RIPA Promotes Closure Notice Verification As Code Of Practice

In a recent DOT enforcement action, a packaging manufacturer was held accountable for having to prove that Closure Notifications were given to their customers. During a routine inspection, DOT claimed that proof of receipt of the instructions was not available. While not resolved throughout the packaging industry, the Reuseable Industrial Packaging Association (RIPA) has taken action by amending their Code of Practice to include the following: "For hazardous materials packaging, written notice must be given to each person to whom that packaging is transferred of all requirements not met at the time of transfer, and of all the type and dimension of any closures, including gaskets, needed to satisfy the DOT performance test requirements. Such so-called closure instructions must be provided for each design type transferred. The provider of the packaging must keep a copy of this notice for at least one year. As a recommended business practice, suppliers of hazardous materials packaging also should implement a system by which they are able to verify that the person to whom the packaging was transferred actually received the notification."