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Statutory Documents - IMO Publications and Documents - International Codes - CTU Code - IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units - Annex 5. Receiving CTUs
Annex 5. Receiving CTUs
1.1 This annex covers a number of actions and activities and provides safety advice for persons involved in the reception and unpacking of CTUs.
1.2 When receiving a CTU, the receiver or consignee should:
1.2.1 Confirm that the unit is as specified on the transport documentation, checking the CTU identification reference as shown in figure 5.1. If the identification reference shown on the documentation is not the same as that on the CTU, it should not be accepted until clarification is received from the shipper.
1.2.2 Inspect the seal, if fitted. Inspecting a seal requires visual check for signs of tampering, comparison of the seal's identification number with the cargo documentation, and noting the inspection in the appropriate documentation. If the seal is missing, or shows signs of tampering, or shows a different identification number than the cargo documentation, then a number of actions are necessary:
1.2.3 The receiver or consignee should bring the discrepancy to the attention of the carrier and the shipper. The consignee should also note the discrepancy on the cargo documentation and notify Customs or law enforcement agencies, in accordance with national legislation. Where no such notification requirements exist, the consignee should refuse custody of the CTU pending communication with the carrier until such discrepancies can be resolved.
2 Positioning CTUs
2.1 Wheeled operation
2.1.1 Road trailers and freight containers on chassis can be left at the packer's premises for a period of time without a tractor unit. When this happens, the correct positioning of the CTU is particularly important as a safe shifting of the CTU at a later stage might be difficult. After positioning, brakes should be applied and wheels should be chocked.
2.1.2 Trailers with end door openings and general purpose freight containers on chassis can be backed up to an enclosed loading bay or can be positioned elsewhere in the premises. For this type of operation a safe access to the CTU by means of suitable ramps is required.
2.1.3 When a semi-trailer or a freight container on a chassis is to be packed, care should be taken to ensure that the trailer or chassis cannot tip while a lift truck is being used inside the CTU (see figure 5.2).
If there is a risk for forward tipping the semi-trailer or chassis should be sufficiently supported by fixed or adjustable supports (see figures 5.3 and 5.4).
2.2 Grounded operation
2.2.1 Freight containers may be unloaded from the delivery vehicle and be placed within secure areas for packing. The area should be level and have a firm ground. Proper lifting equipment is required.
2.2.2 When landing freight containers it should be ensured that the area is clear of any debris or undulations in the ground that may damage the understructure (cross members or rails) of the freight container.
2.2.3 As freight container doors may not operate correctly when the ground is not level, the door end of the freight container should be examined. When one corner is raised off the ground, when the doors are out of line (see figure 5.5) or when the anti-racking plate is hard against one of the stops, the freight container doors should be levelled out by placing shims under one or other corner fitting, as appropriate.
2.2.4 When a swap body standing on its support legs is to be packed, particular care should be taken to ensure that the swap body does not tip when a lift truck is used for packing. It should be checked that the support legs of the swap body rest firmly on the ground and cannot shift, slump or move when forces are exerted to the swap body during packing (see figure 5.6).
2.3 Access to the CTU
2.3.1 After the CTU has been positioned for packing, a safe access should be provided. For loading a CTU by means of forklift trucks driven into the CTU, a bridging unit between the working ground or loading ramp and the CTU floor should be used. The bridging unit should have lateral boundaries and be safely connected to the CTU for avoiding dislocation of the bridging unit during driving operations.
2.3.2 If the CTU floor is at a height level different to that of the loading ramp, a hump may appear between the loading ramp and the bridging unit or between the bridging unit and the CTU floor. Care should be taken that the forklift truck used keeps sufficient ground clearance over this hump. Lining the level differences with suitable timber material under the bridging unit should be considered (see figures 5.7 and 5.8).
2.3.3 If forklift trucks are employed for packing, any roofs or covers of the CTU should be opened if necessary. Any movable parts of such roofs or covers should be removed or suitably secured in order to avoid interference with the loading procedure.
2.4 Packing of CTUs in poor daylight conditions may require additional lighting. Electric lighting equipment should be used under the strict observance of relevant safety regulations, in order to eliminate the risk of electric shocks or incentive sparks from defective cables or heat accumulation from light bulbs.
3 Removing seals
3.1.1 The height of the door handle and the seal varies depending on the type of CTU and the design of the door. Rigid vehicles and trailers are generally lower within a range of 1.1 and 1.6 m from the ground. Freight containers carried on a trailer will have the security cam fitted seal approximately 1.4 m from the ground, but the handles and any seals attached to them at a height of approximately 1.9 m (see figures 5.9 and 5.10).
3.1.2 Seals attached to handles on container doors (approximately 1.9 m above the ground) will be about head height for the average person and attempting to cut through a bolt seal at that height is likely to result in a musculoskeletal injury.
3.1.3 The best posture for cutting seals is for the operator to stand upright with the angle at the elbow between 90° and 120° and the elbow in line or slightly forward of the body.
126.96.36.199 Avoid positions where the elbows are behind the body or above the shoulder.
188.8.131.52 When gripping the cutting tool, the wrist should be kept as straight as possible.
184.108.40.206 The best position of the cutting head will be approximately 0 to 15 cm above the height of the elbow. The height above ground level to the elbow for the average (western) man is 109 cm. This means that the best position for the seal will be between 109 and 124 cm (1.09 and 1.24 m) above standing level.
3.1.4 Figure 5.11 shows a typical example of how many seals are actually cut. The operator has his back bent, the seal is well below the height of the elbow, the arms are almost straight and the left wrist is cocked, while the right appears to be straight.
3.1.5 The length of the bolt cutter levers are very long compared to the movement of the cutting blades, therefore the hands have to "squeeze" in a considerable distance.
3.1.6 Cutting resistance is high as the blades start to cut and reduces to grow again as the cut finishes. Therefore while the hands are wide apart the greatest inwards pressure is required.
3.2 Height adjustment
3.2.1 The normal height for the seals above ground level is between 1.09 and 1.24 m. This means that a normal person when cutting the lower seal position of a freight container mounted on a trailer and with an ideal stance would have their feet approximately 16 cm above ground level. For the higher seal position the foot position would be about 50 cm above the ground.
3.2.2 It is essential that the operator is able to gain a firm footing when cutting the seal. This may require the legs to be spread both laterally and longitudinally. The footing should be:
3.2.3 For cutting the seal at the lower position a single pallet with a plywood panel fixed to the top, or two pallets stacked with a plywood panel, all fixed together so that there is no risk of the items sliding independently would provide a suitable platform. However there is a risk of the operator accidentally falling from the platform during the cutting operation.
3.2.4 To access the highest seals, the use of a proprietary platform with a narrow work platform width may not allow the operator to stand comfortably and safely as the depth may not be sufficient. A second platform with a plywood panel fixed to both will allow sufficient area for the operator to stand and operate the bolt cutters safely (see figure 5.12). Such platforms should also be fitted with fall protection by way of barriers.
3.2.5 Mobile work platforms similar to the one shown in figure 5.13 may be rather more sophisticated than is required and a smaller version may be more appropriate (see figure 5.14). As an alternative a simpler device can be fitted to the tines of a forklift truck as shown in figure 5.15.
3.2.6 The important feature of a mobile work platform is that it can be adjusted to exactly the correct height, has a platform of sufficient area and provides the operator with full fall protection.
3.2.7 A ladder can be used, but this is not a really suitable platform for cutting with large bolt cutters. For smaller cutters they may be used with care.
220.127.116.11 When carrying out a task using a ladder or a step ladder it is essential that three points of contact (hands and feet) are maintained at the working position. Since both hands are required to cut the seal using the bolt cutters, the third point of contact can be substituted by leaning the chest on the ladder or step ladder.
18.104.22.168 Working on a ladder or step ladder should not involve any side loading which necessitates twisting of the body, therefore it is improbable that a ladder can be positioned so as to comply with these requirements and provide sufficient room for the bolt cutters to be operated correctly.
22.214.171.124 Therefore if there is a choice only between a ladder and a step ladder the step ladder will probably provide the better work position.
3.2.8 Figure 5.16 shows the correct position for the operator with the bolt cutters held between the step ladder and the CTU.
3.2.9 In this position there is still a risk of the ladder falling sideways as the cutters are squeezed in, therefore the operator should be supported by a co-worker or the step ladder secured to prevent it falling or sliding.
3.2.10 A safer solution is to use wide mobile steps with a top platform sufficiently wide and deep to permit the operator to stand safely.
4 Preparing to open the doors
4.1 External checks
4.1.1 Once the seal has been removed the CTU doors may be opened, however before doing so, a few more checks should be made.
126.96.36.199 Check the exterior for signs, marks or other labels that may indicate that the cargo may put those involved in unpacking the CTU at risk.
188.8.131.52 The labels shown above indicate that opening the doors should follow a particular process. Only the right hand door on a CTU carrying a flexitank should be opened (see figure 5.17). CTUs that have been fumigated (see figure 5.18) or where there is a coolant or conditioner (see figure 5.19) should be opened and ventilated before entering the CTU.
4.1.2 Dangerous atmospheres
184.108.40.206 CTUs carrying dangerous goods also should be opened with care as there is a risk that the carrying packages have been damaged and the goods spilled.
220.127.116.11 Fumigants are highly toxic. Cargoes most likely to have been fumigated include foodstuffs, leather goods, handicrafts, textiles, timber or cane furniture, luxury vehicles and cargo in timber cases or on timber pallets.
18.104.22.168 CTUs transported under fumigation are required to be marked and declared in accordance with the applicable dangerous goods regulations. However, absence of marking cannot be taken to mean fumigants are not present. CTUs marked as having been ventilated after fumigation may also contain fumigant that was absorbed by the cargo and released during transit (see annex 9).
22.214.171.124 CTUs that are fumigated should be properly marked. On occasion, marks may become obliterated or lost during transport. As CTUs may then not be appropriately marked, the doors and vents should be checked. Tape applied to door gaskets or to the vents may indicate the risk of fumigant presence (see figure 5.20).
126.96.36.199 In addition to the presence of fumigants, toxic gases associated with the cargo's manufacturing process have been found in dangerous levels, for example shoes may have high levels of toluene, benzene and 1,2-dichloroethane.
188.8.131.52 In the short term, vapours irritate the eyes, the skin and respiratory tract. Inhalation of vapours can cause pulmonary oedema. The substance can have an effect on the central nervous system, the kidneys and the liver, causing functional deficiency.
4.1.3 If there are concerns that there are signs of a dangerous atmosphere, a safety data sheet (SDS) should be requested from the consignor or from the shipper, as appropriate and sampling the air inside the CTU before opening could be considered.
5 Measuring gases
5.1 A number of surveys have revealed undeclared gases carried in CTUs. Many of the gases are dangerous and would constitute a severe risk to those involved in unpacking.
5.2 The person who controls the opening and entry of CTUs should always check the chemical properties and the threshold limit value (TLV) of the relevant chemical, referring to their own national standards and guidelines where they exist.
5.3 Unfortunately, one cannot rely on ones sense of smell as most of these gases will be well above their TLV by the time they can be detected. The only practical way is to take air samples. In the open this is very difficult. Initially, a device that identifies the gas is required before the concentration of the gas can be measured.
5.4 The simplest and easiest way to measure the internal atmosphere is to use a readily available detector tube device. Do not open the CTU but gas can be sampled by forcing a solid tube in through the door gaskets (see figure 5.21).
5.5 There is no device available that can detect all hazardous gases, therefore one measurement will not provide sufficient information about the internal atmosphere and multiple tests will be required.
5.6 The risk of hazardous gases in CTUs is relevant to all parties in the supply chain. The causes of these gases can be attributed to internal business processes in manufacturing or by actions performed on behalf of third parties (service providers and logistics companies).
5.7 Action plans for testing and reacting to hazardous gases in CTUs may be drawn up by companies to protect their employees from the effects of these gases when opening and unpacking them. The companies producing the actions plans may not be the ultimate consignees of the goods, but may be authorized to open the CTU earlier in the supply chain or responsible for unpacking.
5.8 It should be remembered that hazardous gases may be introduced into the CTU by:
5.9 In addition, incidents may occur that permit the release of gases from declared or undeclared dangerous goods being carried.
6 Opening the doors
6.1 Unstable or poorly packed cargoes may be pressing against the doors which may be forced open when the door gear is released, or the cargo may fall out once the doors are opened.
6.2 The first action for steel doors is to "ring" them which is to tap the flat surface of both doors. If the sound is dull and there is no resonance then it is likely that the cargo will be resting against the door. Extra care should be taken when opening the door.
6.3 If there is a risk that the cargo is resting against the doors or the CTU contains bulk materials, a safety chain can be fitted across the doors, from top to bottom corner fittings (see figure 5.22). This technique can be also used on CTUs without corner fittings by applying a chain from an anchor point on each side or using a shorter chain attached to the locking bars. The length of the chain should be long enough to permit the doors to open but short enough so that the doors cannot open more than 150 mm (6 in).
6.4 If a diagonal chain cannot be fitted, then a loose strap across the inner lock rods may be used. If there is no facility for attaching the strap, or strap available the person opening the doors should always open the doors with caution.
6.5 Handles for CTUs vary, some will have one locking bar, others two and the handle design may be a bar or a formed handle, as shown in figures 5.23 to 5.25.
6.6 They may be in the format where the handle is on the same side of the locking rod (see figure 5.26) or between the rods (see figure 5.27).
6.7 Most CTU doors open easily by rotating the handles approximately 90° and then pulling on the handles of locking bars. The action of rotating the bars will mean that the cams push against their keepers and force the door open.
6.8 Figure 5.28 shows the operation of the cams on many freight containers. Rotating the lock rod (A) will cause the breaker surface of the cam to press against the keeper (B), thus forcing the door open(C).
6.9 Once the lock rods have been fully rotated, adopt an upright stance and grasp the lock rods or the door at about shoulder height or just below and pull backwards using the whole body.
6.10 If the doors do not open easily:
6.11 If one door will not open, and the other door may be opened (i.e. the CTU is not carrying a dry bulk tank), then both doors could be opened at the same time which may make opening the doors easier.
6.12 As the door opens be prepared to step back quickly if:
6.13 If you need to step out of the way move away from the hinged side of the door.
6.14 Doors in the various types of CTU may open with different degrees of difficulty. The following contribute to this difficulty:
6.15 Once the doors are free to swing and there is no risk on injury caused by the cargo falling out, walk the doors through 270° and attach the retaining strap to the hook to prevent the door from swinging (see figure 5.30).
6.16 DO NOT ENTER THE CTU YET
7.1.1 Closed CTUs are enclosed spaces and care should be taken before entering. Even without toxic gases and other asphyxiates oxygen supply may be depleted which could make normal breathing difficult. Ventilating a CTU will allow fresh air to circulate into the CTU and around any cargo carried and remove any harmful or toxic gases or fumes. The most effective method is to use forced ventilation.
7.1.2 It is a risky activity and it is important that CTUs are ventilated responsibly. The person who opens and closes the doors should be aware of the possible risks involved and, if required, wear personal protective equipment (PPE). The selection of the appropriate PPE will depend on measurements taken to determine the concentration and toxicity of the gases within the CTU and may require a combination of breathing apparatus and skin protection.
7.2.1 When ventilating CTUs a number of factors will determine the action required:
184.108.40.206 The concentration of the gas. The greater the concentration the longer the CTU will require for ventilation.
220.127.116.11 The nature of the gas. Some gases are very light and volatile and will evaporate quickly. Others are less volatile and/or adhere to the cargo, such as methyl bromide and 1,2-dichloroethane. The time for ventilation will need to be decided upon accordingly. It may not be possible to completely remove traces of gases that adhere to the cargo and the CTU may only be declared clean and safe to enter after the cargo has been removed and the CTU washed.
18.104.22.168 Ambient temperature. Higher temperatures will generally permit faster evaporation thus reducing the time to declare the CTU safe to enter. At lower temperatures, some fumigants stop working and remain inert until the temperature again rises. This can mean that the correct volume of a fumigant for the journey initially applied in a hot packing location which then passes into a colder area may arrive at the destination with high levels of fumigant still remaining in the CTU.
22.214.171.124 The size of the CTU. A 12 m long CTU has approximately twice the internal volume of a 6 m unit, and if the doors are only at one end, the circulation of gas has to travel considerably further.
126.96.36.199 The packing method. A CTU that has been tightly packed and is especially full will be more difficult to ventilate than one with many gaps and "open air" around the packages.
188.8.131.52 The nature of the cargo. Cargo that absorbs gases, such as mattresses and clothes, requires more time for ventilation than hard surfaced products. Absorbent materials hermetically sealed within a plastic or similar cover will not require the same time to ventilate as an uncovered item.
184.108.40.206 Packing material used. Absorbent packing materials will require extra time for any gases to leach out. Such materials may require special disposal to meet local environmental regulations.
220.127.116.11 The time which elapsed after the CTU has been closed.
7.3 Ventilation of CTUs can happen in two ways, natural or forced ventilation.
7.3.1 Natural ventilation
18.104.22.168 This can be done by simply opening the doors.
22.214.171.124 In some countries local regulations require an environmental permit for opening CTUs with high concentrations of dangerous gases. Once the application is received the Competent Authority determines under what conditions the company may ventilate on site. The granting of an environmental permit may take up to 6 months.
126.96.36.199 Estimate the necessary ventilation time in advance. CO, CO2 or O2 degas quickly. At encountering these substances start with a minimum of 2 hours ventilation. For other substances this will be insufficient and it is suggested that the CTU is ventilated for at least 24 hours. Record start and end time.
7.3.2 Forced ventilation
188.8.131.52 To carry out forced ventilation or degassing there are several possibilities. A few examples:
184.108.40.206 The advantage of forced ventilation is that it reduces the time necessary to remove high concentration of residual gas, partly because the climatic conditions can be optimized.
7.3.3 General safety
220.127.116.11 Do not enter the CTU during ventilation.
18.104.22.168 Make sure that during ventilation warning signs or otherwise clearly indicate that the CTU should not be approached or entered. For methyl bromide, phosphine and sulfuryl fluoride, for example, a minimum distance of 20 m all around the CTU should be set.
22.214.171.124 Toxic gas concentrations in the cargo space and the cargo itself should be measured and once they fall below the limit(s) the CTU may be released for entry. Carry out additional measurements if the doors are closed without the cargo being unpacked and the interior cleaned for a period of 12 or more hours.
126.96.36.199 The climatic conditions should also be monitored and action taken if:
188.8.131.52 A specialist gas removal contractor should be used if:
184.108.40.206 Specialist gas removal contractors may move the CTU off site into closed and regulated area. The premises are inaccessible to unauthorized persons and the company guarantees that the cargo is monitored.
220.127.116.11 If in doubt, or for questions always contact a local company who specializes in the ventilation and degassing of CTUs.
18.104.22.168 Remember that toxic gases within the CTU will dissipate into the atmosphere. It should be remembered that the higher the gas concentration the greater the harm to the environment.
22.214.171.124 Consider the waste (residue) as hazardous waste. In practice this means that the waste should be offered to a certified collector to be processed or destroyed.
7.4 Ventilation first, then measure. This means that if the quantity and concentration of a toxic gas is known, then the CTU may be ventilated in accordance with the calculated time without the need for measuring the atmosphere until the ventilation time has expired. As always a test should be carried out before entering the CTU.
8 Returning the CTU
8.1.1 The internal and external cleanliness of CTUs is very important if unnecessary restrictions to their use and movement are to be avoided.
8.1.2 The receiver or consignee should return the CTU in the same state that it was delivered. This means that the CTU should be:
8.2.1 If additional cleaning beyond a thorough sweep of the CTU is required the consignees should consider the following techniques:
8.2.2 After a CTU with dangerous cargoes, including fumigated cargoes, has been unpacked, particular care should be taken to ensure that no hazard remains. This may require special cleaning, particularly if spillage of a toxic substance has occurred or is suspected. When the CTU offers no further hazard, the dangerous goods placards, placards and any other marks or signs regarding the cargoes should be removed. A CTU that retains these exterior signs and marks should continue to be handled as though it still carried the dangerous goods.
8.2.3 Contamination of the CTU can be found in many different guises:
8.2.4 Dunnage, blocks, bags, braces, lashing materials, nails into the floor and tape used to cover vents and gaskets should all be removed.
8.3.1 Local environmental regulations and legislation should be considered when disposing of waste removed from the CTU.
8.3.2 Cargo residues should be removed and disposed of in line with the consignee's procedures.
8.3.3 Wherever possible or practicable, dunnage bags and other materials should be recycledfootnote.
8.3.4 Timber dunnage, blocks and braces should be checked for the appropriate IPPC mark (see annex 7, section 1.14). Other timber should be disposed of by incineration.
8.3.5 Liner bags and flexitanks are often removed by the supplier; however all will be contaminated and should be disposed of at an appropriate facility.
8.3.6 Plants, plant products, visible pests, animals and other invasive alien species should be disposed of as described in annex 6.
8.4.1 The various types of CTU suffer differing degrees of damage en route. Rail wagons probably do not suffer much handling damage and are only likely to be damaged by poorly secured cargoes. Road vehicles, especially articulated trailers, do suffer from turning and reversing damage as the vehicle is manoeuvred. Freight containers and swap bodies will suffer from the same manoeuvring damage, but may also suffer from impact damage between other freight containers and swap bodies and handling equipment.
8.4.2 Drivers of road vehicles will generally report any manoeuvring damage but if the trailer or freight container has been collected from a terminal, will only be able to report on damages incurred in the delivery phase. Damages incurred earlier in the supply chain may go unreported unless marked on an interchange document.
8.4.3 The consignee will generally be held responsible for any damage incurred, other than those that have been verifiably observed and endorsed by the CTU operator. For unaccompanied CTUs this endorsement should be shown on the interchange document. It is therefore important that any signs of damage, including recent damage, should be identified and reported on arrival.