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Compliance · October 29, 2024

Why we photograph every plate before it ships

It adds about eight seconds per container and it has paid for itself more times than any other habit in the building.

Why we photograph every plate before it ships
Fig. 01A small procedural habit that resolves disputes, rescues fleets from recertification deadlines and occasionally proves a container was legal when it left. What the photograph does and does not do.

Short answer

Photographing the design-type plate on every outbound container creates a dated record of what was legally on that unit when it left. It does not replace the marking, but it settles disputes and lets a customer audit a fleet without touching it.
Published
October 29, 2024
Reading
5 min
Desk
Certification Bench
Topic
Compliance
Form 01 · Spec request

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The marking plate is the container's legal identity. It records the design type, the packing groups approved, the month and year of manufacture and the approval reference. Everything about a container's regulated future depends on it being legible.

It is also small, riveted to a frame that gets knocked about, and sitting in the exact spot somebody eventually aims a pressure washer.

What the photograph gives us

  1. 01A dated record of what the marking said when the container left our yard, which resolves the most common dispute in this trade in about a minute.
  2. 02A way to answer a customer's compliance question without anyone walking a yard. Send us the serial, we send the plate.
  3. 03A dataset. We can tell a fleet customer which of their containers are approaching a five-year periodic without touching one of them.
  4. 04A check on our own process. If a plate is illegible in the photograph, the container should never have been graded as certifiable.

What it does not do

A photograph is not a substitute for the marking. If the plate on the container becomes unreadable, the container is out of regulated service regardless of what image exists in our records. The regulation is about the marking on the unit, not about evidence that a marking once existed.

It is also not a test record. A photograph proves what the design type was; only a leakproofness test and inspection establish that the container is currently fit for that service.

How we store them

Against the serial number, in the unit record that already carries the prior contents, the wash cycle, the pressure test result and any repairs. That record travels with the container and is reissued on request, because the inspector who eventually asks for it will ask the customer, not us.

The dispute this most often settles

A customer receives a load, one container has an unreadable plate, and the question is whether it arrived that way. Without a record, this is unresolvable and somebody eats the cost on goodwill.

With a record it takes a minute. Twice in the last two years the photograph showed the plate was legible on dispatch, and in both cases the customer found a repainting job in their own yard. Three times it showed we had shipped a unit we should not have, and we replaced it without argument. That second number is the reason the habit is worth having — a process that only ever proves you right is not a process, it is a story.

What a good plate photograph contains

Not every photograph is useful, and a bad one is worse than none because it creates a false sense of having a record.

  1. 01Square on to the plate, filling most of the frame. Angled shots lose characters to glare.
  2. 02Even light. Direct sun on a stamped plate produces shadows that read as different characters.
  3. 03The complete marking, including the gross mass and stacking figures below the design-type code.
  4. 04Any separate test-date stamp, which is often on a different part of the frame.
  5. 05Enough surrounding frame to confirm which container it came from if the serial is elsewhere.

We take two: one of the plate and one wider shot showing the plate in position on the cage. The second one has settled more disputes than the first.

Building a certification schedule from photographs

For a fleet, the plate photographs become a schedule. Transcribe the manufacture date, add the periodic interval, and you have a list of which containers come due in which quarter.

The value is in batching. Testing fifteen containers on one visit costs a fraction of testing one container fifteen times, and without a schedule the second pattern is what happens — testing becomes reactive, triggered by somebody noticing a date on a container about to ship.

What a fleet schedule looks like
Manufacture dateUnits5-year periodic dueAction
2021 Q3182026 Q3Batch test this quarter
2022 Q1242027 Q1Schedule
2022 Q4112027 Q4Schedule
2019 Q26OverdueTest or move to non-regulated service
Illegible3N/ANon-regulated service only

The habit is transferable

Nothing about this is specific to us. Any plant receiving containers can photograph plates on arrival, and the effort is about eight seconds per unit against a payoff that arrives the first time an auditor asks a question about certification status.

It also gives you leverage with suppliers. A customer who can point to a photograph showing a container arrived with an illegible plate is having a very different conversation from one who is relying on memory.

Questions about records

How long do you keep them? Indefinitely for containers we have processed. Storage is trivial and the requests arrive years later, usually from a customer whose own records went missing in a system migration.

Can I get the photographs for containers I bought? Yes, against the serial numbers. That is the entire point of keying records on the unit rather than on the order.

Do you photograph containers you buy as well as sell? Yes, at intake. It is what lets us tell a seller which of their units were certifiable and which were not, which occasionally changes what they do with the next batch.

Is a photograph acceptable to an inspector? As supporting evidence, generally. As a substitute for the marking on the container, no. The regulation is about what is on the unit.

Filed underdocumentationun markingprocessrecords

Written by the Certification Bench at IBC Recycling Services, Cleveland, OH. Published October 29, 2024. Figures quoted are working estimates from our own operation unless stated otherwise; verify anything regulatory against the current rules that apply to you.

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