Click    HERE    for a copy of RIPA’s petition to US DOT seeking improvements in the agency’s regulatory description of steel drum surfaces after reconditioning.  The agency’s requirement is that “any” external coatings or adherents be removed and the surface be rendered to “base material of construction”.   RIPA points out that this requirement is at odds with historical practice and regulatory intent.  It  also can lead to excessive surface treatment (e.g., shot blasting, brushing) that may be counterproductive.

RIPA will be meeting with agency officials to help move the process forward.  Rulemaking can take time as the agency must prepare and publish an official proposal, and then open up the process to public review and comment.