RIPA Quality Assurance Guideline (Draft)

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

2. 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.”

3. 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.

4. 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 e-mail from each mfgr. saying new bottles have been internally inspected & leakproofness tested in accordance with Sec. 178.813, 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.

5. 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.

6. 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 178.813 BY THAT MANUFACTURER.

7. 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.

8. 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.

9. RIPA Quality Assurance Guideline QUESTIONS??

10. Review of IBC Terminology Routine maintenance (49 CFR 180.350) 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

11. Review of IBC Terminology Repaired IBC (49 CFR 180.350) 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/M1234/03 - 11

12. Review of IBC Terminology Remanufactured IBC (49 CFR 180.350) (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..

13. 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

14. Full IBC Mark