1. Reusable Industrial Packaging Association RIPA IBC Compliance Workshop Grand Hyatt Tampa Bay Tampa, Florida March 6, 2013

2. RIPA IBC Compliance Workshop Introduction Focus is on composite IBC regulations and compliance. Also adding (time permitting) - How to be ready for a DOT inspection IBCs used for pesticides – EPA activities Presenters: Brian Evoy, Fiber Drum Sales, Inc. Wes Ledbetter, Indianapolis Drum Service Spencer Walker, National Container Group Paul Rankin, RIPA President Larry Bierlein, RIPA General Counsel

3. RIPA IBC Compliance Workshop Disclaimer The RIPA IBC Compliance Manual is comprehensive; however, it is not intended to be used as a substitute for the regulations.

4. RIPA IBC Compliance Workshop DEFINITIONS & TERMS US Department of Transportation (DOT) - Pipeline and Hazardous Materials Safety Administration, and - Office Of Hazardous Materials Safety

5. RIPA IBC Compliance Workshop DEFINITIONS & TERMS Intermediate bulk container (IBC). A rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling. The capacity of the container ranges from >450 L to 3000 L. Most are 275 – 330 gallons.

6. RIPA IBC Compliance Workshop IMPORTANT DEFINITIONS FOR IBC REPROCESSORS

7. RIPA IBC Compliance Workshop DID YOU SAY “IBC REPROCESSOR?” YES! DOT does not use the term “reconditioning” for IBCs. IBCs are “routinely maintained,” “repaired” or “remanufactured.”

8. RIPA IBC Compliance Workshop Routine maintenance (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.

9. RIPA IBC Compliance Workshop KEY TERMS Original manufacturer’s specifications Not defined; generally same style of valve (e.g. ball) Structural equipment (178.700) Reinforcing, fastening, handling, protective or stabilizing members of the body or stacking load bearing structural members (such as metal cages) Service equipment (178.700) Filling and discharge, pressure relief, safety and heating devices

10. RIPA IBC Compliance Workshop 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.

11. RIPA IBC Compliance Workshop Key Terms IBC design type (178.801): An IBC that does not differ in structural design, size, material of construction, wall thickness, manner of construction and representative service equipment Notes: (1) DOT authorizes 25% size reduction for IBC design tests. (2) Corner protectors are part of design type Service equipment (178.700): Filling and discharge, pressure relief, safety and heating devices

12. RIPA IBC Compliance Workshop Remanufactured IBC (180.350). (This process is commonly called “cross-bottling.”) A metal, rigid plastic or composite IBC that: Has an inner receptacle produced by one manufacturer that is placed into a cage produced by another manufacturer (or vice versa), i.e. cross bottling.

13. RIPA IBC Compliance Workshop Empty IBC Rule and Transportation Requirements

14. RIPA IBC Compliance Workshop Empty IBC Requirements An IBC that has been emptied by a customer is not absolutely empty; it still holds hazmat residue. Two federal agencies regulate empty IBC transport - EPA limits the amount of hazmat residue in the container DOT rules govern actual transportation

15. RIPA IBC Compliance Workshop EMPTY IBC REQUIREMENTS EPA rule (261.7) All residues must be removed that can be removed (by the emptier!) OR 0.3% by weight (about 0.8 gal. for 275 gallon unit)

16. RIPA IBC Compliance Workshop Both IBCs are “Empty” No liquid0.8 gallon

17. RIPA IBC Compliance Workshop DOT REQUIREMENTS FOR TRANSPORTATION OF EMPTY IBCs (Shipper/Emptier Requirement) Openings closed (e.g. cap, valve) Labels in place Truck is placarded (four-digit UN ID for each material) Shipping papers from emptier Driver has hazmat endorsement

18. RIPA IBC Compliance Workshop EMPTY IBC CERTIFICATION RIPA recommends using the RIPA “Empty IBC Certification” form for every shipment. Why? Emptier/shipper must sign and take responsibility Proof to EPA/DOT that you have done your part Proof to emptier/shipper if problems arise

19. RIPA IBC Compliance Workshop INCOMING IBC ISSUES

20. RIPA IBC Compliance Workshop INSPECTION OF NEWLY PURCHASED IBC BOTTLES DOT has cited several members for not testing a new IBC bottle even though the manufacturer has already done the test and sealed the bottle.

21. RIPA IBC Compliance Workshop INCOMING NEW IBC BOTTLES When receiving new bottles, DOT requires performance of a six-sided visual inspection by a trained plant employee on each bottle after it is removed from the delivery truck. Purpose: Check for damage caused in transit that may cause the bottle to be unusable.

22. RIPA IBC Compliance Workshop INCOMING IBC BOTTLE INSPECTION PROCEDURE 1.Inspect ALL incoming bottles on six (6) sides to determine damage. 2.Train employees on inspection procedure. This is function specific training (Keep records in files). 3.Have a letter from each manufacturer stating the bottles have been properly tested (in manual). 4.Keep record indicating # of remanufactured and repaired IBCs. (180.352(g))

23. RIPA IBC Compliance Workshop Sample Training Document Incoming IBC Bottle Inspection Procedure 1. Incoming new IBC bottles must be visually inspected on six (6) sides to determine if any damage that would make the IBC unusable has occurred during transportation (e.g. cracks, holes, damaged valve). 2. If any damage to the bottle is detected, the supervisor should be notified and the bottle should be set aside in a designated location. No damaged bottles may be used for reprocessing. 3. By signing this training statement, you agree that you understand the importance of this procedure and how to conduct incoming bottle inspections. Supervisors Name Employees Name

24. RIPA IBC Compliance Workshop Incoming “Heavy” IBCs Emptiers occasionally mistakenly ship IBCs with more than allowable hazmat residue. Members should have a written procedure in place to deal with these units. Some leave “heavy” IBC in truck for immediate return – shipping paper required. If unloaded, sequester, rejected sticker, notify shipper and return. Shipping paper required.

25. RIPA IBC Compliance Workshop

26. HAZMAT SHIPPING PAPERS Shipping papers (bills of lading) are required when returning product to an emptier. Document describes the product and indicates the hazard. KEYS: Product Description must match the Proper Shipping Name in 49 CFR. Original shipper should provide information.

27. RIPA IBC Compliance Workshop HAZMAT SHIPPING PAPERS Shipping paper (bill of lading) must follow a specific order: Proper shipping name Hazard class ID number Packing Group Reportable Quantity (RQ) Emergency Response Phone # (24 hour access)

28. RIPA IBC Compliance Workshop Example of Proper Shipping Name (Sulfuric Acid) UN 1830, Sulfuric Acid, 8, PG III, RQ Must also include: - 24 hour emergency response contact - Shipper’s certification

29. RIPA IBC Compliance Workshop IBC TESTING, RETESTING & RECORDKEEPING

30. RIPA IBC Compliance Workshop Leakproofness vs. Leak tightness “Leakproofness” testing for new, repaired and remanufactured IBCs (178.813) Inner receptacle tested without cage 20 kPa air pressure for “suitable time” Soap solution on seams and joints (or other effective method) Pass criteria: No leakage of air from IBC

31. RIPA IBC Compliance Workshop IBC Testing, Marking & Recordkeeping Leak “tightness” testing applies to routine maintenance No DOT approved method for conducting this test! Two common options using air pressure: Solution over discharge valve for “sufficient” time Water submersion of discharge valve for “sufficient” time Other non-air pressure methods are acceptable

32. RIPA IBC Compliance Workshop IBC Retest & Inspection 2.5-years from original manufacture date on the bottle or last repair: Must perform: Leakproofness test and External inspection (with Bottle Outside the Cage) to ensure: Properly marked Service equipment functional IBC is “capable” of passing performance tests

33. RIPA IBC Compliance Workshop IBC Retest & Inspection 5-year inspection Leakproofness test External inspection (bottle outside cage) to ensure: Proper marking Service equipment is functional IBC is “capable” of passing performance tests

34. RIPA IBC Compliance Workshop RECORDKEEPING Remanufactured IBCs (“cross bottle”) Maintain a CURRENT copy of design type test Hold copies for 2.5 years after last sale of any design type. NOTE: RIPA MEMBERS DO JOINT TESTING ANNUALLY ON CERTAIN IBC DESIGNS

35. RIPA IBC Compliance Workshop RECORDKEEPING Retest and inspection records Description of design types/packaging spec’s Test and inspection dates Name and address of facility Name of person conducting tests/inspections Results of tests/inspections Keep test records for 2.5 years AFTER production and inspection

36. RIPA IBC Compliance Workshop IBC MARKING

37. RIPA IBC Compliance Workshop

38. IBC Marking All marks must be 12 mm high (about ½ inch) “Primary Mark” UN 31HA1/Y/11/USA/M 4567/3629/1955 “Additional Mark” 1040L/56kg/100kPa/07 03/07 03

39. RIPA IBC Compliance Workshop Bottle Marking 31HA1/M 4567/03 11/USA IBC design code Name or symbol of manufacturer Date of manufacture Country authorizing mark PROBLEM: Mark on bottle not always in same place

40. RIPA IBC Compliance Workshop IBC Reprocessor Markings Three types of markings for reconditioners Routine maintenance Repair Remanufacture

41. RIPA IBC Compliance Workshop ROUTINE MAINTENANCE General cleaning; general restoration Mark:USA/M1234

42. RIPA IBC Compliance Workshop REPAIR General restoration of structural components/Replacement of inner receptacle with one from same manufacturer USA/M1234/03 11

43. RIPA IBC Compliance Workshop REMANUFACTURE “Cross-bottled IBCs” Bottle from Manufacturer “A” in Cage Produced by Manufacturer “B” Design type Design type test (annual update) Full mark, just like a “newly” manufactured unit

44. RIPA IBC Compliance Workshop Stacking Mark On all IBCs repaired, remanufactured, or new RIPA recommends for routine maintenance Lower max kg than new

45. RIPA IBC Compliance Workshop What if an original mark is partially gone or no longer legible? DOT requires reconditioners to re-apply the original mark so it is marked in accordance with requirements in §178.703 of this subchapter. Missing or damaged markings, or markings difficult to read must be restored or returned to original condition.

46. RIPA IBC Compliance Workshop Marking is function specific for employee training programs.

47. RIPA IBC Compliance Workshop CLOSURE INSTRUCTIONS

48. RIPA IBC Compliance Workshop CLOSURE INSTRUCTIONS Must be provided to each person to whom a hazmat packaging is sold. Instructions must have sufficient detail to enable proper & consistent closure, including: Closures used Closure procedures Tools needed, etc.

49. RIPA IBC Compliance Workshop CLOSURE INSTRUCTIONS Can be provided electronically (e-mail or CD); Web not sufficient RIPA recommends electronic and hard copy, perhaps with shipping documents

50. RIPA IBC Compliance Workshop OTHER MATTERS Quality assurance program DOT does not require reconditioners to have an IBC QA program, but RIPA’s Code of Practice recommends one be created. Sample in book. Employee training (initial and every 3 years) General awareness (includes security training) Function specific (leak tester/bottle inspection/marking) Safety NOTE: SECURITY PLANS ARE NOT REQUIRED