The carriage of dangerous goods in tank containers is a regular occurrence, but accidents involving tank containers are far less common than with cargo in standard boxes. Shippers and lines could be well advised to learn from the successful tank container industry to prevent serious accidents such as the 2018 fire on the Maersk Honam, and others.
Since the first cylindrical tank containers were manufactured with ISO frames some 40 years ago, they have become one of the most common methods of transporting hazardous and non-hazardous cargo, yet surprisingly the tank container industry holds a relatively unblemished safety record with only a handful of major incidents clouding its history.
Richard Brough of the International Cargo Handling Coordinating Association (ICHCA) believes that despite the obvious differences between the industries, the general cargo world could adopt some general learnings from the tank container industry.
Brough states that shippers should “understand fully the nature of the goods being shipped and fully comply with the regulations and the Guidance in the CTU Code, and we could save many incidents from vehicle roll-overs through to catastrophic ship fires”
Cargo theft and physical damage to containers is far lower than in the general container supply chain, explains the TT Club’s Mike Yarwood, managing director loss prevention. He added, “The value of the tank container as an asset, in comparison to a standard container, arguably motivates owners, operators and lessors to perform greater levels of due diligence on customers, shippers and the cargoes to be carried, to ensure that the asset is safeguarded.”
Tank containers managed to stay out of the news in 2019 despite numerous vessel fires hitting the headlines. However, the MSC Flaminia fire in 2012 and the subsequent trial that found the shipper and the NVOCC/tank container operator solely responsible, is a solemn reminder of the risks associated with the transportation of hazardous cargo.
"The industry is all about the safe transportation of chemicals and, as such, is highly regulated with trained and competent staff," comments Steve Rowland, safety, security, health, environment and quality management director at tank logistics firm Suttons. He explains that dangerous goods training is given to all staff involved in the journey and adds that through specialist insurers, there are opportunities for shared learning following a major incident such as the MSC Flaminia.
As the tank container market continues to grow year-on-year as a direct result of production, (the global fleet stood at a whopping 652,250 units on 1 January, according to International Tank Container Organisation (ITCO) data, ensuring the safe carriage of goods is an energetically discussed topic.
The fleet is invariably made up of shipper owned units, rather than shipping line-owned, with 54,650 tank containers entering the global fleet in 2019. ITCO found that the majority of these new tanks were purchased by leasing companies – mainly to service the equipment requirements of tank container operators.
ITCO notes that the industry has also seen growth in the number of 3PLs and 4PLs entering the market. "These companies often have little - or no - accredited infrastructure to support their growing fleet of tanks, which (we can assume) they have taken on because of the low lease rates on offer, and on a shorter lease period."
Yet, incorrect handling of a tank container remains rare. "It's a bit like air freight," said Brough, "The established players who move tank containers, understand what they're doing and the construction of tank containers, and type of cargo you put in them, is heavily regulated."
He points out that it's tough to enter the tank container market if you're not an established player, which facilitates self-regulation to a certain extent.
Due to its robust design and durability, the tank has become recognised as the safest, most cost-efficient, flexible and environmentally friendly means of transporting bulk liquids and chemicals globally. It is also considered a valuable asset that, if well maintained can remain in operation for decades.
"Tank containers are constructed to stringent ISO standards and have to be approved by the competent authority of the country they are registered in. They are built to IMO specifications as well," comments Brough.
Logistics insurance specialist TT Club has an insurable interest in around 50% of the global fleet of UN portable tanks and Mike Yarwood reveals that risks in the supply chain as a result of incorrect handling of a tank container and its cargo are extremely rare. "The low level of incidents is perhaps due to a combination of the applicable regulations - as this is a heavily regulated part of the industry - and the ownership of the asset."
He notes that the environment in which tank operators do business is complex and challenging and attributes the comparatively few incidents reported as a "testament to their expertise, professionalism and dedication to safety."
"We still have problems," adds Brough. "I've visited, and audited terminals around the world that have lots of tank containers moving through and they haven't necessarily segregated them, as you would expect to do onboard a ship. You've got non-compatible chemicals sat next to each other."
He observes that it is common for a tank container to be left out in the terminal as it comes off road transport or onto rail cars, which is more frequent.
When assessing types of claims, TT Club has found they are primarily associated with the contamination of cargo. These risks exist because of the nature of the tank, but they are largely very well managed. "It's a very well-known and recognised risk in the industry," says Yarwood.
Contamination and customer liability claims are about 60% of all claims the TT Club receives. Still, when looking on an average of moves per year per tank in existence, the failure rate results in a fraction of a percent.
"Because of the specialisms, tank operators have to be that much more aware of the regulations and the complexities, and generally have a greater investment than other freight forwarders or logistics operators, who don't have to make that investment in equipment," comments Peregrine Storrs-Fox, TT Club's risk management director.
Regulations, as outlined in TT Club's latest StopLoss publication, including: The International Convention for Safe Containers, 1972 (CSC) as amended; an approved pressure vessel code (in most instances ASME VIII Div.1); and the International Maritime Dangerous Goods (IMDG) Code (or similar modal specific dangerous goods regulations) all play a significant role.
Tanks used for international transport including a maritime leg must comply with CSC, which requires that before approval for construction is given, prototype testing is carried out to ensure compliance with the Convention. Swap tanks may not need to comply with this regulation if it is to be carried on land-based transport modes such as road and rail. In addition, tanks should also fully comply with the requirements of the Transports Internationaux Routiers (TIR) convention and specific transport mode requirements such as the Union Internationale des chemins (UIC) code (railway).
Additionally, tank pressure vessels are required to undergo weld non-destructive tests (usually radiographic) and a hydrostatic test on completion of construction and undergo testing every 2.5 years. Failure to pass these tests will result in the tank losing its DG approvals.
"The regulatory system is managed by the UN which helps to maintain consistency across different modes of transport and different countries," says Rowland.
He explains that the Dangerous Goods Regulations are mode specific (IMDG for marine, ADR for road) and they provide the whole framework covering design, testing, inspection, training, qualifications, documentation and marking of tanks. "Although it is a global standard, it is enforced by the competent authorities at a national level. This is certainly a contributing factor to having relatively few reported incidents."
Due to a heavily regulated environment, the lack of serious incidents relating to tank containers can, perhaps, be put down to conscientious stakeholders in the supply chain.
"A lot of what we see is probably down to the tank operator performing due diligence and understanding what the cargo is, knowing who the shipper is, and then making informed decisions about which tank equipment to use," explains Yarwood.
It is clear that tank operators understand the potential risks of transporting dangerous goods, and as the tank container itself is a valuable asset, they tend to go that little bit further in protecting it.
On the topic of misdeclaration, Brough stated: "You don't get that with tank containers generally." While Rowland said, the "globally harmonised" regulatory system gives the line more confidence in the information contained in safety data sheets. "There is more rigour around product approval to ensure compatibility between the product and the tank it is being carried in."
He also notes there is a willingness across the industry to share good practice to improve safety in operation.
The tank container industry has embraced the technological era, and as data-based technology expands, with the Internet of Things and 5G, advanced connectivity is being incorporated into operations. Many established players have been developing smart tanks which provide real-time information on a number of data points such as temperature, pressure and location.
"The entire container freight industry should adopt these technologies without hesitation," says Brough. "Being able to spot something beginning to go wrong much more quickly, has to be a step in the right direction."
However, he notes that there can be "negative consequences of positive actions." He refers to the use of lithium batteries as part of the tracking systems on tank containers. People are concerned about whether the batteries are built to standard and can go into the hull of a vessel.
Nevertheless, the tank container industry is heavily regulated and very compliant due to the nature of the product that's being carried. Not to mention the requirements faced by those wanting to enter the tank container community, which remains a tough barrier.
Katerina Kerr
Tank Container Correspondent
