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Gases in import containers

Legislation

Gases in containers and vapours in import containers can pose a serious threat to anyone that inspects or unloads cargo from containers. Article 3.5g of the Working Conditions Decree requires employers to test import containers for the presence of hazardous substances, before anyone opens or enters the container. If the gas concentration exceeds the threshold limit value the container has to be ventilated. In 2012 the regulations in relation to gases in containers were implemented in the working conditions catalogue Gases in containers in Sea Containers.

Risks

Workers opening and unloading containers need to recognise that it's very dangerous to open a container if the container is not previously tested for the presence of toxic vapours or gases, caused by fumigants or production chemicals.

These chemicals can have acute or chronic health effects on humans, whether or not they have been deliberately introduced to the containers. According to the working conditions regulations companies have to carry out a risk assessment to determine which substances are involved.

Measurements in the Netherlands

The problems with hazardous gases in cargo containers is now widely publicized and the requirement for testing is growing as employers fulfil their responsibility to protect the health and welfare of staff.

However, the traditional testing methods are laborious, time-consuming and limited. In the Netherlands only 16 parameters are tested by most measurement companies. These parameters are listed on the Information Card 7, which is incorrectly considered to be the list of parameters that have to be measured. However the Information Card 7 is only a list of some common found substances in containers. On a large scale, these substances are measured indirectly in reused Tedlar bags, despite the fact that this method is unsafe and not suitable. In this respect it is not possible to carry out reliable formaldehyde measurements in a Tedlar Bag, and frequently the measurements are conducted up to hours after sampling. Gas concentrations can increase rapidly in a container. For safety reasons it is very important to conduct extensive and real-time measurements.

Rejections because of high PID/VOC-readings?

PID's are used to monitor the level of Volatile Organic Compounds (VOC's) in air. PID-measurement is not a required parameter in relation to container measurements. For that reason it is not possible to reject containers only for high PID-readings. The cause of the high readings has to be investigated. Despite this containers are systematically rejected on a large scale for high PID-readings. Until one year ago containers were rejected for PID-readings > 100 ppm. Currently containers are being rejected for PID-readings > 50 ppm!! This will lead to unneccessary degassing and remeasurement costs.

Employers have to realise that they have to carry out research concerning the risks of opening and entering containers, even if they receive a non-fumigation declaration from the overseas supplier. A non-fumigation declaration does not exclude the presence of vapours caused by production chemicals.

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