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.
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,......
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.
Coaldust, I only talk to myself when I need an expert opinion on a problem.
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 -$275 for a 5 year CSC. What should I charge in Alaska? Meanwhile, I’m signed up to go to container school with the IICL, just to have a paper trail in the event that I get audited. Container Skool? Whoduthunkit?
Sign me up! I 'll go get some certs and come to the thawed out north for some certi fyin and salmon Fryin.
Lol. My goodness. Love it. That made my day.
Sock puppets....put one on each hand, sharpy to label them so you can remember whom your talking to....
This story reminds me of the time a very expensive new 250T mobile crane belonging to our outfit overturned (late 1970’s) and the resulting investigation got all the way to the courts. It all centred around the fact that crane inspections, and the signing of the crane log book, had to be performed by a “competent person” according to the Construction (Lifting Operations) Regulations that were in force at the time. The problem was that no definition of such a person existed Within said regulations. What came out of the case was that any person performing crane inspections was deemed to be competent until proven otherwise…..!! Things have changed a bit since then.
Skyking1 “I'll go get some certs and come to the thawed out north for some certi fyin and salmon Fryin.” I was just thinking about that. I’ll be up and running with the paperwork, regulatory nightmare and function specific training behind me. Holy Cow,... We’ll be chillin’ the most and marine survey stamping those b$tches up and down the coast!! Knowwhatimsayin?
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.
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?
EW!
Sounds like all them fancy certifying books are written in ebonics yo.
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.
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.
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.
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
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.
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.
How do you dump pressure when done ?
I'd guess there's a bleeder on the other end, have to get all the air out before you can start the test. Probably a nearly identical procedure to testing fire hose, except different pressure. We test most of our attack line to 300 psi.
Yeah. I put a ball valve on the opposite end. Interesting you mentioned fire hose testing. I was just looking at the test apparatus they use. That would be more convenient. Especially, if I was doing these in bulk.
Same pump.
Worked at a tank shop where one of the foreman made a major boo boo. Hydrotesting a 750bbl tank with studs welded on to hold insulation. Everything that needs to be welded on has to be done before hydrotesting. Filled the tank with water and testing went fine. Told a labourer to let the water out. Big mistake! Forgot to remember that the pressure needed to be released first. Water came out alright. It also sucked the head of the tank in! Expensive mistake!
Woooooosh. My goodness.
It was one of the most expensive tanks they made. Most are just air tested to 1.5 to 2 PSI. That doesn't seem like much but if you walk by when the air is being let out of a 1" or smaller valve you'd swear it was like letting 100 PSI out of a compressor. 400bbl were the most common size. I built a couple hundred hooped safety ladders for 400bbl tanks. Longest ladder was 58' and they lost it. I think the 2 sections got used on another tank so I had to make another 58 footer. Not the only time I had to make another ladder. A bed truck came to pick up a 400bbl tank and when the driver winched the tank over on it's side forgot about the ladder on the far side and mangled it. I got a little sick of building ladders but it was a pretty good job as a first year apprentice right out of high school. I got out of school early because I was offered the job. My welding teacher said I should take the job and don't need to stay till schools out. My grades were good. Lots of apprentices just do crappy jobs like grinding and hardly do any welding the first year.