying pressurised of cargo discharged. the available equipment, the expertise of steam through the coils provides the the local haulage contractors, poor road fastest heating option; more sensitive It is good practice to ensure that quality and general infrastructure. cargoes however may be damaged as pre-discharge samples are secured and a result of the associated sharp rise analysed. The consignee should have Upon arrival at the delivery point, the in temperature. an established method of analysing consignee should always carry out the pre-discharge samples to ensure that same initial checks of the tank structure, Careful management of the heating the cargo conforms to the expected seal and settings as listed above. process is critical in ensuring that the specification. cargo integrity is maintained as well as 10.2 Re-heating (if required) avoiding potentially catastrophic In the event that any quality irregularities If the cargo must be heated prior to explosion incidents. Where steam is are noted immediately upon taking discharge, ensure that an appropriate used to heat the cargo over pressurising pre-discharge samples, the consignee service provider is appointed to is a risk which can result in temperatures should not commence discharge, notify undertake the work and that accurate, which exceed the design of the steam the carrier and arrange for a surveyor unambiguous instructions in writing are coils (usually 130 degrees Celsius). to attend. always provided to them. It is necessary to ensure that the In cases where quality irregularities are Where cargoes must be heated to temperature gauge remains undamaged only noted during or after the tank has facilitate discharge there are various and in sound working order as this is been fully discharged, the consignee options open to the operator. Each tank often used as a guide as to the should undertake a risk assessment and is constructed with a series of coils temperature of the cargo within. endeavour to notify the shipper as soon around the shell of the pressure vessel. as possible, and an independent surveyor The number of coils varies from tank to 10.3 Discharging should be appointed to investigate. tank dependant on the initial A tank is normally discharged from the specification. Generally, the more coils, bottom valve opening, although top Upon completion of the discharge there the more quickly the cargo can be discharge is possible too. During the will often be some residue of the cargo heated, although the steam allowable discharge there is a risk of creating a remaining within the tank. The tank pressure rating of the tank is also a vacuum which can result in catastrophic should be as empty as practicably determining factor. damage to the tank. possible. Cargo residue is expensive to

14 Tank Containers remove at the cleaning facility and conforming with CSC safety criteria, it they can have serious consequences dangerous goods will attract additional may not be possible for it to continue its and come in two major categories: safety procedures. intended transport. There may be the need to tranship the cargo into a • The risks associated with confined At this point the tank is considered to be replacement tank, ensuring compliance spaces for those working inside the in an empty dirty state. Placards and with all loading and regulatory tank barrel can be high if the correct IMDG dangerous goods regulations requirements. equipment is not available or used and continue to apply until the tank is confined entry permit procedures are cleaned (see paragraph 7.2 Cleaning). 11.2 Leaking cargo not strictly followed. For more in depth Where tanks are severely damaged, cargo advice concerning confined space risk, 11. Actions in the event of an incident may leak from the barrel. In such please see TT Club’s StopLoss 19: circumstances, where practicable, the Confined spaces: Managing the risk of Whilst the tank is recognised as the safest leak should be stemmed, or if not possible, entering cargo transport tanks. means of transporting bulk liquids, there the tank placed in a leak tray, bunded area are occasions where incidents occur (walled concrete surfaced area) or • Another potential bodily injury risk which may give rise to insurance claims. surrounded with containment boom/bund exposure is working at height. There is Whilst such incidents are relatively few in to ensure that the cargo is contained – the need to work on top of the tank for number, given the nature of some of the preventing a wider pollution risk. a variety of reasons. Where work is cargoes being transported, there is the carried out at height, robust procedures risk of potentially large exposure The type of cargo being carried will should be in place, and followed, to incidents. In this section we look to influence how those responding to the ensure that personnel are sufficiently highlight the safety features of the tank incident will be able to proceed and the protected and not able to fall. All and provide good practice guidance in level of personal protective equipment stakeholders must comply with the the event of an incident. (PPE) they may require. The type of cargo applicable regulations where working will also influence how the surrounding at height is concerned, recognising 11.1 Typical safety features areas should be managed; areas may that there will likely be national and The thermal insulation layer of the tank need to be evacuated if it is assessed regional variations. shell provides, in addition to its thermal that they might be exposed to danger. qualities, a degree of protection in the Example working at height regulations: event of an impact. 11.3 Contamination The most common type of loss relates to European Directive 2001/45/EC Flame guards and bursting/frangible cargo contamination, including where “Working at Height ”14 discs are fitted to vacuum relief devices the cargo does not meet the specification and spring-loaded valves to mitigate the expected by the consignee. These UK: The Work at Height Regulations 2005 risks where tanks are exposed to incidents arise for a number of reasons, external fire incidents. often not directly attributable to the tank 11.5 Crisis management itself. Occasionally the stubborn remnants When considering risk assessment and The bottom discharge valves comprise of of a prior cargo will be freed by an management it is generally good three closures in series; the internal aggressive Class 8 cargo and show in the practice for all stakeholders in the tank spring-loaded foot valve, the outlet valve pre-discharge samples at the consignee. supply chain to have a robust crisis and a screwed sealing cap or flange. Pre-discharge samples indicating management plan in place which is problems may include discolouration or tested periodically. This plan should also In the event of a catastrophic damage to the presence of suspended particles. consider an emergency response plan in the external portions of the bottom the event of a catastrophic incident. discharge valve, the outlet valve support These particles may be attributable to a pipe is designed with a shear groove prior cargo or an incompatible component. 11.6 Post incident allowing the external part of the valve to Stakeholders need to scrutinise the shear from the tank leaving the tank Where contamination cases are physical and contractual chain to identify barrel and the internal valve intact and concerned, early and transparent (if possible) where the error has containing the cargo. interaction with the cargo owner will occurred with a view to holding the encourage a positive handling of the responsible party liable at an early stage. A safety valve is provided in the top of incident which can result in early the tank to relieve excess pressure that resolution. The solution to many cargo At the earliest practicable opportunity might build as a result of a cargo contamination incidents is reasonably following the discovery of an issue (once chemical reaction or overheating. cost-effective filtering or reworking. any immediate risk is contained and However it is imperative that the cargo under control) the priority should be to The many safety features of the tank are interests are involved in the early stages notify your liability insurer, and consider such that even in the event of of the investigation in order to the early appointment of an independent reasonably serious damage incidents, encourage them to take such action. surveyor/expert. Depending on the type the cargo is contained within the barrel and seriousness of the incident early and therefore the integrity of the cargo 11.4 Injuries action investigating and gathering is maintained. If the damage sustained Injuries for those working with tanks are relative information will assist in results in the frame of the tank no longer few in number; however, when they occur, mitigating the potential loss and liability.

14 https://op.europa.eu/en/publication-detail/-/publication/c4e26d24-8bd3-4d15-8204-3cbfe43fa32c/language-en

Tank Containers 15 Thirteen point checklist

Whilst the earlier chapters consider each stage of the tank transport chain in detail, below is a 13-point checklist which can serve to provide guidance for an intended shipment. If the answers to the thirteen questions are in the positive, then whilst it doesn’t cover every eventuality, the risk of loss through the supply chain will be greatly reduced.

1. Has the cargo to be shipped been clearly identiﬁed and correctly classiﬁed – do I have a current and fully completed SDS?

2. Have any special requirements/instructions been adequately considered and communicated?

3. If required to do so, do I have sufﬁcient information to complete the Dangerous Goods Declaration?

4. Is the selected tank appropriate for the cargo to be carried (see tank instructions)?

5. Has the pre-trip inspection been successfully completed?

6. Is a valid cleaning certiﬁcate available for the tank?

7. Is the last cargo transported in the tank compliant with the shipper’s requirements?

8. Are the components of the tank to be used in good condition and compatible with the cargo to be shipped?

9. Is the volume of cargo suitable to avoid over or under ﬁlling and within the weight limits for the entire journey?

10. Has the shipper provided instructions and have these been passed accurately to all stakeholders through the intended transport chain?

11. Upon completion of ﬁlling have the valves and ﬁttings been correctly closed and seals applied?

12. Has a transport plan been considered including any applicable national restrictions for the entire journey?

13. Are the correct placards and markings in place?

16 Tank Containers

Glossary of terms

Cargo transport unit (CTU) IMDG Code The portable tank shall be capable of Means a road freight vehicle, a railway Means the current edition of the being loaded and discharged without the freight wagon, a freight container, a road International Maritime Dangerous Goods need of removal of its structural tank vehicle, a railway tank or a portable (IMDG) Code adopted by the Maritime equipment. It shall possess stabilising tank. Used as an alternative to Safety Committee of International members external to the shell and shall Intermodal Loading Unit (ILU) Maritime Organisation (IMO). be capable of being lifted when full. It shall be designed primarily to be loaded Carrier Intermodal portable tank on a vehicle or vessel and is equipped The party who, in a contract of carriage, Means a specific class of portable tanks with skids, mountings or accessories to undertakes to perform or to procure the designed primarily for international facilitate mechanical handling. Road performance of carriage by rail, road, intermodal use. tank-vehicles, rail tank-wagons, non- sea, inland waterway or by a combination metallic tanks, gas cylinders, large of such modes. Lessor receptacles and intermediate bulk A person or company who leases containers (IBCs) are not considered to Clean equipment to another company. fall within this definition. A tank shall be described as clean when there are no visible traces or odour of the NVOCC PTI last product or cleaning agent following Non-vessel operating common carrier. Pre-trip inspection. A series of checks an inspection from the man-lids. A shipment consolidator or freight carried out before the CTU in question is forwarder who does not own any vessel, assigned to carry out its assigned tasks. Cleaning certificate but functions as a carrier by issuing its Document issued by the cleaning facility own bills of lading or waybills and SDS to confirm that the tank is clean. assumes responsibility for the shipments. Safety data sheet is a document created for substances or mixtures containing a Consignee Packer wide range of information on the The party to whom a cargo is consigned The party that loads, places or fills the composition, physical, chemical, health under contract of carriage or transport cargo within or on the CTU; the packer and environmental effects of the document or electronic record. Also may be contracted either by the substance or mixture and on the safe known as the receiver. consignor, the shipper, by the freight usage, transport, storage and disposal of forwarder or by the carrier; if the the products. Consignor consignor or the shipper packs a CTU The party who prepares a consignment within his own premises, the consignor Shipper for transport. If the consignor contracts or the shipper is also the packer. The party named on the bill of lading or the transport operation with the carrier, waybill as shipper and/or who concludes the consignor will undertake the function Portable tank a contract of carriage (or in whose name of the shipper. Means: or on whose behalf a contract of carriage has been concluded) with the CTU Code • For the purposes of the transport of carrier. In tank operations, under the IMO / ILO / UN ECE Code of practice substances of Class 1 and Classes 3 ocean bill of lading, the “shipper” may be for packing cargo transport units to 9, a multimodal portable tank. It the CTU operator acting as NVOCC. intended to assist the industry, includes a shell fitted with service employers’ and equipment and structural equipment Tank workers’ organisations as well as necessary for the transport of Means a portable tank, including a tank Governments in ensuring the safe dangerous goods. container, a road tank-vehicle, a rail tank- stowage of cargo in containers. wagon or a receptacle to contain solids, • For the purposes of transport of non- liquids, or gases, having a capacity of not CTU Operator refrigerated, liquefied gases of Class 2, less than 450 litres when for the The party who operates the CTU and a multimodal tank having a capacity of transport of gases. provides empty CTUs to the consignor/ more than 450 litres. It includes a shell shipper/packer may be referred to as fitted with service equipment and Tank Container tank operator. structural equipment necessary for the Means a portable tank with fittings, transport of gases. structural capabilities and dimensions DGN that enable it to be handled and secured The Dangerous Goods Note (or • For the purposes of transport of by the same means as any ISO Dangerous Goods Declaration) is used refrigerated liquefied gases, a thermally configured container and complies with to accompany deliveries of hazardous insulated tank having a capacity of the requirements of ISO 1496-3. goods in transit. more than 450 litres fitted with service equipment and structural equipment necessary for the transport of refrigerated liquefied gases.

18 Tank Containers TT Club TT Club is the established market-leading independent provider of mutual insurance and related risk management services to the international transport and logistics industry. TT Club’s primary objective is to help make the industry safer and more secure. Founded in 1968, the Club has more than 1100 Members, spanning container owners and operators, ports and terminals, and logistics companies, working across maritime, road, rail, and air. TT Club is renowned for its high-quality service, in- depth industry knowledge and enduring Member loyalty. It retains more than 93% of its Members with a third of its entire membership having chosen to insure with the Club for 20 years or more. ttclub.com

Thomas Miller TT Club is managed by Thomas Miller, an independent and international provider of market leading insurance services. Most of the businesses we currently own or manage are acknowledged leaders in their chosen market. Our portfolio includes mutual organisations and, increasingly, specialist insurance services businesses. thomasmiller.com ttclub.com

STOPLOSS 22 – AH/MY/CD 06/20