RIPA 77th Annual Conference
October 24-26, 2018
THE HOUSTONIAN HOTEL, CLUB AND SPA
Over 100 RIPA members and guests convened in Houston October 24-26 to hold the 77th RIPA Annual Conference and Suppliers Exposition. RIPA members were joined for several events and sessions by several dozen members of IPANA who also were convening for their annual conference.
Hershson Award Honoree
Mr. Barry Wingard
The conference kicked off with a festive reception held among the many exhibit spaces set up for the Suppliers Exposition. Over a dozen exhibitors were on hand and several were exhibiting for the first time. It was great to see both newcomers and veteran exhibitors get the chance to interact with customers and share valuable “face time”.
Earlier in the day, a large group of RIPA and IPANA members enjoyed a lively session at “Top Golf” – an event that drew out even the most “rusty” or inexperienced golfers. Based on the enthusiasm expressed by participants, a “Top Golf” event may become a more regular feature of future conferences.
The next day’s session began with the Joint RIPA / IPANA Main Program featuring several excellent speakers covering timely topics.
Leading off the session was keynote speaker Mr. Charles Veniez, President & CEO Mauser Packaging Solutions – Reconditioning. Charles offered a fascinating and insightful view of the industrial packaging business today, especially as regards reconditioning. Mr. Veniez spoke generally about “Circular Economy” activities in Europe and made clear his company’s support for RIPA.
Next up was Mr. John Packard, President of Steel Market Update. John provided a sweeping view of steel markets from both a prospective and historical view. He described how U.S. steel mills in 2015 filed dumping complaints against several countries and how most of those countries imposed “countervailing duties” in 2016. Over the next two years imports dropped. He noted that in 2017, the Trump Administration levied the 25% tariff on steel. In this case, however, Mr. Packard said imports are still coming in and buyers are simply paying the higher prices.
Rounding out the morning speakers was Mr. Mark P. Jones from the James A. Baker III Institute for Public Policy, an institution closely aligned with nearby Rice University. Mark offered a very detailed and, as it turns out, accurate assessment of the mid-term elections. He provided fascinating details on certain races and certain state balloting procedures that likely were new information to most people in the audience. For instance, he described an effort in Texas to eliminate the option to “check all” and vote by one’s party all down the ballot. Without the “check all option, an already lengthy ballot will likely get more frustrating for certain voters.
After a joint RIPA / IPANA luncheon and more of the Suppliers Exposition, RIPA convened for its Annual Membership Meeting. RIPA Chair Brian Evoy welcomed members and thanked the Supplier Members for exhibiting. Brian also recognized new RIPA members and offered honorific remarks for those industry leaders no longer with us.
Next on the agenda was Mr. Jim Curtis, Partner with the law firm Seyfath Shaw in Chicago. Jim’s expertise is in “Environmental Safety and Toxic Torts”. He offered a comprehensive look at OSHA regulations and worker safety issues that often arise in the reconditioning business. Everyone left with a better idea of their OSHA obligations and a better strategy for assessing their needs.
To see several of the complete presentations described here, click HERE.
Closing out the days sessions was an informal roundtable discussion with key staff from DOT PHMSA’s Southwest Field Office in Houston. Chief Investigator Bob Strollo and Investigator Thomas Lynch offered several observations and recommendations on industrial packagings generally and reconditioning in particular. Several RIPA members and staff then posed questions about PHMSA priorities and procedures in the current political climate and in the future. These open discussions occur frequently at RIPA meetings and provide everyone involved a chance to be heard and learn more about enforcement issues.
The evening’s 2018 Morris Hershson Award Ceremony, honoring Mr. Barry Wingard, featured presenters Bill Shocklee and RIPA President Paul Rankin. Much of Barry’s family was on hand to share in the festive proceedings. Even Barry’s colleagues in Ohio appeared by digital video to congratulate Barry and thank him for his exemplary service to the industry.
The next morning RIPA convened its Steel Drum and IBC Product Groups. In the Steel Drum session, members discussed plans for the annual UN qualification testing of a 1A1 design type. Also, members were advised that the ANSI MH2 Standard for Steel Drums was under final review by ANSI. The standard, which was last updated in 2004, sets out dimensional specifications for a number of common steel drum designs and includes an important Glossary of Terms.
In the IBC Product Group session, members were advised that a “Certificate of Equivalency” had been recently renewed by RIPA for its Canadian members. Those that qualify for the certificate can use a DANGER vehicle placard when a shipment of emptied drums includes two or more emptied IBCs. Operators also can provide “user friendly” data on a shipment, such as “14 Class 3 Residue Drums, 14 Class 3 Residue IBCs”. Operations under the terms of the Certificate are limited to certain hazard classes of materials (residues) and are limited to members of RIPA. The Certificate SU 11819 (Renewal 1) will extend to October 31, 2020.
Product Group Co-Chair David Levine then reported on the status of Special Permit 16323 which allows reprocessors to forgo a leak test on brand new bottles provided certain conditions are met. The Special Permit was recently renewed and several RIPA members have recently also renewed their “Party –To” status.
Mr. Levine then reported on the upcoming annual re-testing of certain “cross bottle” IBC designs. A fair number of RIPA members are sponsors of this testing and independently receive test reports from the commercial lab which conducts the tests. Testing of two prominent bottle/cage configurations will begin in November and end in early December.
Both Co-Chairs, Mr. Levine and Mr. Brian Evoy, then led a discussion of IBC residue management. The association continues to work on ways to assist members in safe and effective management of residues in emptied containers
In the Product Group Plenary Session, RIPA General Counsel Rick Schweitzer reported on several regulatory issues concerning trucking and drivers such as Hours of Service. Attendees were advised that federal regulators are proposing to extend the limit on on-duty hours from 12 to 14 for “short haul drivers” (i.e., drivers with less than a100 air-mile radius in a day). There also is a “push” by some industry groups to extend the mileage limit to a 150 air-mile radius. RIPA is on record in previous proceeding in support of an extension of the mileage. The notice and comment period on the hours and mileage questions will extend well into 2019.
RIPA President Paul Rankin provided updates on a RIPA petition with DOT for approval of ultrasonic leakproofness testing and a new, more practical standard for surface adherents on reconditioned steel drums. On the ultrasonic issue, DOT has advised RIPA that the method of testing is set to be proposed and issued for public comment as part of a rulemaking referred to as “Miscellaneous Amendments” to the Hazardous Materials Regulations (HMRs). Prospects for the issuance or proposal of a new surface standard are still under consideration by DOT.
RIPA President Paul Rankin reported that the Canadian General Standards Board (CGSB) is in the final approval stage regarding a new industry standard for reconditioning and remanufacturing small packagings (CGSB-43.126). The CGSB is a part of the Canadian government and works to “bring conformity to the certification of products and services, registration of quality and environmental management systems, and related services. These services are provided in support of economic, regulatory, procurement, health, safety and environmental interests.”
Mr. Rankin then described for members an ongoing effort to gain approval from U.S. DOT to extend the current annual testing of design types for packaging requalification. Although in a formative stage, the matter has been raised formally with DOT and also has the backing of packaging manufactures and their association, IPANA.
Members were reminded of the Nov 16, 2018 deadline to submit to DOT a request to keep their registered “M” or “R” numbers if those numbers are not already tied to a 5-year renewable cycle. RIPA provided all members earlier in the year brief letters that can be put on company letterhead and emailed to DOT for renewal.
RIPA Technical Director, C.L. Pettit, presented the new industry survey for production and other data that has been done biennially since 2000. The newest report covers calendar year 2017. (See full story below.) Among the findings: steel drum reconditioning was essentially unchanged from 2015, down only 1%. Meanwhile, reprocessed IBC production was up about 8% over 2015.
Paul Rankin then previewed the animated video “No More Direct-to-to-Scrap”. The video, along with a companion slide show, was developed by the RIPA Communications Committee chaired by Howard Skolnik. The plan is to present the materials to packaging users and user groups. The goal is to protect safety and the environment by curtailing the premature scrapping of viable, reusable packagings that have not been cleaned and reconditioned.
Mr. Rankin and Mr. Schweitzer then ended the session with an update on discussions with EPA on the agency’s empty container rule. Enforcement officials in EPA Region V have not backed off efforts to stringently regulate the transportation, handling and storage of non-RCRA empty containers that may inadvertently be sent to reconditioners. RIPA is working hard to craft a solution to this problem that would enable reconditioners to return these containers to the original shipper as product.
See some of the major presentations here: