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DOT Introduces New Package Validation Testing Program

October 15th, 2008 by Howard Skolnik

Filed under: Associations, DOT/UN, Industry News

On September 25th, 2008, representatives from the DOT met for the second time with the Reusable Industrial Packaging Association, RIPA, and other packaging industry associations in order to address the issues relating to the LOGSA testing program at Tobyhanna. Present from PHMSA were Ted Willke, Associate Administrator, Rob Richard, Deputy Associate Administrator, Ryan Posten, Director of Hazardous Materials Enforcement, and several other upper level regulators from DOT. RIPA was represented by Paul Rankin, Calvin Lee, Howard Skolnik and CL Pettit. Other associations represented included The Plastic Drum Institute, The Plastic Shipping Container Institute and IPANA. The highlight of the meeting was Ryan Posten’s introductory presentation of the National Packaging Strategy Mission. Given the results of more than 10 years of in-field testing at the Tobyhanna laboratory, the new Packaging Strategy will change validation testing significantly. Rather than gathering random packagings in the field, DOT will go directly to packaging manufacturers for the selection of packagings to be tested, and manufacturers will have the option of performing the validation tests on their own premises, at a third party test lab, or at the LOGSA facility at Tobyhanna. The goal of the new strategy is to eliminate non-compliance of packagings, utilize uniform protocols and generate support for manufacturer’s quality programs. DOT will emphasize the selection of high risk packaging and all data gathered will be used to identify trends and prioritize risks. Posten announced that as of August 8th, 2008, the in-field DOT inspectors were informed of this new approach to packaging validation. Therefore, manufacturers and shippers can expect a DOT inspector to arrive at their facility, ask to see samples of packagings, test certifications and training documents. Ultimately, DOT can request that testing validation be performed in their presence. In the event of a successful test, the visit will be complete. If testing is not successful, DOT will work with the facility to identify potential reasons for failure and retest. It’s a step in the right direction for DOT and US packaging integrity.

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