Your staff recently received an increased number of questions about transportation of IM and UN tank containers. We understand that some of this increased activity is in response to tank container displacement on the East Coast from Hurricane Sandy.


In response to one question, you are allowed to remove markings required in the United States that are not required in other countries after making a delivery of the container to its port of shipping.  Ensure that the UN identification numbers remain on the container.


We also have learned that unlike with cargo tanks, there are minimum and maximum loading regulations for IM or UN portable tank containers.  Such tanks or compartment with a volume of 1,980 gallons or more may not be loaded to more than 20 percent and less than 80 percent by volume.  (See 49CFR172.33 (f)(5).


NTTC was pleased to take part in panel presentations to an Intermodal Tank Container Association meeting in Houston in October along with Lori Pavlish of Dow Chemical.  Several NTTC members attended that event. Ms. Pavlish told attendees that Dow looks for commitment to safety from top executives of transportation service providers.  “If you are operating a safe business, everything else will follow. It must start with the leader,” she said.  “Let us help you solve your problems, especially if we are part of the problem.  We want to know about problems before they occur, not after.”  She said that Dow uses www.sqas.org procedures for carrier and tank cleaning audits.


At the same event, Ron Beeson of Lubrizol Corporation painted a fairly optimistic future for chemical growth. While the US chemical industry is healthy, there are concerns for the global market.  Some plant expansion is anticipated and more might follow if US manufacturers can take advantage of natural gas prices.  He does expect both truck and rail growth in 2013.  He said the future expansion of the Panama Canal should benefit Houston and the Gulf Coast if the proper investment in infrastructure is made.  He added that failure to address truck congestion traffic at the Port of Houston could cause shippers to look at water options rather than land bridges to the West Coast.  Beeson said that shippers do understand that there is a shortage of truck drivers to serve the chemical industry and that driver wages will have to go up to encourage younger people to consider truck driving as a career.


For our part, NTTC focused on how CSA will impact shippers and the importance of attracting and retaining tank truck drivers.  We were pleased that questions and conversations with audience went on long after our presentation.