RIPA Proposes To Re-visit Closure Instruction Definition

Since the adoption of CFR 178.2(c)(1)(i) and (ii) requiring a packaging manufacturer or distributor to inform end users on adequate closure procedures, the flurry of instructions and techniques has caused considerable confusion within the hazardous material packaging community. Many, once-thought, consistent measurements have actually yielded variables that indicate the lack of consistency in closing technique. For instance, torque measurements can be affected by the moisture content on the threads of a bolt, the slickness of the thread surface if oil is present and the integrity of the threads themselves. Other considerations have also been identified and for this reason, RIPA (the Reusable Industrial Packaging Association) in conjunction with the NACD (National Association of Chemical Distributors) will propose that the DOT accept some yet-to-be determined uniform language for closure instructions that will satisfy performance oriented standards for hazardous materials packaging.