RIPA Technical Meeting Grand Rapids, MI
The Pipeline and Hazardous Materials Safety Administration's (PHMSA) strategic framework emphasizes innovation and safety in transportation of energy and hazardous materials. Goals include cultivating excellence, building trust, and pursuing operational excellence. Initiatives such as IBC repair testing relief, drum reconditioning petition, and R&D packaging studies aim to enhance safety and performance in hazardous materials transportation. The Packaging Safety Program ensures safe handling and usage of hazardous materials packaging. PHMSA's vision is to be the most innovative transportation safety organization globally, protecting people and the environment.
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RIPA Technical Meeting Grand Rapids, MI Rick Raksnis Director, Field Services PHMSA
PHMSA2021Strategic Framework PHMSA: VISION THEMOSTINNOVATIVE TRANSPORTATIONSAFETYORGANIZATIONINTHEWORLD PROTECTPEOPLEANDTHEENVIRONMENTBYADVANCINGTHESAFETRANSPORTATIONOF ENERGYANDOTHERHAZARDOUSMATERIALSTHATAREESSENTIALTOOURDAILYLIVES MISSION Promote continuous improvement in safety performance Invest in safety innovations and partnerships Build greater public and stakeholder trust GOALS Cultivate organizational excellence and safety culture Pursue excellence in our operations TRUST HONESTY RESPECT INTEGRITY VALUING PEOPLE EFFECTIVE COMMUNICATION VALUES 2
DOT-SP 16323 - IBC REPAIR TESTING RELIEF Issued: 5/20/15 HMR, SECTION 180.352(d)(1)(ii), REQUIRES THAT COMPOSITE IBCS SUBJECTED TO REPAIR MUST BE LEAK TESTED AND VISUALLY INSPECTION (INTERNAL AND EXTERNAL) AT THE TIME OF REPAIR HOLDERS ARE EXCEPTED FROM LEAK TEST REQUIREMENT FOR BOTTLES TESTED PRIOR TO REPAIR (PRIMARILY NEW BOTTLES) SP SECTION 7.B. REQUIRES VISUAL INSPECTION AT TIME OF REPAIR SP MUST BE MAINTAINED AT REPAIR FACILITY AND DISTRIBUTORS SP REQUIRES EMPLOYEE TRAINING ON TERMS/CONDITIONS PHMSA WILL PROVIDE OVERSIGHT ON ALL SP TERMS/CONDITIONS
RIPA Petition Drum Recondition Engineering & Program Management staff recommended to accept petition formal acceptance letter is being prepared by Standards Group (PHH-10) appropriate rulemaking vehicle has not yet been determined
Planned R&D Packaging Initiatives: Tape study To determine if changes in plastic tape specifications for closure on UN-rated fiberboard boxes will negatively affect performance. This will help us assess if maintenance of specifications after qualification testing is important. The issue of changes in tape specifications has been a recent topic in industry. Status: Undergoing re-evaluation to determine an adequate scope. Bottle study - To determine whether plastic inner bottles should be considered fragile as replacements for glass in UN4GV fiberboard packaging. Standards issued an interpretation several years ago with an opinion that plastic inners may be considered fragile. Status: Planning stages.
Packaging Safety Program Purpose: Ensure and promote the safe performance of hazardous materials packaging, including its manufacture, qualification, maintenance, use, and reuse. Update: Signed and distributed 6 approvals for the selective testing of IBCs. Authorized top closure gaskets to be replaced without conducting an entire sequence of design qualification testing. Designs PHMSA testing(20 Designs In-Testing or Awaiting Testing): 55-Gallon Plastic and Steel Drums Including 1A1, 1A2, 1H1 and 1H2 5 to 7-Gallon Plastic Pails and Jerricans Including 1H2 and 3H1 1-Gallon Steel Jerrican - 3A1 IBCs Including 31HA1 Composite and 13H4 Flexible Fiberboard Combination Packaging 4G Corrective Action Testing for 1H1 and 3H1
Approvals and Permits Division updating the online application system improve the quality of applications streamline the application process lead to shorter processing times improved process times new SP ~ 90 days Modified SP ~ 70 days Competent Authority Approvals ~85 days
Rulemakings Special Permits SOP : 9/10/15 SOPs and criteria used to evaluate applications Highlights required information to reduce process delays do not change inspection activities subsequent to issuance or modification /renewal of a special permit and approval Adoption of Special Permits: 1/21/16 Adopted provisions in 96 widely-used SPs with established safety intended to provide wider access to the regulatory flexibility reduce paperwork burdens and facilitate commerce represents a 8.22% reduction in the total number of SPs evaluated represents 22.5% of the total number of SP holders (832 total)
Key Performance Indicator Inspection By Type 2015 Q1 # of Facility Inspections 44 12 255 19 3 333 2015 Q2 # of Facility Inspections 35 19 216 21 17 308 2015 Q3 # of Facility Inspections 119 25 321 28 32 525 2015 Q4 # of Facility Inspections 81 23 394 32 26 556 Inspection Types Cylinder Explosives General Packaging RAM Grand Total Source: HIP Data October 23, 2015 Quarterly Management Review FY15 9
Key Performance Indicator High Priority Inspections Inspection Type Total Complete % Comp Dom. Cyl. MFGS Dom. RINS Explosives Foreign Cyl. MFGS / RINS Packaging RAM Select Agent 4 51 16 15 43 24 16 3 43 11 12 39 18 9 75% 84% 69% 80% 91% 75% 56% 80%/ 9 months Total 169 135 Source: HIP Data Oct.20, 2015 Quarterly Management Review FY15 10
Questions? Rick Raksnis Richard.Raksnis@dot.gov www.phmsa.dot.gov
