4 Conduct of inspections

  4.1 CTU inspection preparation, assessment and opening procedures should be established.

• .1 Contact the facility and/or carrier with custody of CTUs to be inspected.

• .2 Establish an inspection team communications plan. Reliable voice communications that take into account Administration and facility safety procedures.

• .3 Identify CTUs for inspection and inform facility and/or carrier. A risk assessment methodology should be used to select CTUs posing the highest threat and consequence for non-compliance with regulations.

• .4 Identify the contents of CTUs selected for inspection by obtaining and reviewing the dangerous goods transportation documents. A bill of lading or other descriptive document should be obtained for CTUs with general cargoes.

• 5 Assemble personal protective equipment and needed inspection equipment:

  • .1 Personnel should wear hard hats, safety glasses, safety shoes, high visibility or reflective vests, and gloves, and properly calibrated hazardous condition sensing devices. As appropriate, inspectors should consider the use of additional personal protective equipment such as chemical protective clothing, air purifying respirators or emergency escape breathing apparatus to prevent inadvertent exposure to hazardous materials within the CTU.

  • .2 Personnel should assemble a container inspection kit containing all required tools, references (including regulatory provisions for quick reference), and paperwork.

• .6 A safety brief should be conducted prior to the first inspection. The safety brief should cover the following:

  • .1 operational risk assessment to determine if present and predicted conditions, such as weather and personnel readiness, allow for a safe operation;

  • .2 assignment of roles and responsibilities for all members of the inspection team. At least one member should be assigned safety duties to ensure that proper procedures are followed and to implement protocols in emergency situations;

  • .3 a review of personal protective equipment and its use;

  • .4 a review of safe work practices;

  • .5 a discussion of emergency egress situations, muster location, and other emergency protocols;

  • .6 known hazards that exist at the location where the inspection is to occur; and

  • .7 accidental exposure procedures.

• .7 Stage CTUs for inspection in a manner that will maximize natural ventilation and provide safety from existing traffic patterns, CTU handling operations and concentrations of CTUs scheduled for movement. Staging areas should have adequate lighting, and be away from water runoff drains and electrical outlets. As an additional precaution, when a CTU is on the chassis, place cones or park a vehicle, if available, immediately in front of the CTU to prevent a vehicle from connecting up to the chassis during the inspection.

• .8 Establish a safety watch and review safety procedures before starting the inspection:

  • .1 discuss inspection activity with the safety watch;

  • .2 once the potential hazards of the commodities in the selected CTUs are known, these should be reviewed with the team;

  • .3 assess the staging area and discuss any unique aspects that may pose potential safety hazards. This should include identification of the safe egress routes; and

  • .4 the final step before beginning the inspections should be to conduct a second operational risk assessment to determine if conditions have changed from the previous assessment. When appropriate, reassess safety procedures to reduce risk and, if unsure, seek guidance from a supervisor.

• .9 Conduct an external assessment, to include a complete walk-around, of selected CTUs to ensure safety of inspection personnel. Remain alert for indications of potential internal hazards such as cargo leaks or severe CTU damage. If any leaks are discovered, stop the inspection and initiate established response procedures.

• .10 For closed CTUs, it is highly encouraged to perform atmospheric monitoring before and continuously during the inspection cycle:

  • .1 Inspectors should not enter a CTU if tests indicate that the atmosphere in it is potentially hazardous until it is determined that it is safe to do so.

  • .2 When an inspector enters a CTU atmospheric measurements should be taken above the inspector's head near the top of the container, at head or breathing zone level, at waist level, and near the bottom of the container. After adequate ventilation, the oxygen level at the container door-end should equal ambient levels. Entry into the enclosed space of the container should only occur when the meter readings match those obtained for the ambient atmosphere. Under no circumstances should a tailgate inspection occur when door-end readings differ from normal ambient atmospheric readings or if combustible gas readings indicate a hazardous condition.

• .11 The use of a safety strap is encouraged. Exercise caution when opening closed freight containers. The safety strap will be secured to minimize the free movement of the right side door when it is first opened by crossing the vertical seam between both doors. This can reduce the risk of personal injury from shifted cargo. The safety strap, and other associated components such as ratcheted cargo tie downs, should have a minimum breaking strength of 1,800 kilograms. If the safety strap is made of synthetic material, it should not be elasticized, such as that found in shock cords.

• .12 For CTUs, an assessment of the doorend should be performed to identify shifted cargo. With the safety strap in place, carefully crack open the right door enough to determine if there is any danger from spilled or shifted cargo. A second inspector can do this by looking into the container standing to the left of the left door and at a safe distance:

  • .1 If cargo has shifted and poses a safety threat, notify the facility immediately so that it can be opened safely prior to continuing the inspection.

• .13 Ventilate the CTU. For CTUs other than those that have been fumigated or contain toxic materials, loosen the safety strap and ventilate the CTU by fully opening the doors for natural ventilation:

  • .1 To maximize natural ventilation, open the right and left doors a minimum of 180 degrees so that they are perpendicular to the CTU sides, and ventilate the container for a minimum prescribed time.

  • .2 For CTUs that have been fumigated, ensure that at least 24 hours have elapsed since the time of fumigation before opening the doors. Upon opening the doors, the fumigant and residues must be completely ventilated using natural ventilation or mechanical means prior to entry.

  • .3 Inspectors should be aware that residual hazards may remain in ventilated CTUs (see paragraph 3.1.8).

• .14 Conducting a tailgate inspection. The number of persons entering the CTU to conduct tailgate inspections should be limited to the minimum necessary. Exercise caution when trying to examine cargo forward of the doors; climbing on packages or dunnage is dangerous and should be avoided.

  4.2 Procedures for internal inspections of a closed CTU should be established.

• .1 Normally, inspectors should not have a need to proceed beyond a door end inspection to complete their duties. An inspector should not enter an enclosed space within a CTU, if he or she does not feel it is safe. However, in situations that call for entry beyond the door end, the following steps should be adhered to:

  • .1 Determine the risk of conducting an internal inspection and assess access and egress routes. Examine the interior of the CTU at the door end and determine if the enclosed space has limited access or egress. If the nature of the cargo or loading procedure does not leave a direct or unobstructed egress path, the inspector should consider the CTU a confined space. If the inspector needs access to a cargo in a potential confined space to verify compliance, then the inspector should take appropriate measures to require de-vanning of the cargo to allow unrestricted access to it or utilize specialized remote viewing equipment. Never climb on packages containing dangerous goods, unless such an inspection is necessary and appropriate safety precautions have been taken.

  • .2 Ensure the CTU has been properly ventilated (see paragraphs 3.1.8 and 4.1.13.3).

  • .3 Continue to evaluate the interior of the space throughout the inspection. If at any time there is an obvious change to the interior environment or the inspector feels unsafe, the inspector should immediately egress from the container and re-evaluate the situation.

  • .4 Continuously monitor the internal atmosphere using sensing devices.

  • .5 Maintain readiness for emergency egress. Each inspector should be ready to immediately exit the CTU when changes in sensing devices indicate the presence of atmospheric hazards or if any of the symptoms identified in paragraph 3.2.1 are detected. In the event that the inspector becomes incapacitated and rescue requires entry to be made into the CTU, emergency response personnel with the proper training and equipment should be used to effect the rescue.

  4.3 Establish procedures for resealing a CTU. Procedures should be established for the replacement, recording and information sharing with facilities and carriers of seals that have been removed in the conduct of a container inspection. Such procedures shall conform with applicable national legislation and should take into account MSC-FAL.1/Circ.1 on Securing and Facilitating Global Trade^footnote.