- Tim O'Bryan
It was certainly great to see everyone at the 81st RIPA Annual Conference in San Diego, California. It was the first full scale, in-person Annual Conference in three years! There was a lot of enthusiasm for all that was taking place. I would like to thank our friends at IPANA for co-locating their conference with RIPA’s conference once again. There is much to be gained by having these additional contacts and sharing in business news, technical matters and regulatory developments. The overlapping events combine to add to the proceedings another layer of valuable content and networking opportunities.
EPA Region V VOC Data Collection and Testing Update
Two years ago, representatives from EPA Region 5’s enforcement team began visiting reconditioning facilities in the upper Midwest to determine if emissions of volatile organic compounds (VOC) from washed steel drums were being properly regulated. EPA Region 5 is comprised of the following states: Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin.
Following initial visits, the Agency decided site-specific data was needed to determine if regulatory actions would be triggered for reconditioners.
RIPA initiated discussions with Region 5 officials and proposed an alternative approach to site specific emissions testing. We suggested that RIPA, with appropriate oversight by EPA, would coordinate a data collection effort, followed by several tests at reconditioning facilities, to document a range of “emission factors” that could be used by the Agency and industry to estimate actual and potential emissions at any facility.
EPA Officials Seek Dialogue with RIPA on Empty Container Management Issues
After issuing a highly negative report on the container reconditioning industry in September, “Drum Reconditioner Damage Case Report,” three representatives of the U.S. Environmental Protection Agency agreed to join RIPA at its Annual Conference in San Diego to discuss their views on the industry’s compliance profile and matters related to handling empty containers.
Jessica Young, Chief, Recycling and Generator Branch, EPA Office of Resource Conservation and Recovery (ORCR) opened her presentation by offering something of an olive branch to association members by acknowledging the important role the industry plays in the life cycle of industrial containers. “Drum reconditioners are an important part of the drum management cycle that begins with the companies that empty the drums, continues with the refurbishment and reuse of the drums, and ends with the end-of-life management of the used drums, generally as scrap material,” she said.
RIPA’s Upcoming Board Elections 2023
RIPA will soon be administering its annual election of members to the Board of Directors. Each year approximately one-third of the 15 seats are up for election.
Nominations will be the first step. A Nominations Ballot will be sent to members in the coming days.
Current members of the Board can be re-elected unless they are just completing a second and consecutive 3-year term. In that case, they would need to wait a year to be eligible again.
Please participate in the nominations and voting process. Contact RIPA with any questions or concerns.
U.S. EPA Conducts Further Research into “PFAS” Chemicals
U.S. EPA has conducted further research into the family of chemicals collectively called “PFAS” chemicals – also known as “forever chemicals” for their resistance to breaking down in the environment.
Thus far, EPA’s research into these chemicals has focused on HDPE packagings that have been “fluorinated” to enhance impermeability. The tested packagings have been used to hold pesticides and related products. EPA has shown that fluorine bonds very strongly with carbon atoms in the HDPE walls. However, the new PFAS chemicals formed have been found to leach into the product and then get disbursed into the environment when the products are used.
To date, only smaller packagings such as 2½- and 5-gallon jugs have been examined. Also, little data exists yet to quantify the risks to the environment or human health. Nevertheless, the agency is concerned about the properties of PFAS chemicals and intends to continue its research and data analysis. At one point, EPA said that alternatives to HDPE packagings may include steel drums.
Reportedly, the fluorination of packagings is typically done by third-party vendors using largely proprietary methods.
RIPA will continue to report on PFAS as developments occur.
RIPA Welcomes New Members
New Reconditioner Members
Container Authority, LLC
Formerly Lexington Container Co.
120 Morgan Soaper Drive
Harrodsburg, KY 40330
Mr. Basilio Giangeruso
TricorBraun Industrial Services, LLC
Formerly MBC, Inc.
5260 W. Old Bingham Highway
West Jordan, UT 84081
New Supplier Members
290 E. Fullerton Ave.
Carol Stream, IL 60188
Mr. Sean Smith, Area Sales Manager
Mr. Jason Colegrove, Dir' Sales & Marketing - Midwest
Mr. John Kiefer, Plant Manager
2790 Canfields Lane
P.O. Box 188
Montoursville, PA 17754
Myral Bonnell, President
Paul Gailey, National Mgr Sales
RIPA IN SAN DIEGO
DOT Considering an Increase in the Annual Hazmat Registration Fee
U.S. DOT PHMSA is soliciting input on potential adjustments to the statutorily mandated Hazardous Materials Registration and Fee Assessment program. Actions such as the potential adjustment of fees or the addition of other entities among those required to register may be necessary to fund PHMSA's national emergency preparedness grant programs at the newly authorized level in accordance with the Infrastructure Investment and Jobs Act of 2021. To fully engage with stakeholders, DOT solicits comments and input on questions related to the scope of the registration and fee assessment program. Any comments, data, and information received will be used to evaluate and draft proposed amendments. RIPA is considering submitting comments.
Significantly, entities deemed to be Small Businesses pay a substantially lower fee. The small business definition for reconditioning is up to $8 million in annual revenue.
RIPA IN SAN DIEGO
Save the Dates: 2023 ICCR International Conference
The next ICCR International Conference on Industrial Packaging will take place 26 – 30 September 2023 in beautiful Ghent, Belgium. After being forced to postpone the Conference twice due to COVID-19 travel restrictions, this event promises to be one of the most successful international conferences we’ve seen in many years.
Ghent is a port city in northwest Belgium, at the confluence of the Leie and Scheldt rivers. During the Middle Ages it was a prominent city-state, and today it’s known as a university town and cultural hub. The City is one of the most beautiful in Europe and easily walkable. You don’t want to miss this conference!
ICCR Completes Phase 1 of Industrial Packaging Carbon Project
In December 2021, the ICCR Board of Directors embarked on a project aimed at creating a global industrial packaging carbon calculator for use by customers of ICCR members. The goals of the ICCR project were:
(a) Create a carbon calculator (“tool”) that can be utilized by users of industrial packagings to easily calculate carbon emissions saved using reconditioned packagings rather than new packagings of the same type; and
(b) Improve the image of the global reconditioning industry to its customers by demonstrating that reconditioned packaging significantly reduces carbon emissions when used in lieu of new packagings of the same type.
The ICCR Board is considering how best to proceed with the Carbon Project. E & Y made it clear that data used to support a carbon calculator must be of recent origin and be limited to specific geographic regions, such as North America, Japan or Europe. Corporations are unlikely to report carbon savings without such data.