Tank Container Managers Discuss Expected Worldwide Regulations
Dec 1, 1998 12:00 PM
As the use of tank containers grows worldwide, the expansion of international regulations is expected to increase accordingly, said spokesmen at the annual Tank Container Association (TCA) meeting September 30 in Houston, Texas.
While the industry is generating its own guidelines, new international rules are being considered by the United Nations (UN), said Aris Antoniou, chairman of the TCA Regulatory Committee. He predicted tank containers will be more rigorously regulated by the UN within two years. The International Maritime Dangerous Goods (IMDG) code already includes changes in titles used for tank definitions regarding contents, equipment, and procedures.
International rules are expected to be imposed on confined space entry, said Robert Yuna, chairman of the Guidelines Committee. Before a person could enter a tank, a valid certificate of cleanness and a confined space entry permit would have to be issued. TCA supports these requirements.
In addition to independent considerations by international agencies, the US Department of Transportation (DOT) has asked the UN Committee of Experts on the Transport of Dangerous Goods to classify tank containers by groups and types. Bottom loaded containers are likely to be designated for specific products.
"Some products that are now being carried in them may be prohibited in the future," Antoniou said.
Valve Rule One regulation that has garnered attention in the United States is a DOT rule that went into effect October 1, 1998. The rule requires all tank containers carrying hazardous materials to have a thermal-activated device in the remote closure of the bottom valve on portable tanks. This fusible link is a piece of metal that melts at a certain temperature and causes the outlet valve to close.
"Everybody is ignoring the rule because of the way tank container valves are constructed," said Antoniou. The valve is different from a cargo tank valve. On tank containers, the valve locks open and requires an application of force through cables or rods/linkages to unlock and then spring-close. If the link melts, it may not close.
"The industry needs a reasonable implementation period, such as three years, so that retrofits can be made when the tank is taken out of service for the statutory 2.5 or five years periodic inspection and tests," Antoniou said.
Concern about this issue, and others affecting tank containers, has prompted the TCA to expand the organization's proactive political role to interject the industry's perspective during governmental deliberations.
In what seems to be a contradictory decision, the rule does not grandfather existing equipment, leaving thousands of tank containers in circulation with what DOT claims is inadequate equipment, he said.
Members of the TCA Regulatory Committee have met with government officials on this issue and were awaiting a response at the time of the meeting. "They did listen to us," said Antoniou. "We are expecting some concessions on the compliance date."
Antoniou urged TCA members to serve on the Regulatory Committee. To encourage participation, special arrangements have been made to save time for members by conducting meetings via conference calls. He said taking part in the governing process is even more essential because of the industry's growth that has flooded the world's market, bringing a greater need for standardization and unified repair guidelines.
Antoniou estimates there are 100,000 tank containers in use around the world and another 8,000 are added each year.
Regis Zelenz, manager of international operations for Air Products and Chemicals Inc, used his company's experience to define the industry's growth in less than a decade. Air Products placed 33 tank containers into service in 1990. Today, the company has 440.
To meet the demands of the growing industry, TCA provides a guidelines and definitions manual for its members. An updated version released this year was presented at the Houston meeting by Yuna. He urged managers to consider implementing the manual's procedures.
Container Improvements As an example of ways to improve containers, Zelenz recommended that thermometers be nonfailing and fixed to the vessel's external wall and that containers have a place to draw product samples other than through the dome lid.
He also said that companies offering containers for lease should provide technical knowledge and support to their customers. "As a shipper, I look to the companies that have technological expertise," he said. Terminal and depot personnel should receive comprehensive training so that they understand why a noncompliant container is taken out of service and be able to explain the situation to a shipper."
"The most important thing we look for is the technical support," said Bob Florich, manager of rail and International Standards Organization (ISO) fleet for AlliedSignal Inc.
"We use only one leasing company and we lean on them for technical support, repairs, and any unusual transportation requirements that may arise."
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