RIPA Quality Assurance Guideline (Draft) RIPA Technical Conference Henry Hotel Dearborn, MI April 30, 2012

RIPA Quality Assurance Guideline  RIPA makes available a draft QA guideline to all members.  DOT does not mandate reconditioners develop & maintain a QA manual.  RIPA’s Code of Practice calls for a “documented QC program.”

RIPA Quality Assurance Guideline  DOT wanted to require RIPA members to perform a leakproofness test on all newly purchased IBC bottles.  RIPA Counsel L. Bierlein fought this proposal (with Board backing) and won.  Reconditioners repairing IBCs do not have to leakproofness test new bottles.

RIPA Quality Assurance Guideline  Outcome: The World is Never Perfect  PHMSA hates to lose, expect to see them at your door.  You should have:  letter or from each mfgr. saying new bottles have been internally inspected & leakproofness tested in accordance with Sec , and sealed before being shipped to you;  written QA procedures defining your employees’ responsibility to do a six-sided visual inspection of each incoming new bottle to make sure no damage occurred during transit from the manufacturer.

RIPA Quality Assurance Guideline Employers must –  Update your employee training program to include reference to incoming IBC inspection, training and letters.  We also recommend that you create and maintain a QA guideline with these new elements.  The RIPA IBC Guideline has been updated.

RIPA Quality Assurance Guideline Revisions to RIPA IBC QA Guideline  Section 5.2 (RPM)  MEMBERS ARE REQUIRED TO HAVE IN THEIR FILES A LETTER FROM EACH MANUFACTURER FROM WHOM NEW IBC INNER RECEPTACLES ARE PURCHASED STATING THAT THE INNER RECEPTACLES HAVE BEEN HAVE BEEN INTERNALLY INSPECTED & LEAKPROOFNESS TESTED IN ACCORDANCE WITH 49 CFR BY THAT MANUFACTURER.

RIPA Quality Assurance Guideline Revisions to RIPA IBC QA Guideline  Section 6.0: Inspection Procedures  Visual inspection of each incoming IBC bottle on six sides to determine transportation damage, if any.

RIPA Quality Assurance Guideline Revisions to RIPA IBC QA Guideline  Section 12.0 – Recordkeeping  HazMat employee training records must included mention of function specific training for incoming IBC inspection.

RIPA Quality Assurance Guideline QUESTIONS??

Review of IBC Terminology Routine maintenance (49 CFR ) A routinely maintained IBC is one that is:  cleaned, with closures reinstalled or replaced in conformance with the original manufacturer’s specifications.  Or, which has its structural equipment restored. Structural equipment is handles, bars. Mark:USA/M1234

Review of IBC Terminology Repaired IBC (49 CFR ) A metal, rigid plastic or composite IBC that is restored so as to conform to the design type and is able to withstand the design type tests. IMPORTANT: The inner receptacle of a repaired IBC may be replaced [only] with another inner receptacle of the same design from the original manufacturer. USA/M1234/

Review of IBC Terminology Remanufactured IBC (49 CFR ) (This process is commonly called “cross-bottling.”)  A metal, rigid plastic or composite IBC that is:  produced as a UN type from a non-UN type,  converted from one UN design type to another UN design type, or  Has an inner receptacle produced by one manufacturer that is placed into a frame produced by another manufacturer (or vice versa), i.e. cross bottling..

IBC Bottle Marking Bottle Marking  31HA1/M4567/03-11/USA  IBC design code  Name or symbol of manufacturer  Date of manufacture  County authorizing mark PROBLEM: Mark on bottle not always in same place

Full IBC Mark