See HERE RIPA’s official comments to DOT / PHMSA in response to the agency’s public forum in January 2014 where several proposed and ongoing research and development (RnD)  projects were discussed.  RIPA takes strong exception to  several of the proposed projects, particularly those that involve package testing.  In particular, RIPA strenuously opposes any suggestion that PHMSA should consider an additional production test, or any test, for reuse, reconditioning and remanufacturing.