This section of the RIPA website presents RIPA’s advocacy pieces – comments and testimony, built on consensus among RIPA’s members, offered in response to regulatory and legislative proposals, or perhaps proposed standards from non-governmental bodies.
U.S. DOT Activities
PHMSA Seeks Input on “Fitness” for Special Permits and Approvals (February 29, 2012)
- RIPA comments on problems with the PHMSA Special Permits and Approvals process; offers suggested changes to improve the system.
Proposed Hours-of-Service Changes (March 4, 2011)
- RIPA advises against rule changes that would reduce flexibility for reconditioners and other businesses to plan optimal routes for their drivers.
Industry Letter to UN on “Crossbottling” (April 16, 2008)
- An international industry group for IBCs spells out its position on “replacement bottles” and requirements that they meet an “original manufacturer’s specifications”.
DOT Package Inspection Proposals (December 1, 2008)
- RIPA states its position regarding highway enforcement personnel and their authority to open hazmat packages and close packages already opened.
DOT Miscellaneous Proposals HM 231 (November 27, 2006)
- RIPA opposes a DOT proposal to extend minimum thickness requirements to re-manufacturing, in addition to reuse. Also, RIPA suggests extending IBCs’ definition down to 119 gallons (so that it has non-bulk status, as with drums, thus facilitating reprocessing and reuse).
U.S. EPA Activities
EPA Drum Furnace Proposal on Air Emissions (CISWI) – Follow-up Comments (February 16, 2012)
- Follow-up comments to EPA regarding the definition of “burn-off oven.”
EPA Drum Furnace Proposal to Regulate Air Emissions “CISWI” (August 23, 2010)
- RIPA questions EPA’s proposal to regulate drum furnace air emissions, and for categorizing them as “burn off ovens”.
RIPA Advises EPA on Emptied Drums ( August 6, 2010)
- Emptied drums that meet EPA’s own standards for “empty” are not to be construed as a waste material.
Proposed “Control Technique Guidelines” (August 13, 2008)
- RIPA advises EPA on appropriate levels for VOCs (lb/gallon) in surface coatings for drum interiors and exteriors.
EPA Proposed Definition Solid Waste (August 6, 2010)
- RIPA advises EPA on the status of drum reconditionnig as equipment cleaning and maintenance rather than waste management of “sham recycling”.
EPA Proposal Regarding Paint Booths and Air Emissions (October 16, 2007)
- RIPA explains for EPA paint spray-booth configuration, filter efficiency, and employee training and certification.
EPA Proposed Standards for Water Discharges (June 12, 2001)
- RIPA helps convince EPA that federal pretreatment standards for wastewater from reconditioning are not necessary.
U.S. OSHA Activities
Postings to come.
Other Agencies or Organizations
Postings to come.