U.S. DOT Compliance
U.S. DOT Inspection Checklist 2020
– Every reconditioner and distributor member of RIPA should anticipate being inspected by regulatory authorities – whether from DOT or Transport Canada – on a periodic basis. Members who had previous enforcement experiences with the agencies may assume some repetition of the inspections. This memorandum provides a checklist of things your company can do to help ensure that these regulatory inspections go smoothly.
RIPA Composite IBC Compliance Presentation 2020 (Slide Show)
– This slide show is a companion piece to a recorded RIPA Webinar presentation from September 2020. The recorded Webinar can be found under the Webinars banner on the RIPA home page.
ISDI / RIPA Steel Drum Testing Guidance Manual
– ISDI and RIPA jointly have issued for 2014 an updated guide on steel drum testing. Consult this Guide for tips on conducting the various design qualification tests for 1A1 (liquids), 1A2 (liquids) and 1A2 (solids). The Guide includes many protocols for sample preparation and handling that the regulations simply do not address. Note: These guidelines are not themselves enforceable standards or regulatory requirements; merely guidance from the industry to the industry.
Applying for “M” Numbers; Information on “R” Numbers
– Posted here are instructions on how a hazmat packaging business can register its identity with U.S. DOT and receive a registered symbol – an “M” number – for use in marking UN hazmat packagings as required by the Hazardous Materials Regulations (HMR). In past years, registered reconditioners received an “R” number – and all those “R” numbers remain valid unless individually canceled. Currently and for the future, DOT only issues “M” numbers for everyone.
– Provided here is an illustration, with explanatory notes, of a UN mark for a reconditioned, tight-head, 55-gallon steel drum. The UN mark describes the performance rating of the packaging and, thus, the level of hazard for which it can be used in transporting hazardous materials.
Marking Remanufactured Steel Drums
– For remanufactured metal drums, if there is no change to the packaging type and no replacement or removal of integral structural components, the required markings need not be permanent ( e.g., embossed). Every other remanufactured drum must bear the marks required in paragraphs (a)(1) through (a)(6) of this section in permanent
form (e.g., embossed) on the top head or side.
Sample UN Mark for a Composite IBC
An illustrative representation of a proper UN mark for a composite IBC intended to contain regulated liquids.
Three Types of IBC Reprocessing
– The overall regulatory term “IBC reprocesing” consists of three other regulatory terms: IBC remanufacturing, IBC repair (which includes “cross bottling”), and IBC routine maintenance.
IBC Empty Agreement Between Emptier and Reconditioner
– This document provides a way to address the return of “heavy” IBCs that are rejected under your IBC acceptance policy. It establishes a contractual agreement between your company and the emptier. This agreement not only can provide a legal mechanism by which to manage the costs of returning unaccepted units, but it also can be helpful in explaining to emptiers why it is so important that IBCs be emptied thoroughly.
RIPA Model Closure Notification
– These methods of closure must be provided to ensure that the customer closes containers in the same manner as when they were initially tested and qualified for hazardous materials (aka UN dangerous goods). They can be sent electronically in tandem with shipments of continents (for instance, emailed or presented on a data stick). However, the instructions cannot be simply posted to the company’s website under the assumption that the customer will retrieve them there.
Online “Portal” Access to Company Safety Profiles
– The FMCSA “Portal” provides single sign-on access to various safety databases using a single password and user ID. Over time, the FMCSA Portal (https://portal.fmcsa.dot.gov) will provide access to all existing FMCSA systems. The FMCSA Portal gives companies a single location to view their data. Real-time access to data is improved. Carriers can generate their own safety profiles from within the FMCSA Portal at no cost and designate third-party entities as having online access to their safety and operational data.
U.S. EPA Compliance
Empty Container Certification Form
– Provided here is a form for certifying containers (e.g., drums and IBCs) as empty by U.S. EPA criteria. (Thus, the containers are not a hazardous waste). The form also certifies that the containers are prepared for shipment according to U.S. DOT regulations. Reconditioners should request and maintain signed and dated certifications as part of a recommended Code of Operating Practices.
Glossary of Terms for IBCs in Agrochemical Service
– A glossary of terms provided here is helpful in discussing the use of composite IBCs in agrochemical service. Agrochemical products and packagings are principally regulated by U.S. EPA. This glossary helps reconcile terms and “bridge the gap” with the terms and provisi0ns of DOT’s hazmat regulations.
U.S. OSHA Compliance
U.S. OSHA HazCom GHS Training – RIPA Member Training Module
– Click on the heading above for RIPA’s Member Only Training Module for OSHA’s HazCom GHS Regulations. This training was conducted for members at a relatively recent RIPA conference. Members can expect this training to be updated to include instruction on “combustible dust”. In early 2021, U.S. OSHA is proposing to bring the dust issue under its rules for Hazard Communication. RIPA will update this module and provide it here and directly to members. At that time, RIPA will recommend that employees be trained with the updated module.
– And go HERE for this training tool presented in Spanish.
– RIPA members must train employees in forklift safety and operations, and maintain on file a certificate of training such as that here.
Hazard Communication Program for OSHA Compliance
– In order to comply with OSHA’s regulations, the following written Hazard Communication Program has been established for RIPA members . All work units of the company are included within this program. The written program must be available on-site and available for review by any interested employee. All employees must be instructed in the details of the plan.
– Employers post their OSHA Illness and Injury Logs (OSHA Form 300) in a conspicuous work area by February 1 of each year and leave it posted until at least May1. The form presents summary data on recordable work-related illnesses and injuries for the previous calendar year. The form must be posted even if there were no reported incidents (enter “zeros” in the appropriate rows.)
Other Agencies or Organizations
NAFTA “Certificate of Origin” – RIPA Recommended Entries
– Presented here are RIPA’s recommended entries describing industrial packagings when asked to provide a NAFTA “Certificate of Origin”.