Tank containersManaging 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

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

StopLoss seriesStopLoss 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 atwww.ttclub.com/lossprevention and printed copies are available from the TT Club’s Regional Centres.

DisclaimerThe information contained in this briefing has been compiled from various sources. Neither TT Club nor the contributors accept responsibility for loss or damagewhich 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 otheruse, including derivative guidance based on this briefing, in any form or by any means is subject to prior permission in writing from Through Transport MutualServices (UK) Ltd.

3Tank Containers

Managing risk in the tankcontainer supply chain

1. Introduction

The portable tank is an intermodal cargotransport unit (CTU) used for thetransport of liquids, gases and powdersas bulk cargo. Whilst sections of this textmay be applicable to the operation ofroad tank-vehicles, rail tank-wagons,non-metallic tanks and intermediate bulkcarriers (IBCs) used for transport, thefocus here is the UN portable tank,notably the International Organization forStandardization (ISO) tank container.For ease of reference, the term “tank”will be used to apply to portable tanks,UN portable tanks, intermodal portabletanks and tank containers, unlessspecifically noted.

Through the analysis of TT Club’s claimsexperience there are a number ofcommon errors and misconceptions,which can result in the deterioration ortotal loss of the cargo and damage tothe equipment itself.

This document is intended to be apractitioner’s good practice guidecovering all stakeholders through the

tank transport chain whether operating,filling, discharging or handling tanks.The document is structured in such away that it follows the natural chronologyof the transport chain.

The IMO / ILO / UN ECE Code ofpractice for packing cargo transportunits (CTU Code)1 is mentionedthroughout this document. Chapter 2 ofthe CTU Code defines various functionalstakeholders in the modern supply chainwhilst Chapter 4 provides details of theresponsibilities for each.

In addition to the guidance and informationcontained within this document, allstakeholders need to be aware ofnational, regional and internationalregulations concerning the preparationand transport of certain commodities.

2. Tanks

2.1 Tank overviewIn the freight container industry, the term“tank” usually refers to a 20 ft tankcontainer consisting of a stainless-steelpressure vessel supported and

The intermodal transport of bulk liquid and solid cargoes can presentoperational challenges for all stakeholders in the transport chain.

protected within a steel frame. Tanksare often thought to carry dangerousgoods alone.

However, this perception is far from thewhole truth and as can be seen below,the term “tank” can cover a number ofcontainment designs intended totransport all sorts of bulk liquids,powders, granules and liquefied gases;tank containers are a type of tank.

Various bodies have defined tanks, tankcontainers and portable tanks (seeglossary of terms), and it is worthconsidering how they relate to each other.

Dangerous goods regulations refer toportable tanks but generally refer to UNportable tanks and tank containersmanufactured to ISO 1496-32.

This guide will concentrate on the mostsignificant designs which are generally20 ft intermodal loading units designedto carry pressurised liquids or liquefiedgases. However, the text will includesome information and details relevant toother designs.

1 https://www.unece.org/fileadmin/DAM/trans/doc/2014/wp24/CTU_Code_January_2014.pdf2 https://www.iso.org/obp/ui/#iso:std:iso:1496:-3:ed-5:v1:en

TANK

RailTank-wagons

RoadTank-wagons

PortableTanks

Non-metalicTanks IBCs

UN PortableTanks

IntermodalPortable Tanks

Swap-tanks TankContainers

Tank divisions

4 Tank Containers

2.2 Tank containersThe first design of the tank dates backto 1969 and developments of thatdesign through the 1970s resulted in thegeneral design and structure which wesee in today’s fleets.

Tanks are built to the same exactingstandards as other Series 1 ISO orEuropean Committee forStandardization (CEN) freight containersand, with a few exceptions, can behandled in exactly the same way as allintermodal freight containers. They aresuitable for transport by all surfacemodes. Both dangerous goods andnon-regulated goods (hazardous andnon-hazardous cargoes) can betransported in tanks.

Due to its robust design and durabilitythe tank has become recognised as thesafest, most cost efficient, flexible andenvironmentally friendly means oftransporting bulk liquids and chemicalsglobally. The tank’s multimodality allowsseamless transfer between road, rail andsea. Shippers are increasinglyrecognising the versatility of the tankand favouring its use over traditionalparcel tankers and drums.

A tank is a pressure vessel,manufactured in stainless-steel, carbonsteel or a composite material dependingon its intended use and is positionedwithin a steel frame which meets ISO,CEN and International Convention forSafe Containers (CSC) standards3,which may be:

• surrounded by an insulation layer(usually rock wool or glass wool fibreblock) and a protective outer layerordinarily constructed frompolyurethane and aluminium and/orglass reinforced plastic (GRP), or

• protected by a steel sunshield

A standard 20ft ISO tank is 6.05 metreslong, 2.438 metres wide and 2.6 metreshigh. The volume capacity of a standardtank generally ranges from 14,000 litresto 26,000 litres.

There are currently understood to be inexcess of 650,000 tanks in the globalfleet, and the fleet continues to grow yearon year. Swap tanks are regional (mainlyEuropean) CTUs that are used on shortsea, rail and road transport modes and aretypically 7.15 or 7.85 metres long, 2,5 or2.55 metres wide and 2.67 metres high.

The volume capacity is larger accordingly,and can carry up to 36,000 litres.

Tanks constructed to transport dangerousgoods are usually constructed to meetthe requirements of IMDG but may alsohave approval for a variety of regulationsincluding but not limited to ADR, RID 6.7and CFR494.

2.3 Tank developmentWhilst the tank remains largelyunchanged over the years, there areemerging technologies, which are beingincreasingly used across the industry.Global Positioning System (GPS) trackingsolutions are being implemented toprovide greater transparency tooperators, owners and lessors improvingoperational efficiencies.

Dual temperature control units areavailable to provide electrical heatingand cooling in transit, providing back-upsystems where particularly sensitivecargoes are concerned. Telematicssolutions are available to assist withheating control and to monitor and recordsevere shocks during transit, which mayassist in providing an evidential audit trailthroughout the transit period.

Manufacturers also continue to seek toincorporate solutions and controls forground level operation, thus minimisingthe need for personnel to be present ontop of the tank.

3. Regulation and standards

Several areas of the tank industry arestandardised or regulated. Regulationsinclude:

• The International Convention for SafeContainers, 1972 (CSC) as amended

• An approved pressure vessel code (inmost instances ASME VIII Div.1)

• IMDG Code (or similar modal specificdangerous goods regulations)4.

Tanks used for international transportincluding a maritime leg must complywith the CSC, which requires that beforeapproval for construction is given,prototype testing is carried out to ensurecompliance with the Convention. Swaptanks may not need to comply with thisregulation if it is to be carried on land-based transport modes (road and rail).Tanks should also fully comply with therequirements of the TransportsInternationaux Routiers (TIR) Convention5and specific transport mode requirementssuch as the Union Internationale deschemins (UIC) Code (railway)6.

Tank pressure vessels are required to:

• undergo weld non-destructive tests(usually radiographic) and a hydrostatictest on completion of construction

• undergo testing every 2.5 years and5 years. Failure to pass these testsresults in the portable tank no longerbeing approved for the carriage ofdangerous goods

• adhere to ISO 1496-3 – Series 1freight containers – specification andtesting – Part 3: Tank containers forliquids, gases and pressurised dry bulk

• adhere to EN 1432 Swap bodiesSwap tanks, dimensions, requirements,test methods, operating conditions

4. Equipment selection

In this section, we will explore the variousoptions available and considerations tobe taken when selecting the mostappropriate tank for the shipment ofcargo. The selection of the correctequipment is of importance and will bedetermined by the volume, mass andcharacteristics of the cargo to be shipped,the nature of the journey, and the requiredtransport temperature for the cargo.

3 http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Convention-for-Safe-Containers-(CSC).aspx4 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,&dl5 https://www.unece.org/tir/welcome.html6 https://uic.org/

5Tank Containers

Many of the chemicals shipped globallyare classified as dangerous goods and willfall under the relevant modal regulations.

For example, under the IMDG Code,portable tank instructions specify therequirements applicable for a tank whenused for the carriage of specificsubstances. The Dangerous Goods List(DGL) in Chapter 3.2 of the IMDG Codedefines the tank instruction required foreach substance that may be transported.Portable tank instructions T1to T22 specifythe applicable minimum test pressure, theminimum shell thickness, the pressure-relief and bottom opening requirements.In practice most tanks for generalpurpose use are constructed to T11.

Portable tank instructions T1 to T22 aregenerally used for the carriage ofdangerous cargoes (liquids and solids) ofClass 1 and Class 3 through to Class 9except Class 7, and non-hazardous bulkliquid cargoes. Some bulk solid cargoesare also shipped in tanks.

Tanks under codes T23, T50 and T75are more specialised in nature and arefrequently designed for the carriage of aspecific intended cargo.

T23 portable tank instruction applies toself-reactive substances of Class 4.1and organic peroxides of Class 5.2. Theminimum test pressure is 4 bar, otherspecifications such as the shellthickness, pressure relief requirementsand bottom openings are specific tocertain cargo types.

T50 tank instructions apply to thecarriage of non-refrigerated liquefiedgases and chemicals under pressure.

T75 tank instructions apply to thecarriage of refrigerated liquefied gasesand chemicals under pressure.

For T50 and T75 tank instructions, thespecification of the tank must meet thecriteria for the intended cargo to becarried. The minimum test pressures varyfrom 7 bar to 43 bar; there are also cargospecific stipulations concerning openingsbelow the liquid level, maximum fill ratioand pressure relief requirements.

When a given portable tank instruction isspecified for an intended dangerouscargo, tanks which possess higherminimum test pressures, greater shellthicknesses, more stringent bottomopening, and pressure relief devicearrangements may be used. The tablebelow provides a guide as to which tanks

Portabletankinstruction

T1

T2

T3

T4

T5

T6

T7

T8

T9

T10

T11

T12

T13

T14

T15

T16

T17

T18

T19

T20

T21

T22

Minimumshell thickness(reference steel)

See 6.7.2.4.2

See 6.7.2.4.2

See 6.7.2.4.2

See 6.7.2.4.2

See 6.7.2.4.2

See 6.7.2.4.2

See 6.7.2.4.2

See 6.7.2.4.2

6mm

6mm

See 6.7.2.4.2

See 6.7.2.4.2

6mm

6mm

See 6.7.2.4.2

See 6.7.2.4.2

6mm

6mm

6mm

8mm

10mm

10mm

Minimumtest pressure(bar)

1.5

1.5

2.65

2.65

2.65

4

4

4

4

4

6

6

6

6

10

10

10

10

10

10

10

10

Bottomopeningrequirements

2 closures

3 closures

2 closures

3 closures

Prohibited

2 closures

3 closures

Prohibited

Prohibited

Prohibited

3 closures

3 closures

Prohibited

Prohibited

3 closures

3 closures

3 closures

3 closures

Prohibited

Prohibited

Prohibited

Prohibited

Extract from Table IMDG 4.2.5.2.6 – Portable tank instructions

6 Tank Containers

are appropriate for the carriage ofparticular substances.

It is necessary to refer to the table inIMDG at 4.2.5.2.5 to determineadditional tank instructions. It should notbe assumed that the next higher tankinstruction meets the requirements.

For example, the table shows thealternatives for T10 are T14, T19, T20 orT22 and excludes the use of T11, T12,T13, T15, T16, T17, T18 and T21.

In addition to the items covered underthe tank instructions below, a tank ownermust consider the compatibility of thetank material with the substance (cargo)to be transported, especially theresistance of the tank material tochemical attack. Corrosive substanceswith a chloride content are notcompatible with stainless steel andmight require a special tank lined withchemical resistant material.

5. Maintenance and testing

Why run the risk of equipmentbreakdown?Even the newest, most sophisticatedequipment requires maintenance; tanks

are no exception. Under the CTU Code,the CTU operator (in this instancegenerally the tank owner or a leasingcompany) is responsible for providing aCTU that is fit for purpose.

It is essential to keep the equipment ina sound state of repair to ensure theefficient operation of the tank. Containersused for international transport mustcomply with the CSC with regard tokeeping the container safe. Impropermaintenance can cause inconvenientdowntime, costly consequential repairsand potential loss of cargo. Establishinga preventative maintenance schedulecan prove extremely valuable.

Under the CSC, CTU operators arerequired to develop and operate amaintenance system that describes howthe container will be inspected,examined and maintained. This schemeshould cover the frame of the tank, plusits connection to the pressure vessel andthe prevention of the loss of portabletank service items.

The maintenance of the pressure vesseland service items must comply with theapproved pressure vessel regulationsand the relevant modal specific

regulations. This will include themaintenance and refurbishment ofvalves and the reseating of hatches.

Additionally, tanks are required to besubjected to a periodic inspection andtest every 5 years and an intermediateinspection and test every 2.5 years. As aguide, the requirements of theinspections are set out below.

IMDG 6.7.2.19The intermediate 2.5 year periodicinspection and test shall at least include:

• An internal and external examination ofthe tank and its fittings with due regardto the substances intended to be carried,noting that the internal examinationcan be waivered for product-dedicatedequipment at the discretion of theindependent inspection authority

• A leakproofness test

• A check of the satisfactory operation ofall service equipment

• Sheathing, thermal insulation shall beremoved only to the extent required forreliable appraisal of the condition ofthe tank

Portable tankinstructionspecified

T1

T2

T3

T4

T5

T6

T7

T8

T9

T10

T11

T12

T13

T14

T15

T16

T17

T18

T19

T20

T21

T22

T23

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

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Portable tank instruction also permitted

Determination of the appropriate tank instruction

7Tank Containers

The 5 year periodic inspection and testshall at least include:

• An internal and external examination

• A hydraulic pressure test

• Sheathing and thermal insulation shallbe removed only to the extent requiredfor reliable appraisal of the condition ofthe tank

• When the shell and equipment havebeen pressure-tested separately, aleakproofness test of the assemblyshall be undertaken

IMDG 6.7.2.19.6A tank may not be filled and offered forcarriage after the date of expiry of thelast 5 year or 2.5 year periodicinspection and test. However, a tankfilled prior to the date of expiry of thelast periodic inspection and test may becarried for a period not to exceed threemonths beyond the date of expiry.

IMDG6.7.2.19.7On occasion exceptional inspections willbe required, where for instance a tankshows evidence of damage, corrosion,leakage or other conditions whichindicate a deficiency which could affectthe integrity of the tank. The extent ofthe exceptional inspection and test shalldepend on the amount of damage ordeterioration of the tank. It shall,however, include at least the 2.5 yearinspection and test.

For tanks not covered by the CSC,this requirement would include thetank frame.

6. Corrosion

6.1 GeneralThe pressure vessel of the tank istypically constructed of stainless steel,basic grades of which contain aminimum of 10.5% chromium by mass.It is the chromium which providesstainless steel with its corrosionresistant properties by formation of anadherent oxide layer.

304L and 316L grades of stainlesssteel, which are commonly used in theconstruction of tanks, are classes of“austenitic” stainless steel. Stainlesssteel resists many mineral acids, such asnitric acid and concentrated sulphuricacid. It has an excellent generalcorrosion resistance against a widerange of chemicals that would otherwisecorrode normal carbon steel.

The chromium within the stainless-steelforms an oxide layer of protection,which is only a few atoms thick, it is thisalone which resists corrosion. It shouldbe highlighted, however, that thispassive layer can be susceptible todamage and attack.

There are six primary types of corrosion:

• Pitting corrosion – Local disruption ofthe passive layer

• Crevice corrosion – A localised attackon a metal surface at, or immediatelyadjacent to, the gap or crevice betweentwo joining surfaces

• General corrosion/attack – Aggressivechemical corrosion

• Stress corrosion cracking – Tensilestress, temperature and corrosivespecies

• Inter-granular corrosion – Sensitisation

• Galvanic corrosion – Dissimilarmetal corrosion

Corrosion should be a primary concernfor tank owners and operators. Whilsttanks are generally constructed fromstainless steel and are thus resistant tostaining and corrosion, the carriage ofcertain cargoes or certain cleaning andmaintenance operations can lead tocorrosion and pitting. What might initiallyappear to be minor surface pitting; mightbe developing under the surface intoareas of catastrophic corrosion.

6.2 Corrosive substancesClass 8 cargoes (corrosive substances)with chloride content are thepredominant challenge where corrosionof tanks is concerned. All substances inthis class are more or less destructive onmetals and textiles.

Chloride content might apply to manysubstances, including non-regulatedsubstances. For example, sea water canbe corrosive to stainless steel.Substances that are compatible at lowtemperatures might be corrosive at hightemperatures.

There are various corrosion compatibilitycharts and data available to enableassessment of the substance prior tofilling the tank. Care should betaken to ensure that the current conditionof the steel is well understood, as suchcharts will benchmark on the basis thatthe steel is in new and perfect condition.

When the classification is carried out forthe transport of dangerous goods,corrosive substances are tested againsta criterion of causing severe damagewhen in contact with living tissue and inthe event of leakage are capable ofdamaging or destroying other goods, ormeans of transport. Substances underClass 8 also include those which form acorrosive liquid only in the presence ofwater, or which produce corrosive vapouror mist in the presence of naturalmoisture of the air. For the purposes ofclassification under the IMDG code,substances identified in Packing GroupsI and II are not tested against theircorrosivity towards the stainless steelshell of the tank.

Corrosive substances assigned toPacking Group III demonstrate corrosionthat does not damage living tissue to fullskin thickness but does exhibit acorrosion rate on either steel oraluminium surfaces exceeding 6.25 mmper year at a test temperature of 55°Cwhen tested on both materials.

6.3 How vulnerable is the passivelayer to damage/corrosion?Stainless steel is only “stainless” when thesurface oxidises with chromium and otherelements to develop a protective film thatresists further oxidation. This protectedoxide film is considered a passive surface.To passivate stainless steel, a minimumof 10.5-12% chromium is needed.

Once the passive layer is breached, thelocal area becomes active. This results inthe formation of a corrosion cell whichthen drives the corrosion further owingto the surrounding material remainingpassive (in this way, pit). Damage cangenerally be caused by the following:

• Exposure to aggressive halide ions(chloride and fluoride)

• Contamination (free iron ions)

• Physical damage

• Low oxygen environments

• Under-deposit corrosion

It should be noted that in an oxygen richenvironment, in the absence of pitting,the passive layer can self-repair.

Pitting resistance equivalent numbers(PREN) are a theoretical way ofcomparing the pitting corrosion resistanceof various types of stainless steels,based on their chemical compositions.

8 Tank Containers

The PREN (or PRE) numbers are usefulfor ranking and comparing the differentgrades, but cannot be used to predictwhether a particular grade will besuitable for a given application, wherepitting corrosion may be a hazard.

304L grade stainless steel has PRENof 18.

316L grade stainless steel has PRENof around 25.

To resist sea water continuously, aPREN of around 40 is required.

Pitting is most commonly effected bycontamination and the presence ofhalides (such as chlorides). The greaterthe PREN, the more resistant tohalides the stainless steel will be.However, after long periods of exposureto cleaning regimes, aggressivechemicals, sediments and the generalrigours of transport, the stainless steelof tanks will become depleted of thebeneficial chromium at the surfaceresulting in decreased passivity. Thepassivity is easily monitored and can berestored by passivating or, pickling andpassivating, in solutions containing nitricacid. If the surface has become pittedover time, then this often needs to bemechanically removed by grinding as thegeometry of pits can limit oxygen at thesurface, making passivation difficult.

7. Pre-trip inspections and cleaning

7.1 Pre-trip inspectionThe objective of the pre-trip inspection(PTI) carried out on every tank prior tofilling with cargo is to ensure:

• that the equipment is in a safecondition, in proper working order

• that it is fit for purpose

• that the tank frame is visually in a safecondition and that the frame is withinthe ISO or CEN specification envelope;and that the correct components havebeen installed and are sufficient towithstand the rigours associated withthe carriage of the given cargo

7.2 CleaningAfter the carriage of dangerous goods,the applicable regulations continue toapply until the tank is cleaned.

There may be the need to transport thetank in empty dirty condition to a locationwhere a suitable cleaning station exists.

Example of a corrosion pit. Visual inspection of the pit provides no informationabout the damage to the subsurface

Pitting corrosion. Complex interaction of ionic species during pit formation.Note the concentration of chloride ions within the pit

PTI: Is the equipment ina safe condition, properworking order and fitfor purpose?

9Tank Containers

It is generally good practice to ensure thatthe tank is cleaned as soon as practicablypossible following the carriage of cargo.Operators should be mindful that acargo can change its composition if andwhen air or humidity are introducedespecially following discharge.

Operators should be mindful that waterused in the cleaning process in someparts of the world will contain differinglevels of chlorine and or impurities whichcan “damage” the tank during thecleaning process itself.

The European Federation of TankCleaning Organisations (EFTCO) defines‘clean’ in the following way:

“A tank shall be described as clean whenthere are no visible traces or odour of thelast product or cleaning agent followingan inspection from the man-lids.”

It is important that the CTU operatorperforms due diligence when selectinga service provider where cleaning isconcerned. As well as the cleaningstation’s ability to physically clean thetank, there are ethical sourcing andenvironmental considerations. Eachstakeholder has a corporate socialresponsibility to ensure where possiblethat the environment is sufficientlyprotected.

For example, does the cleaning stationhave a sufficient effluent process systemand a licence, as well as a means ofdisposing of the remnant cargo?

The availability of a suitable cleaningstation should be taken into accountprior to a cargo being accepted fortransport. It should be appreciated thatnot all cargoes will be able to beprocessed by an individual cleaningstation. Checks should be made to verifythe cleaning station’s:

• Permits, licences and environmentalrequirements

• Range of substances licenced andequipped to clean

• Quality and safety records

• Commercial arrangements

The operator should report the followinginformation to the cleaning stationregarding the last carried cargo:

• UN number

• Proper shipping name

• Technical name – both to meet theregulatory requirements for certaindangerous goods, or for non-dangerous goods if it is not clear fromthe substance name.

• The presence of inert gas or if the tankis under pressure.

• The presence of substance residue ifover 5 litres.

Virtually any conceivable cargo type canbe cleaned providing the necessaryfacilities are available. The key criteriafor success in this context are:

• The correct identification andcommunication of the last carried cargo

• The correct instructions identified andpassed to the cleaning station.

• Any additional relevant informationpassed to the cleaning stationregarding prior carried cargoes.

• Heeding expert recommendation fromthe cleaning station.

The processing of excess cargo and tankwashings is dependent on the capabilityof the cleaning facility and nationalenvironmental waste disposal licences.

Some levels of cleaning may also requirepersonnel to enter the tank and manuallyinspect. This requires special safetyprocedures including the issue of a tankentry certificate (see also paragraph11.4 of this document).

Certain types of tank can give rise toadditional challenges through thecleaning process. Inevitably tanks fittedwith surge/baffle plates have a greaterinternal surface area to clean due to theadditional internal structure. Moreover,the areas where the baffle plates arefixed in place provide excellent locationsfor stubborn cargo remnants to reside.

Examples of common wash instructions:

• Cold water wash

• Detergent wash

• Chemical rinse

• Caustic wash

• Steam purge

• Solvent pre-solve diesel spin

• Pickling

The cleaning station should maintain adatabase of known cargoes and thereforebe in a position to recommend therequired cleaning method in order to cleanthe tank. Some of the more challengingcargoes to clean are not necessarily themost dangerous. Seemingly innocuouscargoes, such as milk, are inherentlychallenging as are more obvious cargoessuch as inks and dyes.

Many shippers have developed extensivelists of banned prior cargoes; thosewhich are known even in very smallquantities to compromise the quality oftheir cargo. The motivation is to mitigatethe risk of contamination as a result ofcarriage in the tank. Such practices canprovide additional procedural challengesfor the tank operator who must alsoconsider banned prior cargoes as a partof the PTI and prior to allocating a tankto be loaded.

Inevitably, a more intensive clean processwill attract an additional premium interms of both financial cost and the timerequired. Following the cleaning processwhere appropriate the tank must bedried internally to ensure no waterremains in the tank prior to the loadingprocess recognising that some cargoesare more sensitive than others. In somecases cargoes can be rendered out ofspecification due to high moisture contentmeasured in parts per million (PPM); themargins for error are very small.

Once the tank has been cleaned thecleaning station should issue a cleaningcertificate (a cleanliness certificate canalso be requested but this would bemade out by an independent inspectioncompany to confirm the level ofcleanliness of the tank – this wouldnormally involve the inspector enteringthe tank to confirm the condition ofthe barrel).

The cleaning certificate will vary in formglobally, noting that there are regionalrecognised standards such as theEuropean Cleaning Document (ECD)7which is often issued by EuropeanFederation of Tank Cleaning

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

10 Tank Containers

Organisation (EFTCO) approvedcleaning stations. Other documents areused globally such as the ITCO ACCCleanliness Certificate8.

Such standards set the benchmark forthe services to be provided but alsoseek to address and clarify the liabilityof the cleaning station in the event of aloss post clean. The primaryrequirement is for the tank to be clean,dry and odour free.

Once the cleaning process is completethe placards and markings on the tankshould be removed. After it has cooledso as to prevent a vacuum forming,valves and fittings may be secured andthe tank made ready for the nextassignment.

The cleaning certificate does notguarantee that the tank is safe to enter.Problems can occur for example withrubber lined tanks which can holdproduct even after the tank has beenthoroughly cleaned thus creating ahostile environment which may notsupport life. In particular, be alert toenclosed space risks9.

Once the certificate has been signedand the tank has left the premises of thecleaning station, it is difficult to establishany liability on the part of the cleaningstation in the event of a post clean loss.

8. Loading cargo into a tank

8.1 GeneralThe process of loading cargoes into atank will be influenced by theclassification and the characteristics ofthe cargo being shipped. The shipper/consignor is responsible for theclassification of the cargo under theapplicable regulations.

The classification of the cargo willprescribe under the applicableregulations as to how it should be stored,handled, loaded and treated duringtransit. It is important to maintaincompliance with such requirementsrelating to loading cargo into a tank.

Of course, not all cargoes shipped intanks are dangerous, for example manyfood grade cargoes are shippedglobally. In terms of equipment selection,these cargoes require dedicated foodgrade tanks.

8.2 Pre-checksGiven the complexities of the modernday supply chain the shipper or thefreight forwarder could be performingthe functions of the packer. Under theCTU Code, the packer is responsible forensuring that:

• the tank has been checked and verifiedas fit and clean for use before loadingcommences

• the tank is safe to use

• a banned prior cargo has not beenshipped in the tank that may beincompatible with the plannedconsignment

• the cargo has been correctlyprepared in terms of temperature andtreatments where applicable; and

8.3 Packing/fillingUnder the CTU Code the Consignor isresponsible for providing all informationrequired for the proper filling of thesubject cargo. The packer (loader) isresponsible for ensuring that thetransport and packing instructions areadhered to and that the cargo issufficiently “secured”, such as all valvesfully closed.

General good practice regarding loading:

• Ensure that the cargo is loadedaccording to any consignor’s guidelineswhich may be available for thatparticular substance

• Ensure that the tank is not over orunder filled by volume according tothe degree of filling assigned by theIMDG dangerous goods list tankprovision (TP)

• Tanks shall not be offered for transportwith a degree of filling for liquidshaving a viscosity less than 2,680mm²/s at 20°C, or at the maximumtemperature of the substance duringtransport in the case of a heatedsubstance, of more than 20% but lessthan 80% unless the shell is divided, bypartitions or surge plates, into sectionsof not more than 7,500 L capacity

• Ensure that the gross mass of theloaded tank does not exceed themaximum permissible operating grossmass of the container or any road or

rail limitations in any country passedthrough during the planned transport

• Close the man lids and valves, andsecure the fastenings

• Close any compartments fitted andsecurely fasten to prevent any risk ofopening during transport. Be awarethat a compartment breaking open intransit can be extremely dangerousand cause high consequence damage

• Where IMDG regulated cargoes areconcerned, affix the applicableplacards and markings

• Where appropriate affix Customs andsecurity seals to valves and entrypoints to ensure that they cannot beopened during transport

Loading facilities will vary in their levelsof sophistication in terms of theequipment used to fill tanks.

The filling process should be appropriateto the consignment and tank packinginstruction. When filling, it is importantthat the filled tank does not present arisk to those involved with handling andtransporting it, or to members of thegeneral public. Therefore, it is essentialthat liquids are not allowed to surgeuncontrollably resulting in the tankbecoming unstable (see also section 8.4).In dangerous goods regulations such asthe IMDG Code at chapter 4.2.1.9.6;calculations are given for the degree offilling, however, these calculations arejust as valid for non-regulated liquids.Therefore, no tank should be overfilled(which may over pressurise the barrel orcause spillages), or under filled (whichmay increase the instability of the tankunless fitted with baffles or sub-dividedinto compartments).

On completion of loading the IMDGDangerous Goods Declaration should becompleted including, where applicable, a“Shipper’s Declaration” and a“Container/Vehicle Packing Certificate”.

Example of a shipper’s declaration:

I hereby declare that the contents of thisconsignment are fully and accuratelydescribed below by the proper shippingname, and are classified, marked andlabelled/ placarded and are in allrespects in proper condition for transport

8 https://www.international-tank-container.org/storage/uploads/ACC09-2017-A4.pdf9 https://www.ttclub.com/loss-prevention/publications/stop-loss/stop-loss-19-confined-spaces-managing-the-risk-of-entering-cargo-transport-tanks-145295/

11Tank Containers

according to the applicable national andinternational governmental regulations.

Example of a container/vehiclepacking certificate declaration:

I hereby declare that the goods describedabove have been packed/ loaded into thecontainer/ vehicle identified above inaccordance with the applicable provisions.

This must be completed and signed forall container/ vehicle loads by theperson responsible for packing.

All tanks being transported internationallyby sea are subject to SOLAS thatrequires that a Verified Gross Mass(VGM) is provided by the shipper to theship’s master and the terminal before itcan be loaded. SOLAS10 also prohibitsthe loading of any container where theVGM or actual gross mass is greaterthan the maximum operational grossmass of the container11.

8.4 Free surface movement(liquid surge)The free surface effect is a mechanismwhich can cause a tank to becomeunstable and refers to the tendency ofliquids to move in response to the forces

to which the tank is exposed to. Duringextreme manoeuvres (sudden turning,starting or stopping) the tank andcarrying vehicle can become so unstablethat they can severely affect the drivingcharacteristics of the transport vehiclewhich may result in the vehicle turningover. A sub-design of tank are baffletanks, which are designed to reduceproduct surge, thus reducing the risk ofturn overs, and used for smaller/largertransport loads. Baffle or surge platesare installed within the barrel tocompartmentalise the load space to amaximum of 7,500 litres each. A standard26,000 litre tank would, therefore, requirethree sets of baffle/surge plates.

To mitigate the effects of free surfacemovement, the IMDG Code stipulatesminimum and maximum permissible filllevels for tanks. Where lower volumes ofcargo are to be shipped, eitherspecialised low capacity tanks or tanksfitted with surge plates are required.

Generally, tank containers should have aminimum fill capacity of 80% by volume.Where the tank is being shipped inempty dirty condition the tank shouldnot be transported with more than 20%by volume.

8.5 Safety Data Sheet (SDS)A safety data sheet is a documentthat lists information relating tooccupational safety and health for theuse of various substances and products.This forms a non-mandatory widelyused system for cataloguing informationon chemicals, chemical compounds,and chemical mixtures.

An SDS is a document created forsubstances or mixtures containing awide range of information on thecomposition, physical, chemical, healthand environmental effects of thesubstance or mixture and on the safeusage, storage and disposal of theproducts along with spill-handlingprocedures.

An SDS for a substance is not primarilyintended for use by the generalconsumer, focusing instead on thehazards of working with the material inan occupational setting. There is also aduty to properly label substances on thebasis of physico-chemical, health, orenvironmental risk.

Some countries impose an explicit dutyof care that each SDS be regularlyupdated, usually every three to five

10 International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended11 https://www.ttclub.com/loss-prevention/container-weighing/

12 Tank Containers

years. However, when new informationbecomes available, an SDS must berevised without delay.

Substances which are not classified asdangerous goods are referred to as non-regulated (or commonly non-dangerousor non-hazardous goods). Non-regulateddoes not mean that the substance isfree of danger or hazard.

The format of the SDS is specified bythe Globally Harmonized System ofClassification and Labelling ofChemicals (GHS)12.

The GHS stipulates that the SDS shouldfollow a standard 16 section format anddetail all of the characteristics of thecargo under various different sections. Allof the sections are of importance but thefour sections of particular importance inthe context of this document are:

Section 2 – Hazard identificationThis section includes the label elementsthat should accompany the cargo.

Section 6 – Accidental release measuresOf particular importance to thosetransporting or handling the tank wherethere is an incident that results in arelease of the cargo.

Section 7 – Handling and storagePrecautions for safe handling and theconditions for safe storage includeincompatible substances andsegregation.

Section 14 – Transport informationUN number and proper shipping name,plus transport classes and packing groups.

Tank operators require that consignorsprovide up to date SDSs for theconsignments, and in turn undertake due

diligence checks on cargoes to ensure,as far as is practicable, that theinformation they are receiving is accurateand appropriate. A dangerous goodsadvisor may be able to ascertain whetherthe information provided within the SDSis reasonable and correctly classified. Aknowledge of the cargo may also beuseful so that prior incidents involvingthe same cargo can be referenced forany recommendations made as a resultof the incidents regarding the storage,handling and transport.

Where the applicable sections of theSDS are incomplete, the information isinconsistent or the tank operator hasdoubts, then concerns should be raisedwith the shipper and/ or consignor priorto the cargo being packed.

8.6 Temperature sensitive cargoesSome cargoes are temperature sensitiveand require either temperature-controlled tanks or chemical stabilisationwhen being shipped. Shippers mustundertake due diligence to establishsuch requirements and ensure thatsuitable tanks are requested, andprovided, for theconsignment to ensure safe transport.Where such cargoes are concernedthere is a requirement that the shipperforwards accurate information and anyregulatory requirements onto allstakeholders in the transport chain.

8.7 Hot loadingCertain cargoes become solid at ambienttemperatures and therefore are requiredto be packed into the tank at an elevatedtemperature. Once packed, the cargo willcool and likely solidify during transport.Care must be taken by tank operators toensure that the loading temperature isknown along with the rate at which thecargo cools and solidifies. If the cargo

must be shipped immediately followingthe completion of packing, and the cargois known not to cool quickly, there maybe requirements for additional notationsand markings on the tank to remaincompliant with the applicable regulationsand to ensure other stakeholders areaware of the potential dangers.

Tanks being packed/filled with a hotcargo that is to be released from thepacking facility for transport in a liquidstate at a temperature at or above100°C or in a solid state at or above240°C shall be marked on both sidesand each end with a special elevatedtemperature marking as below.

Elevated temperature carriage mark

9. In transit instructions

9.1 SecurityThe IMDG Code requires a security plandesigned to prevent misuse of highconsequence dangerous goods in aterrorist event.

National authorities might also applyadditional security provisions.

High consequence dangerous goods aredefined by the Code as those whichhave a potential for misuse in a terroristincident and which may, as a result,produce serious consequences such asmass casualties or mass destruction.

The table in the IMDG Code at 1.4.3.1provides an indicative list of these (notClass 7).

Notwithstanding the Code’s provisionsfor high consequence dangerous goods,operators are recommended to considerdeveloping a security plan to ensure thesafekeeping of all tanks and substancestransported. Not least to ensure secureprocesses, depots, transport contractorsand shipping routes are considered.

Mitigating the risks of liquid surge with a baffled tank

Minimum dimension 250mm

Minim

umdim

ension250m

m

Min

imum

dim

ensi

on25

0mm

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

13Tank Containers

9.2 Chain of communicationEach stakeholder in the transport chainhas a responsibility to pass sufficientand relevant information regarding thecargo and transport requirement tostakeholders so that safety in thetransport chain and the integrity of thecargo is maintained. Careful scrutiny ofthe instructions at each stage isfundamental to the successful shipmentof cargoes in tanks.

The shipper is responsible for ensuringthat the cargo is correctly described andclassified and to notify the packer (whomay be a freight forwarder) of anyspecific instructions in relation to thepending shipment.

The bulk liquid transport chain can becomplex especially where internationalshipments are concerned.

9.3 In the event of a lossWhen incidents arise, it is often due tosimple instructions not being passedbetween the various stakeholders,highlighting the need for accuracy indata, instructions and documentation.

Where dangerous goods are concernedit is imperative to ensure that the cargois correctly identified, classified anddeclared and the relevant supporting

documents are obtained. The SDS willtake prominence through the bookingacceptance and the Dangerous GoodsDeclaration (DGD) will be pivotal instowage planning.

It should be highlighted that ensuringthe correct classification and SDS areobtained is not always sufficient. Of themany documents which may accompanya dangerous goods shipment, the DGDis the critical document in terms ofinformation being communicated to theshipping line. This document is preparedby the consignor or shipper thus certifyingthat the dangerous goods being shippedhave been packaged, labelled anddeclared in accordance with the applicableregulations. It is this document rather thanthe SDS upon which the shipping line willrely in determining the ship stowage plan.

Each stakeholder in the transport chainhas a duty of care and obligation to warnother stakeholders of any known dangersconcerning the cargo being shipped,especially where these characteristicsmay not be immediately apparent.

Ambiguity or poorly worded notationscan also be an attributing factor. Whereinstructions appear to be less thancertain, the relevant stakeholder shouldseek clarification prior to proceeding.

10. Final mile delivery

10.1 Collecting the tank for deliveryOperators should undertake duediligence13 when appointing a haulier orthird-party service provide.

At the time the tank is collected from thedestination port or depot for delivery tothe consignee, the following checksshould be carried out by the trained andqualified collecting driver, regardless ofwhether the inland haulage is arrangedby the carrier or the consignee:

• Visual check that the tank appearsstructurally sound

• The areas and structures around thedischarge valve are free of apparentimpact damage.

• There are no apparent leaks

• The security seal remains intact anddisplays the correct seal number

• The temperature gauge on the tankreflects the details in the transportdocumentation (where applicable)

• All handles on the discharge valveremain in the fully closed position

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

14 Tank Containers

• The correct chassis/ low loader is usedand all twist locks are engaged.

• The required cargo placards aredisplayed and securely fitted

In some countries, additionalconsideration may have to be given tothe available equipment, the expertise ofthe local haulage contractors, poor roadquality and general infrastructure.

Upon arrival at the delivery point, theconsignee should always carry out thesame initial checks of the tank structure,seal and settings as listed above.

10.2 Re-heating (if required)If the cargo must be heated prior todischarge, ensure that an appropriateservice provider is appointed toundertake the work and that accurate,unambiguous instructions in writing arealways provided to them.

Where cargoes must be heated tofacilitate discharge there are variousoptions open to the operator. Each tankis constructed with a series of coilsaround the shell of the pressure vessel.The number of coils varies from tank totank dependant on the initialspecification. Generally, the more coils,the more quickly the cargo can beheated, although the steam allowablepressure rating of the tank is also adetermining factor.

The type of heating applied will dependon the sensitivity of the cargo to beheated and the urgency to achieve aliquefied state. The coils are designedto be plugged into different heatsources. Applying hot water into thecoils provides a sensitive increase intemperature. Applying pressurisedsteam through the coils provides thefastest heating option; more sensitivecargoes however may be damaged asa result of the associated sharp risein temperature.

Careful management of the heatingprocess is critical in ensuring that thecargo integrity is maintained as well asavoiding potentially catastrophicexplosion incidents. Where steam isused to heat the cargo over pressurisingis a risk which can result in temperatureswhich exceed the design of the steamcoils (usually 130 degrees Celsius).

It is necessary to ensure that thetemperature gauge remains undamagedand in sound working order as this isoften used as a guide as to thetemperature of the cargo within.

10.3 DischargingA tank is normally discharged from thebottom valve opening, although topdischarge is possible too. During thedischarge there is a risk of creating avacuum which can result in catastrophicdamage to the tank.

The consignee must monitor thedischarge to ensure that the negativepressure inside the tank barrel remainsat tolerable levels.

The consignee should have a means inplace to determine and verify the volumeof cargo discharged.

It is good practice to ensure thatpre-discharge samples are secured andanalysed. The consignee should havean established method of analysingpre-discharge samples to ensure thatthe cargo conforms to the expectedspecification.

In the event that any quality irregularitiesare noted immediately upon takingpre-discharge samples, the consigneeshould not commence discharge, notifythe carrier and arrange for a surveyorto attend.

In cases where quality irregularities areonly noted during or after the tank hasbeen fully discharged, the consigneeshould undertake a risk assessment andendeavour to notify the shipper as soonas possible, and an independent surveyorshould be appointed to investigate.

Upon completion of the discharge therewill often be some residue of the cargoremaining within the tank. The tankshould be as empty as practicablypossible. Cargo residue is expensive to

15Tank Containers

remove at the cleaning facility anddangerous goods will attract additionalsafety procedures.

At this point the tank is considered to bein an empty dirty state. Placards andIMDG dangerous goods regulationscontinue to apply until the tank iscleaned (see paragraph 7.2 Cleaning).

11. Actions in the event of an incident

Whilst the tank is recognised as the safestmeans of transporting bulk liquids, thereare occasions where incidents occurwhich may give rise to insurance claims.Whilst such incidents are relatively few innumber, given the nature of some of thecargoes being transported, there is therisk of potentially large exposureincidents. In this section we look tohighlight the safety features of the tankand provide good practice guidance inthe event of an incident.

11.1 Typical safety featuresThe thermal insulation layer of the tankshell provides, in addition to its thermalqualities, a degree of protection in theevent of an impact.

Flame guards and bursting/frangiblediscs are fitted to vacuum relief devicesand spring-loaded valves to mitigate therisks where tanks are exposed toexternal fire incidents.

The bottom discharge valves comprise ofthree closures in series; the internalspring-loaded foot valve, the outlet valveand a screwed sealing cap or flange.

In the event of a catastrophic damage tothe external portions of the bottomdischarge valve, the outlet valve supportpipe is designed with a shear grooveallowing the external part of the valve toshear from the tank leaving the tankbarrel and the internal valve intact andcontaining the cargo.

A safety valve is provided in the top ofthe tank to relieve excess pressure thatmight build as a result of a cargochemical reaction or overheating.

The many safety features of the tank aresuch that even in the event ofreasonably serious damage incidents,the cargo is contained within the barreland therefore the integrity of the cargois maintained. If the damage sustainedresults in the frame of the tank no longer

conforming with CSC safety criteria, itmay not be possible for it to continue itsintended transport. There may be theneed to tranship the cargo into areplacement tank, ensuring compliancewith all loading and regulatoryrequirements.

11.2 Leaking cargoWhere tanks are severely damaged, cargomay leak from the barrel. In suchcircumstances, where practicable, theleak should be stemmed, or if not possible,the tank placed in a leak tray, bunded area(walled concrete surfaced area) orsurrounded with containment boom/bundto ensure that the cargo is contained –preventing a wider pollution risk.

The type of cargo being carried willinfluence how those responding to theincident will be able to proceed and thelevel of personal protective equipment(PPE) they may require. The type of cargowill also influence how the surroundingareas should be managed; areas mayneed to be evacuated if it is assessedthat they might be exposed to danger.

11.3 ContaminationThe most common type of loss relates tocargo contamination, including wherethe cargo does not meet the specificationexpected by the consignee. Theseincidents arise for a number of reasons,often not directly attributable to the tankitself. Occasionally the stubborn remnantsof a prior cargo will be freed by anaggressive Class 8 cargo and show in thepre-discharge samples at the consignee.Pre-discharge samples indicatingproblems may include discolouration orthe presence of suspended particles.

These particles may be attributable to aprior cargo or an incompatible component.

Where contamination cases areconcerned, early and transparentinteraction with the cargo owner willencourage a positive handling of theincident which can result in earlyresolution. The solution to many cargocontamination incidents is reasonablycost-effective filtering or reworking.However it is imperative that the cargointerests are involved in the early stagesof the investigation in order toencourage them to take such action.

11.4 InjuriesInjuries for those working with tanks arefew in number; however, when they occur,

they can have serious consequencesand come in two major categories:

• The risks associated with confinedspaces for those working inside thetank barrel can be high if the correctequipment is not available or used andconfined entry permit procedures arenot strictly followed. For more in depthadvice concerning confined space risk,please see TT Club’s StopLoss 19:Confined spaces: Managing the risk ofentering cargo transport tanks.

• Another potential bodily injury riskexposure is working at height. There isthe need to work on top of the tank fora variety of reasons. Where work iscarried out at height, robust proceduresshould be in place, and followed, toensure that personnel are sufficientlyprotected and not able to fall. Allstakeholders must comply with theapplicable regulations where workingat height is concerned, recognisingthat there will likely be national andregional variations.

Example working at height regulations:

European Directive 2001/45/EC“Working at Height”14

UK: The Work at Height Regulations 2005

11.5 Crisis managementWhen considering risk assessment andmanagement it is generally goodpractice for all stakeholders in the tanksupply chain to have a robust crisismanagement plan in place which istested periodically. This plan should alsoconsider an emergency response plan inthe event of a catastrophic incident.

11.6 Post incidentStakeholders need to scrutinise thephysical and contractual chain to identify(if possible) where the error hasoccurred with a view to holding theresponsible party liable at an early stage.

At the earliest practicable opportunityfollowing the discovery of an issue (onceany immediate risk is contained andunder control) the priority should be tonotify your liability insurer, and considerthe early appointment of an independentsurveyor/expert. Depending on the typeand seriousness of the incident earlyaction investigating and gatheringrelative information will assist inmitigating the potential loss and liability.

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

16 Tank Containers

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 intendedshipment. If the answers to the thirteen questions are in the positive, then whilst itdoesn’t cover every eventuality, the risk of loss through the supply chain will begreatly reduced.

Thirteen point checklist

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 consideredand communicated?

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

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

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’srequirements?

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

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

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

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

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

13. Are the correct placards and markings in place?

Cargo transport unit (CTU)Means a road freight vehicle, a railwayfreight wagon, a freight container, a roadtank vehicle, a railway tank or a portabletank. Used as an alternative toIntermodal Loading Unit (ILU)

CarrierThe party who, in a contract of carriage,undertakes to perform or to procure theperformance of carriage by rail, road,sea, inland waterway or by a combinationof such modes.

CleanA tank shall be described as clean whenthere are no visible traces or odour of thelast product or cleaning agent followingan inspection from the man-lids.

Cleaning certificateDocument issued by the cleaning facilityto confirm that the tank is clean.

ConsigneeThe party to whom a cargo is consignedunder contract of carriage or transportdocument or electronic record. Alsoknown as the receiver.

ConsignorThe party who prepares a consignmentfor transport. If the consignor contractsthe transport operation with the carrier,the consignor will undertake the functionof the shipper.

CTU CodeIMO / ILO / UN ECE Code of practicefor packing cargo transport unitsintended to assist the industry,employers’ andworkers’ organisations as well asGovernments in ensuring the safestowage of cargo in containers.

CTU OperatorThe party who operates the CTU andprovides empty CTUs to the consignor/shipper/packer may be referred to astank operator.

DGNThe Dangerous Goods Note (orDangerous Goods Declaration) is usedto accompany deliveries of hazardousgoods in transit.

IMDG CodeMeans the current edition of theInternational Maritime Dangerous Goods(IMDG) Code adopted by the MaritimeSafety Committee of InternationalMaritime Organisation (IMO).

Intermodal portable tankMeans a specific class of portable tanksdesigned primarily for internationalintermodal use.

LessorA person or company who leasesequipment to another company.

NVOCCNon-vessel operating common carrier.A shipment consolidator or freightforwarder who does not own any vessel,but functions as a carrier by issuing itsown bills of lading or waybills andassumes responsibility for the shipments.

PackerThe party that loads, places or fills thecargo within or on the CTU; the packermay be contracted either by theconsignor, the shipper, by the freightforwarder or by the carrier; if theconsignor or the shipper packs a CTUwithin his own premises, the consignoror the shipper is also the packer.

Portable tankMeans:

• For the purposes of the transport ofsubstances of Class 1 and Classes 3to 9, a multimodal portable tank. Itincludes a shell fitted with serviceequipment and structural equipmentnecessary for the transport ofdangerous goods.

• For the purposes of transport of non-refrigerated, liquefied gases of Class 2,a multimodal tank having a capacity ofmore than 450 litres. It includes a shellfitted with service equipment andstructural equipment necessary for thetransport of gases.

• For the purposes of transport ofrefrigerated liquefied gases, a thermallyinsulated tank having a capacity ofmore than 450 litres fitted with serviceequipment and structural equipmentnecessary for the transport ofrefrigerated liquefied gases.

The portable tank shall be capable ofbeing loaded and discharged without theneed of removal of its structuralequipment. It shall possess stabilisingmembers external to the shell and shallbe capable of being lifted when full. Itshall be designed primarily to be loadedon a vehicle or vessel and is equippedwith skids, mountings or accessories tofacilitate mechanical handling. Roadtank-vehicles, rail tank-wagons, non-metallic tanks, gas cylinders, largereceptacles and intermediate bulkcontainers (IBCs) are not considered tofall within this definition.

PTIPre-trip inspection. A series of checkscarried out before the CTU in question isassigned to carry out its assigned tasks.

SDSSafety data sheet is a document createdfor substances or mixtures containing awide range of information on thecomposition, physical, chemical, healthand environmental effects of thesubstance or mixture and on the safeusage, transport, storage and disposal ofthe products.

ShipperThe party named on the bill of lading orwaybill as shipper and/or who concludesa contract of carriage (or in whose nameor on whose behalf a contract ofcarriage has been concluded) with thecarrier. In tank operations, under theocean bill of lading, the “shipper” may bethe CTU operator acting as NVOCC.

TankMeans a portable tank, including a tankcontainer, a road tank-vehicle, a rail tank-wagon or a receptacle to contain solids,liquids, or gases, having a capacity of notless than 450 litres when for thetransport of gases.

Tank ContainerMeans a portable tank with fittings,structural capabilities and dimensionsthat enable it to be handled and securedby the same means as any ISOconfigured container and complies withthe requirements of ISO 1496-3.

Glossary of terms

18 Tank Containers

TT ClubTT Club is the established market-leadingindependent provider of mutual insurance and relatedrisk management services to the internationaltransport and logistics industry. TT Club’s primaryobjective is to help make the industry safer and moresecure. Founded in 1968, the Club has more than1100 Members, spanning container owners andoperators, ports and terminals, and logisticscompanies, working across maritime, road, rail, andair. TT Club is renowned for its high-quality service, in-depth industry knowledge and enduring Memberloyalty. It retains more than 93% of its Members with athird of its entire membership having chosen to insurewith the Club for 20 years or more.

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Thomas MillerTT Club is managed by Thomas Miller, an independentand international provider of market leading insuranceservices. Most of the businesses we currently own ormanage are acknowledged leaders in their chosenmarket. Our portfolio includes mutual organisationsand, increasingly, specialist insurance servicesbusinesses.

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STOPLOSS 22 – AH/MY/CD06/20