TT Talk – Tank container risks
The versatility of the tank container for both transport and storage can give it preference over traditional parcel tankers and drums, influencing how supply chains develop, providing additional efficiencies and flexibility.
The intermodal transport of bulk liquid and solid cargoes can present operational challenges for all stakeholders in the supply chain. The UN portable tank (tank container) is a very good means of transporting liquids, gases and powders as bulk cargo.
Constructed to the provisions of the UN Model regulations, the tank container is an intermodal cargo transport unit (CTU), suitable for the carriage of both hazardous and non-hazardous cargoes.
Due to its robust design and durability the tank container has become recognised as a highly safe, cost efficient, flexible and environmentally friendly means of transporting bulk liquids and chemicals globally, allowing seamless transfer between all land and sea modes.
According to the ITCO global fleet survey 2019 there are in excess of 600,000 UN portable tanks in the global fleet, with a continuing positive outlook. TT Club has an insurable interest in around 40% of the global fleet and recently hosted a day seminar for stakeholders in this niche sector of the supply chain, attracting over 80 delegates from all over Europe representing tank container owners, operators and lessors, as well as key service providers, lawyers and insurance brokers.
The aim of the event was to consider the subject of managing safety in the tank container supply chain from a range of stakeholder perspectives.
Reg Lee, President of ITCO provided an overview of the current tank container market and a valuable insight into developments in the years to come.
Peter Skoufalos, Partner at Brown, Gavalas and Fromm delivered a fascinating first hand overview of the ‘MSC Flaminia’ litigation to date, highlighting fundamental issues which tank container operators should consider in their daily operations.
Brookes Bell considered the challenge of corrosion in the tank container industry introducing some of the practical issues associated with the carriage of cargo.
Chris Newton, Partner at Keoghs considered a fictional bodily injury claim based on the risks associated with confined spaces and explored the potential consequences for the tank container operator through HSE and Police investigations. Existing TT Club guidance has focused on confined space risks in tank container operations.
Key contractual exposure: contamination
Whilst the frequency of claims generally is low, analysis of TT Club’s claims experience evidences the common errors and misconceptions which can result in the deterioration or total loss of the cargo and damage to the tank container equipment itself. Most frequent are allegations of cargo contamination. Whilst there are a number of potential causes, an area of focus is the sufficiency of cleaning of the unit following discharge of cargo.
“Most frequent [claims] are allegations of cargo contamination… an area of focus is the sufficiency of cleaning of the unit following discharge of cargo”
In order to avoid such issues, it is imperative to ensure that the last carried cargo is fully removed from the tank container before the next cargo is loaded. Effective cleaning after each carried consignment is therefore of paramount importance.
The transport of certain products may require additional internal cleaning, including removal of valves and changing of contaminated seals and gaskets, to prevent contamination of the next cargo. As part of the pre-trip inspection the cleanliness of the tank container should be checked to ensure that it meets the requirement of the shipper, especially where some prior cargoes are banned or the cargo to be transported has particular sensitivities.
The availability of a suitable cleaning station should be taken into account prior to a cargo being accepted for transport; certain cargoes may not be able to be processed. The risks inherent in transporting the tank container in ‘empty/dirty’ condition to a location where there is a suitable cleaning station also need to be assessed.
“The availability of a suitable cleaning station should be taken into account prior to a cargo being accepted for transport”
Apart from identifying a competent cleaning station, successful cleaning will require complete and informative instructions, such as:
- Full identification of the last carried commodity;
- Complete and accurate cleaning instructions, taking account of future use of the unit;
- Any additional relevant information regarding prior carried cargoes.
The operator additionally needs to heed expert recommendations from the cleaning station.
Certain types of tank container can give rise to additional challenges for the cleaning process. For example, units fitted with surge/baffle plates have a greater surface area to clean due to the additional internal structure and the areas where the baffle plates are fixed present particular challenges.
The tank operator should also perform due diligence in selecting a service provider; in addition to the pure ability physically to clean the unit, there are ethical sourcing and environmental considerations. For example, the cleaning station should be able to demonstrate an effluent process system and licencing concerning disposal of remnant cargo.
Checks should be made to verify:
- Permits, licences and local environmental requirements;
- The range of substances licenced and equipped to clean;
- Quality and safety records.
Source: TT Club