Safe storage and handling of containers carrying dangerous goods and hazardous substances

CEFIC/ ECTA Guidelines
**Issue 1 - March 2018**

Content

1. Introduction 6
2. General Site Operations 8
2.1. General Requirements 8
2.2. Site Access 9
2.3. Registration of a Product on Site and Entrance Check 9
2.3.1. Reviewing a Storage Request 9
2.3.2. Entrance Check 11
2.4. Marking and Labeling 13
2.5. Working Conditions 13
2.6. Housekeeping 14
2.7. Management of Change 15
2.8. Competencies and Training 16
2.9. Human Behavior and Behavioral Based Safety (BBS) 17

3. Storing of Containers 18
3.1. Segregation 18
3.1.1. Basic Principles and Recommendations 18
3.1.2. Recommendations on Segregation 19
3.1.3. Tank Container 24
3.1.4. Box Containers 25
3.1.5. Measures for Segregation 25
3.2. Container Stacking 26
3.3. Flooring 30

4. Equipment 31
4.1. Equipment Selection and Specification 31
4.1.1. Moving Equipment 31
4.1.1.1. Terminal Tractors and Tractor-Trailer 31
4.1.1.2. Chassis 32
4.1.1.3. Other Vehicles 32
4.1.2. Lifting Equipment 32
4.1.2.1. Mobile Lifting Equipment 32
4.1.2.2. Cranes 34
4.2. Inspection and Maintenance of Equipment 34
4.2.1. Pre-Start Checks 35
4.2.2. Periodic Inspection 35

5. Container Operations 35
5.1. Internal Transport and On-Site Traffic 35
5.1.1. Layout of Traffic Ways 35
5.1.2. On-Site Traffic Regulations 36
5.2. Safe Handling 37
5.2.1. Loading, Unloading and Lifting Operations 37
5.2.2. Qualification of Personnel 38
5.2.3. Unattended Machinery 38
5.2.4. Safe Coupling and Uncoupling of Equipment 39
5.3. Inspection and Maintenance of Containers 39
5.4. Heating of Containers 40
5.4.1. Product Evaluation 41
5.4.2. Control of Steam/ Water/ Glycol Pressure 41
5.4.3. Glycol/ Water Temperature 41
5.4.4. Product Temperature 41
5.4.5. Overflow 42
5.4.6. Heating Plan 42
5.5. Sample Taking 42
5.6. Transferring Material into another Container 43

6. Emergency Response & Spill Preparedness 45
6.1. Spills 45
6.1.1. Small Spills - Dripping 46
6.1.2. Large Spills 47
6.2. Exposure of People 47
6.3. Fire and Explosion 48
6.4. Natural Disasters/ Climatological and Geographical Risks 50
6.4.1. Temperature 50
6.4.2. Flooding and Heavy Rain 51

7. Abbreviations 52

APPENDICES 53
Appendix 1 - Model Container Terminal Risk Assessment 53
Appendix 2 - Container Segregation - Additional Information 53
Appendix 3 - CEFIC/ ECTA HSSE Self-Assessment for Container Storage 54
Appendix 4 - Pre-Start Checklist for the inspection of Trucks used onsite. 54

Figures

Figure 1 - Overview of typical elements of a HSE-MS and a selection of procedures that would be expected to be in the Planning & Procedures section for a container storage terminal 8
Figure 2 - Flowchart: Product Registration 12
Figure 3 - Tank containers (front) and box containers (back) 25
Figure 4 - Swap body (top) and 20’ tank container
Figure 5 - 40’ tank container 26
Figure 6 - Stacking of 20’tank containers (left), swap bodies (right) and block stacking of empty box containers (in the back) 28
Figure 7 - Schematic representation of a stair stacking of containers that should be more stable in high wind speed situations 28
Figure 8 - Swap body tank containers are sometimes of such a design that it takes some skill and careful maneuvering to place the containers well on top of each other 29
Figure 9 - Containers on a liquid tight floor 30
Figure 10 - Terminal tractor 31
Figure 11 - Empty handler 33
Figure 12 - Reach stacker (for loaded containers) 33
Figure 13 - Rail mounted gantry crane (RMG) 34
Figure 14 - Containers connected to a heating unit 40
Figure 15 - Pump, running on diesel (no sparks), for chemical liquids 44
Figure 16 - Movable drip tray 46

Tables

Table 1 - Guidance on working conditions at a container terminal 14
Table 2 - Overview and examples of typical changes 15
Table 3 - Typical Management of Change (MOC) process6 16
Table 4 - Unintentional errors and their follow-up 17
Table 5 - Types of rule breaking and corrective actions 18
Table 6 - Recommended container segregation based on Product Hazard Phrases or ADR class and a Priority figure 21
Table 7 - Guidance on maximum container stacking height for ISO Containers depending on whether empty or loaded and wind speed 27
Table 8 - Guidance on maximum container stacking height for Swap Body Containers depending on whether empty or loaded and wind speed 27
Table 9 - Overview of typical traffic signs on a container terminal 36

Introduction

A significant part of the transport of chemicals in Europe occurs in intermodal transport units (ITUs), e.g. iso-containers, and makes use of the intermodal infrastructure in place. This transport mode can contribute up to 60% of the total transport volume. Whereas currently the majority of the transport volume is based in Western Europe, this Cefic report[^1^] indicates potential for increasing volumes into, in particular, Russia and South-East Europe. Container terminals for short-term storage of ITUs, but also longer-term storage of preloaded ITUs, are a key part in the intermodal transport infrastructure for ITU transport. Next to a few (very) large hubs, a significant part of the container flow is handled through small and medium sized container storage terminals.

While large explosions such as those in 2015 at Tianjin China (173 fatalities, 8 missing and about 800 people injured) are fortunately an exception, smaller scale incidents happen regularly. Indicative of the situation at container terminals is a 2013 analysis by TT Club, provider of insurance and related risk management services to the international transport and logistics industry. The analysis of 9500 claims valued at US$ 400m associated with container terminals showed that “the majority (68%) were due to poor operations and processes and a further 14% resulted from maintenance related issues. Only 18% were caused by weather related issues, seemingly out of the control of the operator, but an amount of these could have been avoided through more adequate preparation”. The main area of risk appeared to be in the operation of mobile equipment such as quay cranes, lift trucks, rubber‐tyred gantry cranes and straddle carriers. ITUs containing dangerous goods and hazardous substances bring a further significant risk dimension to the storage of containers.

Whereas the storage of packed dangerous goods up to 1000kg (e.g. IBCs) in warehouses and bulk liquids in fixed shore tanks is frequently well regulated, the storage of ITUs is often less well regulated. In member states of the European Union, the container terminals exceeding certain storage quantities will need to meet the Seveso III Directive on the control of major accidents. The Directive requires:

The notification to the authorities of a new site.
A Major-Accident Prevention Policy (MAPP).
Implement MAPP through a Safety Management System including a Risk Assessment.
For so-called upper-tier sites, a Safety Report has to be produced every 5 years. An upper-tier site is a site that contains more than a specified amount of certain dangerous goods.
The management of change.
An Emergency Plan for upper-tier sites.
The need to inform the public.
An incident notification/ registration.

While the storage of packed goods is in most EU countries well described in regulations, it appears that the storage of ITUs is only very limitedly addressed. Examples are the Technical Rules for Hazardous Substances - Storage of Hazardous Substances in Nonstationary Containers (TRGS 510) in Germany and a short section on iso-containers storage in the Dutch PGS 15 - Storage of Packed Dangerous Goods.

While taking into account the above regulatory landscape, this CEFIC/ ECTA Guideline will provide guidance on the safe storage of ITUs based on:

a risk assessment of the storage of ITUs on container terminals,
best practices from the companies contributing to this Guideline and
the existing regulations. When local or international regulations set more stringent requirements than the guidance in this Guideline, those regulations prevail.

The scope of this Guideline is the safe (intermediate) open-air storage and handling of hazardous and non-hazardous goods in tank- and box container at small and medium sized container terminals. The handling includes among others, placing into and releasing from storage, transport inside the terminal, sampling, heating/ cooling and transferring product from container to container. Not in scope are the large deep-sea marine shipment container terminals. Nor is the storage of:

Explosive products and substances (GHS Symbol 01; H200-H205)
Ammonia nitrate and ammonium nitrate containing formulations (Weight percent > 10%)
Organic Peroxides and formulations of these, unless they contain less than:
- 5 % of organic peroxides or
- 0,5 % active oxygen from organic peroxides and additionally the weight percent of hydrogen peroxides is below 5%
Radioactive substances
Hazardous substances with the danger of infection.

The guidance provided in this Guideline is based on an assessment of the typical risks present in a small-medium sized container storage terminal and best practices from the companies that contributed to this Guideline. The Model Container Terminal Risk Assessment can be found in Appendix 1 and might form the starting point of a risk assessment of a specific terminal. In that case, it should always be reviewed in detail to take into account local circumstances, chemicals stored and local processes. Section 2 focusses on the general operations at a container terminal including site access for people, equipment and containers. Section 3 provides guidance on the storage of containers including container segregation and stacking. Equipment and its inspection and maintenance is addressed in Section 4, while Section 5 is looking deeper into the handling of containers e.g. in moving, lifting and heating. The last section provides guidance on when operations go wrong and an emergency situation occurs.
A (self)-assessment form provided in Appendix 3 will allow terminal management and potential customers to assess the current situation at a terminal against the guidance and best practices in this Guideline.

General Site Operations

General Requirements

Experience learns that a safe site runs efficiently. Basically, in order to work safely certain performance standards, processes, work planning and execution and control on changes to these, should be in place. Establishing these structures will also ensure that the basic work process runs efficiently. This can be achieved by means of an effective HSE Management System, which is named Safety Management System in the Seveso regulation. Figure 1 gives an overview of the generic elements of an HSE Management System in the context of a container terminal. Some of these HSE elements will be addressed in more depth in the subsequent section.

Figure 1 - Overview of typical elements of a HSE-MS and a selection of procedures that would be expected to be in the Planning & Procedures section for a container storage terminal

Site Access

The access to the site should be limited to those people and products that need to be. This, among others, to avoid that theft and/or tampering with containers and equipment can take place. Moreover, this also will reduce the chance that someone enters an area were the person should not be in and be exposed to moving equipment or hazardous product without the correct PPE. Unlawful entrance to the site should be prevented, e.g. using a fence. A documented entrance check should take place on all people (staff, contractors, drivers, visitors), transport documentation (including ADR certificate and driver ID) and product before site entrance is allowed. Drivers and any other visitors should receive instruction on site rules including PPE to use, how/where to deliver the container and what to do in case of an emergency. Equipment should be checked (including leakages) before it enters the site or immediately afterwards. Equipment that does not meet regulations, site requirements or is leaking should be dealt with according to site procedure.
Visitors that will enter the site on foot should be given clear instructions on the lay out of the terminal and where they can go and where not. They should be given guidance on PPE’s to wear and how to behave in a safe way. One of the instructions should be to always be aware of location of moving vehicles by monitoring the sound and by making eye contact with the drivers, where ever pedestrians and moving equipment may cross their path. The next section will provide further guidance on, among others, the entrance check for product and equipment.

Registration of a Product on Site and Entrance Check

Reviewing a Storage Request

Before a new storage agreement can be closed, a proper management of change (MOC) should have taken place (see also section 2.7 below) in which it is determined whether the product can be stored and handled safely on site and within the permit. (See also Figure 2 - Flowchart: Product Registration)
To be able to do the assessment of the new storage request (Storage Request Check) from a product hazard and legal perspective the following information would be needed from the customer:

SDS (preferably local language(s) of storage(s) and/or English)
Product name
Chemical product name
GHS/CLP classification
UN number/ CAS number
Proper Shipping Name
Classification (+ subsidiary risk)
Packing group
Flash point
Boiling point
Weight
Suitable Personal Protective Equipment (PPE)
Suitable extinguishing media (water/ foam/ etc.)
Type of shipping unit
Customer name

Based on the above information it is recommended to consider (among others) the following questions to evaluate whether the storage request can be accepted and the subsequent further processing of the unit at the terminal can be executed:

Chemical properties:

Poisonous substance?
Flammable substance?
Does it represent a hazard when in contact with extinguishing agent?
Specific requirements regarding PPE in case of a Loss of Containment (LOC)?
Present PPE sufficient?
Current means of spill control sufficient?

Storage considerations:

Presence of substance allowed according to permit?
Limitations in volume according to permit?
Modification generating change in permit, notification to authorities required?
Logistical modifications needed? (entry- and exit road, transport, stacking area)?
Additional separation rules necessary for safe storage?
Negative health effects in case of exposure?

Procedures and training:

Additional controls necessary at entry?
Modifications to current procedures and/or instructions?
Extra training/ instruction needed?
Is there a need for creating an additional risk scenario?

Repressive services:

Are the present extinguishing means sufficient and suitable in case of an emergency (fire or LOC)?
Is there the possibility of a reaction in case of contact with the extinguishing means?
Are the present means of spill control sufficient in case of a LOC?
Emergency plan to be adjusted?

Heating/ Cooling:

Heating/ cooling of the product allowed?
Desired product temperature?
Can the required method of cooling/ heating be applied?

Transferring product into another receptacle:

Is it allowed to transfer the product?

The site should have a structured process in place to handle this assessment and predefined roles who are authorized to approve such storage and handling requests (e.g. Director, Site Manager) and who should be consulted in the process (e.g. HSE Manager, Dangerous Goods Safety Advisor DGSA). The storage location to be selected must be suitable for the products to be stored according to the product characteristics and site segregation rules (see section 3.1).

Entrance Check

Intermodal transport units (ITUs) need to be registered with their storage location upon arrival. For terminals that underlie Seveso III Directive this is a legal requirement, and best practice for all other terminals as a prompt registration is key for an effective emergency response. When the container arrives at the terminal, it must be first checked whether the ITU and product is registered in the terminal (IT-)system and whether an order for storage exists. If this is not the case, the container should not be allowed to progress until the situation is resolved and it is ensured that the review as described under 2.3.1 is completed. The site (IT-)system should contain all relevant information for handling of the transport unit. Subsequently a visual check will need to be done. The visual check should contain both a technical and formal check:

Visual technical check of the handling unit conditions on/of:

leakage (leaking unit)
visual deformations of the transport unit
pressure (depressurized)
temperature (if necessary)
used container type

Visual formal check of the handling unit conditions on/of:

container state (loaded/ unloaded/ cleaned)
properly labeled and marked according to legislation/ regulations (ADR/ IMDG) (see section 2.4)
seals
seal number
Container number
CSC/ ACEP/ ITCO
Driver documents

Only if the checks are in line with site rules and expectations the ITU should be allowed on site.

Figure 2 - Flowchart: Product Registration

Marking and Labeling

Special attention should be paid to Marking and Labeling during the entrance check, in order to prevent typical errors, which are placards, marks or labels that are: