Category Archives: Uncategorized

Question:  “Our office in Japan will be sending a gas tank to the USA with class 2.2 Non-toxic/Non-flammable. The tank will be gas free when offhire. Does the tank needs to be cleaned in order to prep the tank for the next loading?” 

Tank Guru:  I suppose it depends on what mean when you say ‘gas free’ and also what you mean by ‘next loading.’  

In my mind, gas-free means ‘safe for fire, safe for man,’ or in other words, the tank is safe to enter when you check the LEL and O2 levels and there is no risk of fire.  This definition of gas-free also includes nitrogen as a gas, meaning that the O2 level is high enough that a worker entering the tank can safely breathe without special PPE. 

If the tank is truly gas-free to this standard, then it should be good enough to meet the offhire requirements of most lessors since an interior inspection would normally be performed in the process of writing the offhire estimate. 

But if by ‘next loading’ you mean that it is going to be reloaded immediately upon arrival to the U.S. instead of off-hired and then loaded at some future date, then I don’t think the tank would necessarily need to be safe to enter.  So long as all residue of the previous gas has been purged from the tank and the atmosphere inside is completely inert (for example a nitrogen atmosphere), then I think that is normally more than good enough for loading the next cargo.

Question:  “ISO Tanks are assigned a six-digit serial numbers by an international body. Can we label a tank with a different serial number?  The six-digit serial number remains on the tank.  For example, we have a tank with a serial number 117003.  We labeled the tank as AH-1.  This is how the tank is identified on a BOL.  Is this authorized?  Can we do this legally?” 

Tank Guru:  Absolutely, provided you are talking about transportation domestically.  If the tank were traveling internationally and going on a container ship, you would want to refer to it by the container number (the six digits you refer to above, preceded by the 4 alpha characters and then followed by the check-digit).  For more information on that numbering system, please see this link:  https://www.bic-code.org/bic-codes/

But if the tank stays on a chassis and you’re just referring to trucking the tank container from A to B, then you can call it whatever you want on the BOL.  Hope that helps.  Great question!

Question:  “Is there anything in CFR about pressure-testing lined tanks?” 

Tank Guru:  Not that I’m aware of. All tanks have to be pressure tested, regardless of whether they are lined.  Additionally, the lining should be inspected visually as you would perform an interior inspection at the 2.5 and 5-year periodic anyway; and if the visual raises cause for concern then a spark test (or other type of additional inspection) may be warranted.

There is the IMDG language about waiver of the interior inspection during 2.5 year test for tanks in dedicated service (as I suppose that many lined tanks are), but as a tank owner you certainly wouldn’t want to skip something so important as a chance to ensure that your lining is holding up against the cargo!

The WordPress.com stats helper monkeys prepared a 2015 annual report for this blog.

Here’s an excerpt:

A San Francisco cable car holds 60 people. This blog was viewed about 2,000 times in 2015. If it were a cable car, it would take about 33 trips to carry that many people.

Click here to see the complete report.

Question:  “We don’t want our company’s name on the tank container, because the cargo transported is very hazardous.  Can we just leave it off the data plate?” 

Tank Guru:  Nope, sorry.  Under 49CFR §178.274 (Specifications for UN portable tanks), Sec. 178.274 (i)(2) requires that the name of the tank’s operator (or owner, in the case of owner-operated tanks) “must be marked either on the portable tank itself or on a metal plate firmly secured to the portable tank” such as the primary data plate.

On the one hand, it is understandable that you would want to avoid unnecessary exposure, but on the other hand if there is an incident involving your tank, it is important for the authorities to be able to know who to contact.

Question:  “How do we create our own prefix for our container unit numbers?” 

Tank Guru:  Container prefixes, whether for tank containers or standard dry van containers, need to be registered with B.I.C. (the Bureau International des Containers et du Transport Intermodal) in Paris, France.  Their website is http://www.bic-code.org and it outlines the reasons for the globally recognized numbering system, as well as the process to register your own code.  The registration form for that can be found here:  http://www.bic-code.org/images/file/Formulaires/7%206%201.pdf

Also on the B.I.C. home page is a link to a neat little check digit calculator.  Once you register your 4-digit Alpha prefix and decide on the 6 numeral digits that you will assign to your container (or series of containers), you can use their check digit calculator to complete the numbering system for your container(s) and mark them accordingly.  Click here for that:  http://www.bic-code.org/calculate-the-check-digit-online.html

Lastly, if you see a container with a prefix that you are not familiar with and want to know who the registered owner is, the B.I.C. website is again the place to go.  Use this link (http://www.bic-code.org/consultation-of-the-containers-bic-code-register.html) to search by prefix.  For instance, type in “ZIPU” in the Code box and click “send” and this is the result you will get!  http://www.bic-code.org/container-bic-code-zipu.html

The WordPress.com stats helper monkeys prepared a 2012 annual report for this blog.

Here’s an excerpt:

The new Boeing 787 Dreamliner can carry about 250 passengers. This blog was viewed about 1,400 times in 2012. If it were a Dreamliner, it would take about 6 trips to carry that many people.

Click here to see the complete report.