Question: “We have a customer that wants to load a 1.17 SG product in 24000 liter tanks. Because the product will solidify in transport as it cools, a representative from one of the Class Societies said it would be OK.
The problem we see is that once the product arrives overseas and is heated at a depot prior to being delivered to the customer, it will no longer be solid and we believe it will no longer meet the viscosity requirements in IMDG 4.2.1.9.6 that allow you to ignore the 80% fill rule. But the Class Society representative says that the IMDG viscosity criteria is at 20° C, and since we are having to heat the product above 20° C in order for it to be viscous, therefore we are in luck.”
Tank Guru: His logic makes sense; however it sounds like complying with the letter of the law but not the spirit of the law. If the rule is there to prevent a dangerous slosh and surge situation, but you dodge the rule because ‘had the product been cooler it would have been less volatile’ — then good luck defending that position in a court of law if there is a rollover accident resulting in death or injuries.
I think you should convince your customer to use 21000 liter tanks, which will generally have a lower tare weight than larger tanks, and allow for slightly more payload anyway. #CommonSenseSafety
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