With this type of cargo, different clients have different requirements, including the
type of gaskets, which should be used.
Trade organization of international road hauliers ask following
question. One of our members has put me a question that gives me some problems. One of his
drivers is afraid that he might fall down if he climbs a tank container.
What does the international regulations say on how the driver or others that climb a tank
container must be secured?
How high may a driver or others climb a tank container without special equipment fitted to
the tank container?
ANSWER
The international regulations CSC and ISO 1496 give design criteria for access ladders
and walkways but do not cover handrails.
Some companies have tanks fitted with fixed or detachable handrail systems as a private
undertaking.
Others like my previous company used portable stairs and a safety gantry system, when a
tank was on a trailer. (see attached details and supplier (D Harker Fabrications).
The safe access and working on tanks is not covered by the Transport Design codes but by
the Health and Safety Executive of each country under ECE Directive issued in 1992 under
NO. ISBN 0717601436.
Adequate protection must be provided for anybody working above 2 metres. My understanding
of this directive is as follows:
When a tank is in a chemical plant it is the responsibility of the plant to provide safe
access to the top of the tank.
When a tank is in a transport depot the depot is responsible for providing a safe working
environment.
Hand Rail Problems.
1.Even with handrails fitted somebody has to go to the top of a tank to erect the guard
rail.
2.High maintenance costs.
3.Transport problems on rail due to damage to overhead power lines.
4.Gantry clearances in certain chemical plants.
The use of a personal harness is not recommended as they are a trip hazard and can
cause damage when a person falls.
At the end of the day each company must carry out their own risk assessment and provide
the necessary safety equipment to suit their own operational needs.
Jack Hopkins - Technical Advisor to ITCO
Referring to our resent telephone conversation, I would appreciate of
having a detailed explanation for following terms.
Lessor, Lessee, Operator, Depot, Manufacturer and Leasing Company.
The reason for the question is quite simple: we are a new company and want to use
absolutely correct terms.
ANSWER
First I want to explain about ITCO :
In ITCO you have 3 divisions
Manufacturing companies of tanks and spare parts
Leasing companies
Operating companies
Depots and Inspection and certification companies are artificially placed under
Manufacturing
Trucking companies fall under Operators.
A Manufacturing company is a company which manufactures ISO Tank Containers - 20'
standard frame such as Consani, CPV, Welfit Oddy, WEW, Suretank, Ebrotank, M1, Trencor,
UBH. FORT VALE and PEROLO are spare part manufacturers.
A leasing company is a company which lease containers to the Industry and to Operators
the main ones are EXSIF, TRIFLEET,CRONOS, GESEACO,TANKSPAN, MULTISTAR,PEACOCK.
Operators are companies offering door to door transport , using ISO Tank Containers and
having at least one sea leg in the transport. For example a transport from Helsinki to
Bangkok.
These companies usually own a large part of their fleet and lease the other part. The
operators , member of ITCO are : Bulkhaul, Den Hartogh, Derijke, Haesaerts, Hoyer, Huktra,
Interflow, Nightfreigt, Seabrook, Stolt tank Container, Suttons , Tilcon, UTT,VOTG, TABY.
Please advise name of contact in Austria concerning following
issue : Any chance to help me with problem in Austria.
We have had a couple of tanks stopped by the police, in fact the same policeman, he states
the tanks do not conform to ADR due to test pressure and outlet, he demands a
« T »10 but IMDG states a « T »4 can be used. As the job is being
done under IMDG and a sea journey was prior to the road journey the ADR allows the
carriage under IMDG type tanks.
Do you know anyone in the EU transport Commission or in Austria we can contact. The
vehicle has been impounded by the police for 4 days, and they are demanding a
transhipment ! !
ANSWER
Mr Olli Perkanniemi from EEC answers :
Article 6 of Directive 94/55/EC on transport of dangerous goods by road states that
each Member State MAY authorise this kind of transport.
Therefor I would suggest that you contact Dr Gustav Kafka, in charge in Austria of TDG.
Tel 43 1 711 62 1500
Following answer was given by our adviser : Jack Hopkins :
Since I do not know your product I assume the IMDG "T4" is correct.
ADR marginal 1.1.4.2 and 1.1.4.3 (pages 10 & 11) allow a tank built before 1st January
2003 complying to IMDG to be used for an ADR journey involving a maritime transport.
However the transport documents should be marked in accordance with marginals 5.4.1.1.7
and 5.4.1.1.8 (page 226)
Provided the above conditions have been adhered to the "Austrian Bobby" is wrong
impounding the tank.
Referring to my earlier e-mails to you, I need to ask for your
assistance in following matter. During the market research process we have been confronted
with a statement that wall thicknesses of containers are getting thinner to save material
in production.
That would lead us in a situation where grinding would not be adequate in the future, only
polishing.
Can you advise us about the right channels to confirm or refrase this matter. Thank you in
advance.
With best regards,
Jari Nenonen
Robogrind Oy
Siltakatu 64 A
04400 Järvenpää
Finland
Tel: +358 40 703 0101
Fax: +358 9 2791 271
e-mail: jari.nenonen@robogrind.fi
Further to my previous e-mail, I have been confronted with a question regarding
responsibilites between contract partners.
Let`s assume that a customer orders grinding work, manual or robotized and a contractor
takes off material to the extend that shell thickness falls below acceptable limit and
tank cannot be used eversince.
Is contractor then responsible for the damage and if so, to what extend.
Are these matters discussed at ITCO`s forum and how could I get information in greater
detail.
I would appreciate your assistance in this regard.
FIRST ANSWER
The answer to the first question is definitely yes , manufacturers are attempting to
decrease the plate thickness in order to lower the gross weight of the container and
secondly to reduce the cost of material.
Is that the right way to go ? This is a valid question which should interest everybody in
the industry. This point will be investigated and we will revert
The question of responsibility normally comes under "what is in the contract
between the owner of the tank and the depot who carries out the work: the depot will under
normal circumstances be held responsible only if it is proven that they have made an error
Willy
Did there come up any news in the thermal link issue since 12.03.2002?
Last information was that it is permitted to unload an IM portable tank while it is
remaining on a transport vehicle with the power unit attached. Until October 1, 2003 it is
not reqiured for these IM portable tanks to be equipped with a thermal means of remote
activation of the internal self-closing stop-valves fitted on the bottom discharge outlet.
ANSWER
The facts as stated in your e-mail are absolutely correct for IM portable tanks
transporting liquid hazardous materials that is flammable, pyrophoric, oxidising or toxic.
The bottom outlet requirements must be as marginal CFR49: 175.275(d)(3), and the shipper
and the carrier will share responsibility for verifying certain safety conditions at the
consignee's facility are met.
These requirements are listed on page 8221 (centre section) of Federal Register Vol 67 No.
36/ Friday Feb 22, 2002.
The extension to the implementation date of the "Thermal Link" until October 1st
2003 is intended to provide manufacturers, lessors and users of IM Portable Tanks a total
of 5 years from the effective final rule date Oct 1st 1998, to modify tanks (for US/DOT
use only).
The USA proposal for including thermally activated closing mechanisms for internal valves
was rejected at UN Geneva meeting 3-11 DEC 2001.
US delegate to submit new proposal to United Nations for further discussions.
Looks like this regulation will be a special requirement for USA. I doubt it will be
included in IMDG, UN or ADR/RID.
Dot 51 Tanks for Non Refrigerated Liquefied Gases
CFR 49 - 178. 276 ( Page 849) gives design criteria.
Filling/discharge opening located below liquid level must be fitted with thermal means of
closure - marginal 178.276 (4) page 851.
The deferment by the USA on thermal links does not extend to DOT 51 tanks as no reference
to 178276 is mentioned only 178275.
There is also no mention of unloading on a transport vehicle with power unit removed. Just
a statement that a DOT 51 type tank a thermal link must be fitted.
It is different reading for IM portable tanks to that for DOT 51.
IM portable tanks will be to :- (also un portable tanks)
a) 177.834 (4) (0) page 730 - unloading.
(b) 178.275 (E) (iv) page 846 - outlet.
(c) Deferred until Oct 1st 2003.
No mention of special requirements for loading.
DOT 51 will be to :-
(a) I cannot find any reference to loading / unloading on a vehicle ( If you find please
let me know).
(b) 178.276 (4) page 851 - outlet.
(c) No deferment granted.
"UN Orange Book" section 6.7
does not require any thermal links just standard 3 bottom closures and remote closure of
internal valve.
J Hopkins - Technical Department ITCO.
I would like to know if ITCO also has companies involved in producing
refrigerated container as members? and furthermore if you could provide me with the
figures for the numbers of refrigerated container produced world wide on a yearly basis?
ANSWER
We are an association of Tank Containers active in the liquids and bulk powder
transportation mode.
Various "refrigeration" type of liquid containers are employed in the
transportation of specialised liquids and most of the manufacturers in our association
build these units for special applications. We do not however manufacture refrigerated box
type containers.
I trust the above answers your question.
I' m an Italian student of mechanical engineering and actually my research work is based on tank container studies.
Mainly I need information about tank container history, I looked for that, but didn't find anything unfortunately.
So it would be great and really helpful for me and I would appreciate so much if you could suggest me some articles, links, web resources, books and so on, and the location in which I could find something about that.
Thanks very much for the time you granted me and for everything you can do for me.
ANSWER
I attach 2 articles about the history of the Tank Containers : .
- History of tank containers by Jan Gerhard-De Vries, January 93 (pdf-32Kb)
- 30 years of tank containers and swap tanks by Jan Huigen and Bob Fossey (pdf-26Kb)
These Articles provide good information but were subject to many disagreements amongst the ITCO membership.
They are welcomed to be completed by pictures and other sources of information
Willy Freson
I have a basic knowledge about english, right now I am an IICL inspector
,and i would like to know how may i become in an isotank inspector ?
What are the steps that a have to follow to become in an ITCO inspector?
ANSWER
This same question has come up several times ,and ITCO is presently looking in setting up,training courses for inspectors. This issue will be dealt with during our General meeting in Brussels end January 2004
Willy Freson
I do hear a rumour that there is a push to try and eliminate aluminium and it's alloys from all ADR units by
reducing the melting point requirement on materials used for construction.
I have feelers out through other contacts we have at UN level, do you know anything about this / could you ask around through your contacts on how seriously this is being considered?
This is possibly a political battle between stainless and ally plate manufacturers and may not transpire to anything.
ANSWER
I have made a couple of calls to people with their ear to the ground regarding the above subject, neither have heard anything.
I am shocked if it is the French who would push for a "higher" melting point for metals used to manufacture tanks or trailers.
As you know the French have submitted a paper for consideration by WP 15 for aluminium cryogenic liquid tanks, with regard to the minimum thickness of the inner vessel,
If anything it may be single skin petroleum / fuel oil tanks, where the fire risk is far higher.
Your contact at the society of motor manufacturers and traders would know if there was anything afoot.
J Hopkins - Technical Department ITCO
I would like to know if ITCO also has companies involved in producing
refrigerated container as members? and furthermore if you could provide me
with the figures for the numbers of refrigerated container produced
world wide on a yearly basis?
ANSWER
We are an association of Tank Containers active in the liquids and bulk
powder transportation mode.
Various "refrigeration" type of liquid containers are employed in the
transportation of specialised liquids and most of the manufacturers in our
association build these units for special applications. We do not however
manufacture refrigerated box type containers.
I currently hold a iicl container inspectors certification and as such often revalidate CSC inspections on containers. my query is can i witness 2.5 yr and 5 yr hydrostatic tests on tanktainers.
ANSWER
My understanding of the 2.5/5 year periodical inspections in accordance with US/DOT, ADR, RID, IMDG and PED is as follows:
The Competent Authorities of each Country approve certain nominated companies to inspect tanks and issue globally accepted certification on their behalf.
IE. Lloyds Register
Bureau Veritas
American Bureau of Shipping. ETC.
These companies employ surveyors who carry out the field inspections in accordance with the designated regulations and report back to their regional offices, who issue the corresponding certification.
CSC inspections are controlled by the Health & Safety under approved ACEP systems or individual inspections
with no certification necessary just the nameplate stamping. Independent surveyors can under take these inspections
on the tank frame and mountings.
All the surveyors for IMDG, ADR/RID & US/DOT I have ever met are time served engineers from a marine, chemical or
mechanical background.
Mostly they are employed by the classification societies but a very few are self-employed surveyors who work on a subcontract basis for the classification societies.
These societies issue approved certification, which is normally accepted worldwide.
I have known tanks held up because a particular country would not accept a BV or ABS certificate they wanted a Lloyds Cert.
Also because there has been passed cases of litigation between tank owner and classification societies regarding tank defects not identified at the periodical test,
the classification societies prefer to use their own surveyors that subcontract ones.
Independent surveyors certification would not be accepted in Europe.
The US/DOT have granted approval to a number of repair facilities within the USA to perform their inspections and issue US/DOT certification /stamp nameplates. These repair facilities do not have the necessary
European approvals therefore a second surveyor is required. This method is not cost effective.
J Hopkins - Technical Department ITCO
We are in need of some suitable tanks for transportation of AHF.
Please let us know if you are in a position to provide new/used tanks on lease or on outright basis.
ANSWER
If the product is Anhydrous Hydrogen Fluoride (?) then an IMO 1 tank is not
enough, you need :
Top outlet only , fitted with bursting discs.
Cannot be carried in stainless steel tanks . Lined tanks are required.
Unfortunately you need to contact a manufacturer , which you can find in our list of members.
Willy Freson
We understand that isocontainers rental conditions (we guess world wide agreements)
establish that emptied isocontainers should be thoroughly cleaned and residues properly disposed before
being reshipped in empty conditions to another country, in order not to be in conflict with the Basle
Treaty on Dangerous Waste: Is that the case?
What is the practice in e.g Europe regarding handling empty iso-containers?
Are disposal certificates needed every time you empty and ask to clean an emptied
iso-container, in order to cover the company's "from cradle to grave" liability, since we do no owe
the container itself but do the product?
What about those isocontainers, which contained specific chemicals, which cannot
be treated on site or those which it is not recommended or even counter indicated to be treated by
unskilled people? . Are those cases considered by the international regulations?
Are there any worldwide treaties or legislation or regulations which specifically
cover the "dirty isocontainers" matter ?
Are there any worldwide treaty / regulation which specifically exclude trading
dirty isocontainers from the restrictions imposed by the Basle Treaty?
(like it hapen for example with bulk oil tankers).
ANSWER
In Europe :
Mty/dirty (ADR classified) tanks are supposed to be carried as if they were loaded,
which means with cmr's & hazchem.cards.
On top of that tanks are supposed to be labelled in accordance with either ADR/IMDG depending on the
structure of the traffic (deep-sea/intereuropean).
In case a tank is mty (cleaned) a document should accompany the tank evidencing
same has been cleaned.
The CEFIC,ECTA and EFTCO have taken the initiative and are currently working on
the design of document to (fully) cover latter issue, and get this implemented
in the ADR.
They are also working on a list of approved (read fully licensed) cleaning
stations.
In the USA;
- OK to move haz residues provided properly documented and placarded
- disposals should be dealt with by qualified cleaning stations
Can someone comment further on the Basle Treaty ?
Could you give us an idea where is the best place to purchase the newest Code and Regulations
listed below:
IMDG, UNADR, CFR, DETRID, CSC, UIC and TIR
Also, any recommendations concerning other regulations not listed here.
ANSWER
All the codes quoted can be purchased from The Stationary Office. Tel no 0870 600 5522 or e-mail to:
- esupport@theso.co.uk
You ensure you request the latest editions.
J Hopkins - Technical Department ITCO
Do you have information about the check-digit algorithm of the container code?
We know an old algorithm but meanwhile we see some container where this algorithm doesn't fit.
Are there different algorithms?
ANSWER
There is only one calculation for determining the check digit which follows
the owners letters and tank numbers.
The formula used to be shown in the BIC-code but I see they have deleted it
and offer a service to do the calculation for a fee. The formula is shown in
the UIC 592 code but I do not have a copy this code.
The formula is not straight forward but it is briefly as follows:-
Each letter is given a numerical value with A being 1, B=2, C=3 etc down to
Z=26
Example of calculation for tank number ABCD 123456
Tank letters A B C D
Tank no & letter values 1 2 3 4 - 1 2 3 4 5 6
code to multiply above 1 2 4 8 16 32 64 128 256 512
-----------------------------------------
1 4 12 32 16 64 192 512 1280 3072
Add all resultant nos to give total = 5185
Divide total by 11 5185/11=471.3636364
Multiply whole no by 11 471 x11=5182
Subtract result from 1st total 5185-5182=3
The result is the check digit =3
If you change any letter or number the check digit changes.
If the remainder is 10 then check digit is 0.
I have a special chart that I have developed that makes it straight forward to check tank numbers
J Hopkins - Technical Department ITCO
I am trying to determine what regulations exist with regards to Tank Container
Markings i.e. who or what says that we need to fit ABCD008801/0 to 4 sides of the tank, who or what
says that we need to fit MAWP labels or No Fork lift labels or RID/ADR labels etc.
I have scoured the ADR and 12th edition of UN but I cannot find any references other than that of
what must go on the Data Plate.
If you are familiar with any of the relevant regulations I would be grateful if you could point
me in the right direction.
ANSWER
I can well imagine your confusion relating to the above subject. It is something
we all take for granted, but exactly what dictates why we mark tanks as we do has taken a fair
amount of research so here are my findings:
It is a chain of inter linked standards :
ADR,RID, IMDG all make reference to tank containers/portable tanks conforming to ISO 1496/3
ISO 1496(Technical data on tank containers)refers to ISO6346 (Coding, Identification & Marking of tanks).
ISO 6346 requires an unique owners identification system.
3 letters plus the letter "U" plus 6 numbers and check digit.
Country code
Size & type code of tank
Various other operational markings etc.
All tanks are approved to TIR for international transport. The Customs Convention also stipulates in
Annex 1 tanks must be marked in accordance with ISO6346
UIC 592-2 OR also requires the same markings for movements of tanks under RID regulations.
The ISO Alpha code for each owner is registered with the Bureau International Des Containers in Paris.
AAR600 also requires owners/manufactures to register each tank with the Alpha code into their computer
system before being presented for transport on US railways. A large fine is imposed for any tank
found not in compliance.
I could go on a great length but hope this brief description will suffice.
J Hopkins - Technical Department ITCO
The questions are related to regulatory matters and, specifically, about
the impact test requirements included now in the IMDG Code (2000) and ADR/RID (2003).
The Spanish authorities are applying these new requirements in the most strict and inflexible
way. I would like to know if other authorities apply the same policy, or if it comes like that
straight from the regulations. The position of the Spanish authorities is as follows:
1.ADR (2003) comes into force on 1st July 2003
2.All prototypes approved before that date need to be re-approved in accordance with 2003 edition
(i.e., one unit needs to be impact tested in Tergnier, France). This means that all previous
approvals are no longer valid until the test is made and no new unit can be built until then.
3.There is absolutely no possibility to avoid the actual impact test on a unit, and that unit
has to be of exactly the same characteristics as the prototype to be re-approved. In CSC it is
possible to get one prototype approved based on one similar that has been actually tested, simply
demonstrating by calculations that the new is, at least, as strong as the previous. The Spanish
authorities do not accept to get away from performing an actual impact test.
The questions are:
1.Do the other national authorities also put in force ADR 2003 on 1st July?
2.Do all previous approvals are considered null until an impact test is performed?
3.Particularly worrying is point 3 above, as it would oblige us to impact test about a dozen of
prototypes that we have already approved using previous editions of ADR and IMDG Code. Is there
a possibility in the regulations -or other authorities accept- to waive the impact test based on
a previous similar prototype tested?
Your response / comments to the above would be very much appreciated.
ANSWER
The Spanish Authorities are incorrect in their interpretation of the new IMDG
and ADR regulations which do come into force 1st July 2003.
Existing design approvals and impact tests are acceptable to the new regulations with further testing.
Existing tanks which may not have been rail impacted tested can still be used to the new regulations
by virtue of ADR marginal 1.1.4.3 ( page 11 ) It allows tanks built and approved before 1st Jan 2003
compiling to the previous IMDG and ADR to be used until 31st Dec 2009 provided certain conditions are complied with.
This is mainly inspection and test provisions and tank instructions from various columns are met.
Also the demand to test each type is wrong.-ADR marginal 6.7.2.18.1 allows designs of smaller tanks
meeting certain criteria to use an existing approval.
I have checked with 2 other uk operators who confirm they are not having any problems with the Spanish
Authorities provided the port authority is notified in advance of the tanks full approvals and test dates by e-mail.
I also checked with BV and they also confirm the above is correct.
J Hopkins - Technical Department ITCO
In the latest issue of ACC , as in previous issue , Section 4 - Paintwork , refers to Euro Standard Re4.
Could you please send me copy of the relavent part of the Euro Re4 Standard for
reference and also advise if there is an Americian equivalent to the Euro
Standard that depots in USA can apply.
ANSWER
I do not know of an equivalent Us specification or were to obtain a copy of the RE4.
The answer to your question about RE4 is this is a standard of corrosion on metal. It is similar
to the standards for shot blasting i.e. SA2 ½. And used mainly in the bridge building industries
to measure the level of corrosion over the entire surface.
Here is the full scope of standards.
Each standard is the level of corrosion permitted on the entire surface.
RE 1 = 0.05%
RE 2 = 0.5%
RE 3 = 1%
RE 4 = 3%
RE 5 = 8%
RE 6 = 15 > 20 %
RE 7 = 40> 50 %
RE 8 = 75 > 80 %
RE 9 = 95%
IT'S TITLE IS THE European standard (RE LEVEL OF CORROSION).
Further :
To the question : where can the Re4 chart as specified in section 4 Paintwork of the ACC be obtained ?
And is there a precise title of the document ?.
The answer is : Unfortunately , the booklet has no title ; it is published by the European Committee of Paint,
Printing Ink and Artists' Colours Manufacturers' Associations ( CEPE ).
You can either go on their web site www.cepe.org/CEPE.htm or send them an e-mail to secretariat@cepe.org
In our depot now, there is one isotank that has 4 holes in the tank shell.
The probable cause is gunshots. These diameter of the holes is about 20 mm
So my question is what should I do to repair this tank. Can we patch the hole with same material from interior ?
ANSWER
Is it possible to have some photographs of the damaged areas so we can try to work out a repair procedure.
You cannot just patch the holes from the inside. With damage to this extent you would have to insert the
shell, then have all repaired areas X rayed then hydro test the tank under the supervision of Bureau Veritas or LLyods
Inspector.
All material used must be the same as the shell already is. The person carrying out this procedure must be
coded to carry out this type of repair.
(1) Remove section of grp panel for accsess to damaged shell area x3.
(2) looking at the damage cut out shell 150mm x 150mm x 3 each insert must have all corners radious.
(3) Once all areas cut out and inserts prpared fit inserts in to shell from outside and tack weld in useing the T.I.G. process.
(4) Once tack welded in weld inside of shell first again useing T.I.G. process.
(5) When completed cut back the burn through on the insert from the outside again useing the T.I.G.
process, once this is completed have all repaired areas of repairs. Ultrasonic tested.
(6) When passed this process go back in side and polish all welds smooth on repaired areas when this
process completed tank has to be Hydro tested and witnessed by a LLoyds or Bureau veritas inspector.
(7) When all these processes completed replace insulation and over patch the GRP patches.
- Replacement of corner post, the original measurent of corner post is 15 x 18 cm, but very difficult to
find this kind of steel in our country, is it possible to join two U shape of steel (7.5 - 18 cm) ?
- The material of the frame should be CORTEN STEEL or what ?
ANSWER
It is very unusual for corner post to be manufactured from Corten Steel.
Mostly the equivalent to British Standard BS 4360 Grade 50C is used, but to
be completely sure you should check with the Container manufacturer for the
exact grade.
The correct thickness of the existing member should be matched or exceeded.
The use of two channel sections welded together in place of a seamless
rectangular section is deemed an unacceptable repair for a major load
bearing member.
Some large cold rolled hollow sections are formed with two equal profiles
but the welded joint is 100 % x-rayed .Examine the damaged post to see if it
is of this type of manufacture.If it is then you can carry out the two piece
repair.
The weld must be a full penetration weld and not just a fillet sat on the
top of the section.IE you must fully weld prep both members before butting
them together.
I cannot give you a straight yes or no, there are to many variables.
One is certain you must carry out the repair under an insurance company and
the repair recorded on an addendum and forwarded to the tank owner.
J Hopkins - Technical Department ITCO
I have a question regardind ADR rules.
According to ADR new edition each swap tank containers is identified through
a code (i.e. L4BN, L10CH, ...).
Is there a programme (software) where you give in input the ADR code of
the tank and the programme print a list of all the carriable product?
Please let me know if it exist and where it is possible to buy it.
ANSWER
I am not aware any soft ware which performs the function you are looking for.
A number of classification societies have compiled lists of substances which
can be transported in the various types of tank. IE Lloyds Register - B.
Veritas.
These approved lists of substances are normally attached to the ADR/RID Type
Approval Certificate.
I think there is some money to be made for somebody who bring out this type
of software.
I have another technical question and I hope to have an official answer.
I have a discussion with Bureau Veritas about the meaning of "....thermal insulation made of material
which are not readily flammable." reported in the ADR.
Bureau Veritas sent me a fax in which is stated:
"In this case reference must be made to IMDG which gives more precise details i.e. the insulation
material must remain effective at all temperatures up to 649°C and be jacketed with a material having
a melting point of 649°C or greater."
Our swap tank containers are insulated with polyurethane or glasswool or rockwool and are jacketed with
aluminium or stainless steel or GRP us the 99% of the insulated swap tank containers in the world.
According to Bureau Veritas poit of view the material that we use for insulation and cladding not comply with ADR request.
I do not agree at all because:
- I am talking about RID/ADR swap tank containers without IMO;
- all the other manufacturer use the same material but do not have this problem even if they work with Bureau Veritas as well.
How can I solve this problem?
Is there an official document which states the mining of "material not readily flammable"?
ANSWER
I cannot understand BV's concerns. The wording in IMDG and US/DOT has been present for at
least 5 years and as you rightly state your insulation materials are no different from any other manufacturer.
Ask BV how they have approved other previous tank designs.
During my manufacturering and design days I had similar problems with Lloyds Register when this text was
introduced and from memory I took the following actions to solve the problem.
The polyurethane foam had a flame retardant added so it was self extinguishing.
Glass wool and Fibre glass have a melting point higher than the 649 degree C.
The plastic section of the GRP will melt before the 649 degree but glass matting backing on the GRP panels
remains intact securing the insulation.
I obtained letters from my supplier to support these facts and because all these materials came from the
same supplier , he under took a test to prove the facts.
Alum. is just about at the 649 before melting, but Lloyds looked at it as unlikely that the whole of
the tank was lightly to covered by fire and therefore heat would be conducted away.
St.steel has no problems with this tempt. and therefore the insulation beneath is in no danger of burning.
Hope this will help you solve the issue with BV.
We currently run a successful Refrigerated Transport Business in Australia
and some of our customers are asking for Refrigerated Bulk Tankers to transport there liquid products
across Australia. These are currently transported in drums, plastic liners and other forms of small containers.
We are trying to find self power refrigeration for these units so that the tank container stays within the 20'
(6m) length. Could you please help pointing us in the correct direction, either in Australia or elsewhere,
where we could find what we are looking for.
ANSWER
There is a unit that is available in Japan but it is electric powered
The self power part would be that it can run self sufficiently (ie with its own diesel
power Thermoking or Carrier unit or with a generator attached to run the electric powered refrigeration unit
(like the sea container units)).
As we intend to run these units by rail across Australia (4000km) and the trains do not have electric power
available we would need self powered units
ANSWER
Seacontainers used to run Reefer tanks with a clip on generator unit ,I believe
most of these were sold to Tiphook and were inhertied by Transamerica then Exsif. Im copying in Exsif (Graham Wood)
on this reply because maybe he can confirm if I am right or not and maybe they can help you with their
portable generator units they used for their Reefertank
(Graham's reply)
These tanks were designed to take a clip on generator which is mounted on the top rail and bolted back
to the frame with special brackets. The type that fits is a "nose mount" minimum output required 15KVA 3 phase nominal
440 volts.
to help avoid a recurrence, I want to share with ITCO members a serious safety incident
that took place at our Immingham depot, and ask that you circulate this information in the interest of safety.
I am not aware of any ITCO protocol for doing this but trust you will ensure the information is shared. (The risk
also applies to box container depots using the same type of equipment.)
For some of the repair and maintenance work we undertake, we lift the tankcontainer onto four separate corner stands
that are 50 cms high, thus lifting the tank off the ground. The stands have base plates that are intended to provide
stability and spread the weight on the ground. At the top of the stand post there are lugs that fit into the container
corner castings in the same way as a twist lock but without the lock. I am sure most members will be familiar with the concept.
The accident demonstrated that separate corner stands do not stay upright if subjected to a sideways pressure. In our case
the tank was gently nudged by a manouvering vehicle and one corner fell over causing serious injury to a fitter.
Whilst there are other issues still under review, we have concluded that it is unsafe to use four separate stands and have
withdrawn them from use and in future will only use stands connected to each other by a frame.
In case anyone has doubt that it may not apply to them, we have used these type of stands without incident for over twenty
years, and thought them to be safe. Having spoken to a number of depots following the accident we know that others use
similar equipment with the same confidence that we previously had, and hope they will now learn from our experience and
check the lateral stability of their stands.
ANSWER
Further to my earlier message explaining the 'corner stands' accident and sharing the basic problem with
members, I want to add to the learning that can be had from our experience.
Our accident was not a regular exposure but happened when all the components came together, and as a result of looking more
carefully for the cause we believe additional information could be of benefit to members.
Our more complete analysis of the accident identified we should also revisit the control measures we have in place to
safeguard pedestrians and other personnel at ground level, when we have lift trucks and heavy goods vehicles moving within the depot.
For those based in the UK they should be aware that the UK HSE have identified 'Workplace transport' as one of their
important areas of focus, and this in addition to the 'Working at Height' project will become more evedent in the
future when they deal with our industry. However workplace transport will apply to all sites, and not just depots such as we operate.
Could you please inform me whether there are specifications available concerning the filter
that should be used when unloading drinking water from a tank container ?
ANSWER
I did ask your question to one of of our member, container manufacturing company, who replied as follows:
"About a filter - am not aware of requirement but can make reference to previous time when I was involved in food grade
applications. Then the customer had us fit a bursting disc with a double membrane lining which had the effect of ensuring
that no bacteria or dust particles could be taken in through the pressure relief system. ( some climatic conditions make
for significant air-borne sand and dust) the double lining ensured that should one rupture, then you had a second system in place.
Otherwise, you could be asked for a sanitary valve on the discharge section ( which basically has a clean flow, highly polished
surface completely free from the possibility of product entrapment)
The initial inspection will ensure the internal surface is acceptable. The only other area of care is with the gasket and
this for food is usually sweet white rubber or nitrile.
We were asked if our tcs have the following certification:
PED (Pressure EquipmentDirective) -CE law no. : 97/23/CE
This cert. is necessary starting from 29.05.02.???
ANSWER
Here is a meeting of the PED Working Group taking place in Brussels today
to discuss among other things the planned implementation date of these regulations.
It was scheduled for July 2003 but some member Countries are requesting a deferment untill 2004 at the earliest.
It is certainly not mandatory at present. I feel it may be 2005 before it is law but we will no more in the new year.
J Hopkins - Technical Department ITCO
For the first time we were requested by one of our Customers to clean one tank container
to OK standards and to obtain a Kosher certified cleanliness certificate.
We understand this tank container is aimed at carriage of food grade. Our questions are:
Is there any Company in Santos - Brasil authorized to give such certification and who ?
If not how should we proceed to meet the required Kosher standards ?
ANSWER
contact number for the local Rabbi who provides you with Kosher approval is :
Mr Jacob Blumenfeld, tel 55 21 2256-3587. He is in Rio.
In SP there is Rabi Valt tel 55 11 220-5642 mobile 55 11 9974-4318.
