“As a general matter, RIPA believes incident data should be the primary initiator of PHMSA packaging inspection cases, not – as is generally the case today – random visits to companies or the result of tests conducted by LOGSA / Tobyhanna.  Greater reliance on incident data would help the agency prioritize investigations and optimize the use of scarce resources and personnel.

Also, RIPA believes that incident reports should more accurately describe the failed packaging. ……… To this end, RIPA strongly recommends the incident report form be revised to include a line-item for material thickness, where applicable.”

For a complete copy of RIPA’ s comments  CLICK  HERE.