Do we have anyone on the HEF that certifies these things or is familiar with testing them? Can anyone with an PHMSA “M” Number re-test them? And yes, I’ve had my nose in the rule book all day and my eyes are crossed. One of my customers is asking me.
Anyone familiar with UN T50 LPG ISO’s?
Started by Coaldust26 replies
CoaldustSuper User#1 CoaldustSuper User#2 What a regulatory nightmare. So, I’ll reply to my own question. Yes, Coaldust. If the PHMSA people issued you an “M” number, you can inspect UN portable containers all day long and holidays. But, what if I put it on a boat and ship it to Seattle? Well then CFR 452.3 applies. (3) each exam must be performed by qualified personnel, trained and experienced the detection of structural damage. *** does that mean? Is there a school or credential for that? Or, is it based upon self certification? Can I provide some training and claim my employee is trained and experienced? Where does the intermodal container CSC Safety Survey fall into this? Who can do CSC surveys? Is a current CSC even required for domestic transport? The rules only say export. Should I even care what the IMO says? There office is in London. They don’t have any way to enforce regulatory compliance on me. The struggle continues,......
CoaldustSuper User#3 Do you ever talk to your self as you work through a problem? Fellas, Can you keep a secret? Under clause 12.4.1.3 ISO/CSC guide, 2014 latest edition. It states there is no “certification” required for inspectors to extend the expiration date on a CSC certification plate. It only says the “inspector” have such knowledge and experience. I attached a picture of the interpretation.
sled dogJunior Member#4 Coaldust, I only talk to myself when I need an expert opinion on a problem.
CoaldustSuper User#5 I’m in the ISO container business now. ! I talked to a couple inspectors today in the Seattle area. Looks like the going rate is $200 -$275 for a 5 year CSC. What should I charge in Alaska? Meanwhile, I’m signed up to go to container school with the IICL, just to have a paper trail in the event that I get audited. Container Skool? Whoduthunkit?
skyking1Super User#6 Sign me up! I 'll go get some certs and come to the thawed out north for some certi fyin and salmon Fryin.
CoaldustSuper User#7 Lol. My goodness. Love it. That made my day.
DDougSuper User#8 Sock puppets....put one on each hand, sharpy to label them so you can remember whom your talking to....
NigeLegend#9 This story reminds me of the time a very expensive new 250T mobile crane belonging to our outfit overturned (late 1970’s) and the resulting investigation got all the way to the courts. It all centred around the fact that crane inspections, and the signing of the crane log book, had to be performed by a “competent person” according to the Construction (Lifting Operations) Regulations that were in force at the time. The problem was that no definition of such a person existed Within said regulations. What came out of the case was that any person performing crane inspections was deemed to be competent until proven otherwise…..!! Things have changed a bit since then.
CoaldustSuper User#10 Skyking1 “I'll go get some certs and come to the thawed out north for some certi fyin and salmon Fryin.” I was just thinking about that. I’ll be up and running with the paperwork, regulatory nightmare and function specific training behind me. Holy Cow,... We’ll be chillin’ the most and marine survey stamping those b$tches up and down the coast!! Knowwhatimsayin?
skyking1Super User#11 Coaldust said: Skyking1 “I'll go get some certs and come to the thawed out north for some certi fyin and salmon Fryin.” I was just thinking about that. I’ll be up and running with the paperwork, regulatory nightmare and function specific training behind me. Holy Cow,... We’ll be chillin’ the most and marine survey stamping those b$tches up and down the coast!! Knowwhatimsayin? Click to expand... Get the old girl up and running, then we'd be like the Pros from Dover on the original MASH movie on the Tokyo trip. This R model is a relative pig of a 310, but you get the idea.
CoaldustSuper User#12 Leaks can’t hide from me when I use my leak detection secret sauce recipe. Because, those bubbles mean tank trouble. But, don’t be trippin’. When I get done, no hazmat will be drippin’. ! Knowwhatimsayin?
skyking1Super User#13 EW!
stinky64Senior Member#14 Sounds like all them fancy certifying books are written in ebonics yo.
CoaldustSuper User#15 My verse has been a curse. Almost set up for doing these ISO’s. I have a new customer that has some T11’s that need done. I dropped off a couple gauges at Alaska Metrological for calibration and a paper trail. Next challenge is to create an inspection document. The rules are less stringent for ISO’s vs cargo ranks. But, with ISO’s in the US, you deal with PHMSA and the IMO. As long as the shipper is happy, I don’t care about the IMO. These are domestic tanks, no export involved. I do need to make sure PHMSA is happy. I need to fabricate a nice ladder for climbing inside. The barrel is much taller than a typical cargo tank.
CoaldustSuper User#16 Finding and purchasing ISO container parts is not like finding cargo tank parts, which are mostly domestic in nature and very competitive and customer service focused. The ISO container biz is a big International club and I ain’t in it. But’ I’m figuring it out. Worked the weekend and published a decent rough draft test & certification document. I’ll use it a few times to work the bugs out and pass it along to the FastField folk and have them make it sparkle.
CoaldustSuper User#17 Just an update. Getting closer to testing T-50’s. I’ve got 24 of them scattered across the state to get done before the barge season ends. The last place in the Seattle area that did them closed down in January and the place in Tukwila that does ISO’s isn’t even registered with PHMSA to “legally” test them. The T-11 ISO business is booming. I’m now the only person in Alaska that can do them. Without flying someone up from Oregon and dealing with the added expense.
CoaldustSuper User#18 The big port cities on the west coast have all but banned cargo tank wash facilities. The leasing companies are in a panic. If the tank don’t get washed, it can’t be inspected. No inspection, no shipping, no filling with product. I met with a big lease company and they want to move their cleaning and testing to AK. Huge opportunity for someone. Only one place in Ak that cleans tanks. A $1,000 clean bill in Houston is $3,500 bucks here
CoaldustSuper User#19 Time to bump this. I’m in the T50 and T75 biz now, with both feet. This was my first international client. Eurotainer in France, with an office in Houston. This bad boy is filled with liquid oxygen. Built like an old fashioned thermos bottle from the 70’s. The interstitial space is under a vacuum. Cargo tanks big or small, I inspect them all! If the hazmat is drippin’ don’t be trippin’,…… but, my HEF brethren already knew that.
CoaldustSuper User#20 Let’s bump dis’ thread. Got a big over-the-water fuel transfer on the calendar and those Coasties love their hose certifications. Hydro-testing tonight at 1.5x the MAWP and getting a bath while doing so. I need to fine tune my test rig, but it’s working fairly well. Hold for 10 minutes, paint the stems to check for slippage. Look for bulges. If that hazmat starts drippin’ the Coasties start trippin’. Don’t want a Beluga swimming by to get oil in her eye, swim up the beach and get stuck.