Large scale growth in the tank sector will undoubtedly provide many opportunities for logistics operators of tank containers as greater capacity will be required to serve chemical commodity trades. However, as is often the case, opportunity does not come without risk.
Analysis of TT’s claims point to the primary risks being those of impact incidents, internal pitting (from corrosion) and cargo contamination. It is believed the increased occurrence of impacts involving tanks is a factor of higher volumes of tanks handled at maritime and intermodal terminals with the greater proportion of such incidents occurring at these locations. Increased congestion, it is suggested, puts additional pressure on operators of handling equipment to achieve greater throughput levels.
Contamination and corrosion issues in large part originate in inappropriate cargo care and insufficient cleaning and maintenance regimes. TT’s guidance in mitigating such risks revolves around operator preparation and knowledge.
It is important to know your customer. TT has had experience where low-grade chemicals were mis-sold as higher-grade products, leading to rejection of the cargo by the consignee as being out of specification. While in essence a sales contract issue, the logistics operator can be exposed to significant storage costs while the dispute between seller and buyer is resolved, frequently tying up large numbers of ISO tanks for several months. In one instance this was compounded when, after several months, it was discovered that the low-grade material had solidified and had begun to attack the integrity of the ISO tank, resulting in deep pitting to the steel shell and rendering the tanks as total losses.
As basic good practice, TT recommends that robust selection criteria is developed, particularly when it comes to the employment of sub-contractors whether they be haulage contractors, tank cleaning and heating stations or repair facilities.
Risks can become enlarged when companies move into unfamiliar operational territories, it is essential for them to achieve a full appreciation of the prevailing market conditions, general business culture and expectations from local parties such as enforcement agencies. Since local economic and business ethics may differ, a local partner or agent could prove invaluable in providing assistance and expertise.
While cargo contamination has a number of potential causes, an area of focus is the expediency and sufficiency of cleaning the unit following discharge of cargo.
In order to avoid such issues, it is imperative to ensure that the last carried cargo is fully removed from the tank container before the next cargo is loaded. Effective cleaning after each carried consignment is therefore of paramount importance.
The transport of certain products may require additional internal cleaning, including removal of valves and changing of contaminated seals and gaskets, to prevent contamination of the next cargo. As part of the pre-trip inspection the cleanliness of the tank container should be checked to ensure that it meets the requirement of the shipper, especially where some prior cargoes are banned or the cargo to be transported has particular sensitivities.
The availability of a suitable cleaning station should be taken into account prior to a cargo being accepted for transport; certain cargoes may not be able to be processed. The risks inherent in transporting the tank container in ‘empty/dirty’ condition to a location where there is a suitable cleaning station also need to be assessed.
Apart from identifying a competent cleaning station, successful cleaning will require complete and informative instructions, such as:
- Full identification of the last carried commodity
- Complete and accurate cleaning instructions, taking account of future use of the unit
- Any additional relevant information regarding prior carried cargoes
Certain types of tank container can give rise to additional challenges for the cleaning process. For example, units fitted with surge or baffle plates have a greater surface area to clean due to the additional internal structure and the areas where the baffle plates are fixed present particular challenges.
The tank operator should also perform due diligence in selecting a service provider; in addition to the pure ability physically to clean the unit, there are ethical sourcing and environmental considerations. For example, the cleaning station should be able to demonstrate an effluent process system and licencing concerning disposal of remnant cargo. (See checklist.)
The provision of the following Thirteen Point Checklist is TT’s attempt to encapsulate, in easily digestible form, the major risk mitigation actions that operators can employ:
- Has the cargo to be shipped been clearly identified and correctly classified – do I have a current and fully completed Safety Data Sheet (SDS)?
- Have any special requirements/instructions been adequately considered and communicated?
- If required to do so, is there sufficient information available to complete the Dangerous Goods Declaration?
- Is the selected tank appropriate for the cargo to be carried?
- Has the pre-trip inspection been successfully completed?
- Is a valid cleaning certificate available for the tank?
- Is the last cargo transported in the tank compliant with the shipper’s requirements?
- Are the components of the tank to be used in good condition and compatible with the cargo to be shipped?
- Is the volume of cargo suitable to avoid over or under filling and within the weight limits for the entire journey?
- Has the shipper provided instructions and have these been passed accurately to all stakeholders through the intended transport chain?
- Upon completion of filling have the valves and fittings been correctly closed and seals applied?
- Has a transport plan been considered including any applicable national restrictions for the entire journey?
- Are the correct placard and markings in place?
In conclusion, business growth always comes with a certain amount of risk. From the employment of new and potentially unfamiliar contractors to entering contracts with what may be new shippers, operators will likely – and in some cases unwittingly – expose themselves to operational and commercial risks. This should not detract from the positive search for new opportunities for the tank container sector. But careful preparation before embarking on expansion makes shrewd business sense.