Nov/Dec 2017

By December 4, 2017Uncategorized


At the recent IPANA Fall Conference, Mr. Kyle Stavig, CEO of Myers Container, LLC, was elected the new Chairman of IPANA. Mr. Chris Lind, Director, Technology and Regulatory Affairs at Mauser USA, LLC, will continue to serve on the IPANA Board as Vice-Chairman. Mr. Lind previously served as IPANA Chairman.

The IPANA Spring Meeting will feature an exciting lineup of speakers including, Jim Spigener, a safety leadership expert from Dekra Consulting. Breaking from our normal format, we will host a luncheon on April 17 featuring a compelling and moving presentation by the Chairman of Project Healing Waters a volunteer organization that works with disabled veterans. More details to come! I hope to see you there.

The Plastic Drum Institute (PDI) recently honored Jerry Geyer as the inaugural recipient of its Lifetime Membership Award. “This is truly an honor that I was not expecting,” said Geyer, product management and development director at Greif, Inc. “To see the industry continue to grow and prosper has been very satisfying, and to know I have been a small part of its wonderful history. My goal has always been to work for the growth and betterment of the entire industry of plastic drum manufacturers and suppliers.” The Lifetime Membership Award is given to a long-time member of the plastic drum industry who exemplifies dedicated service and devotion to the mission of the Plastic Drum Institute.

The Industrial Steel Drum Institute (ISDI) recently honored Earnest Beardsley, and Robert Evans, Jr. posthumously, with the organization’s Lifetime Membership Award. The award for Earnest Beardsley was presented to his son Jim Beardsley, who is the current Chairman and CEO of North Coast Container, “It is with great honor that I accept this award on behalf of my father,“ said Beardsley. “His dedication and entrepreneurial spirit drove him to build a world-class, steel drum business and I couldn’t be prouder to follow in his footsteps.”

The award for Robert Evans was also presented to his son Robert Evans and wife, Barbara Evans. “It’s an honor to accept this award on behalf of my father,” said Robbie Evans who is Vice President of Con-Tech International. “His impact on our family, our company and our industry will live on in the many lives he touched during his decades of unselfish service to each of them.”

Regulatory Affairs

In early October, PHMSA released their revised Field Operations Manual. The revision of this manual took approximately three years to complete and the Interested Parties for Hazardous Materials provided comments in May of 2014. Mr. John Heneghan, Acting Director of Field Operations attended the Fall IPANA meeting to discuss the changes in the manual. You can view the new manual by clicking here.

The Department of Transportation (DOT) published a Notification of Regulatory Review Docket No. DOT–OST–2017–006981 concerning the agency’s plans for Regulatory Review. In the announcement, the agency stated they will review their existing regulations and other agency actions to evaluate their continued necessity, determine whether they are crafted effectively to solve current problems, and evaluate whether they potentially burden the development or use of domestically produced energy resources. As part of these reviews, the Department invited the public to provide input on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. In response to the recent Federal Register notice, IPANA has submitted comments regarding extending the time period for periodic retests, reuse of samples for DOT testing and collection of invoices during DOT field operation inspections. You can view all 2786 comments that were submitted by clicking here.

On Friday November 17, 2017, PHMSA issued a notice that would terminate any M number and R number approvals that were previously issued without an expiration date. According to the notice, these approvals would expire one year from the publication date of this notice. PHMSA further states that if holders of these approvals can provide evidence that such approvals should not expire, the approvals in question may be reissued with a 5-year expiration. Also, holders of a R# can continue to use the R# as long as it is associated with an M#. You can view the notice by clicking here.

PHMSA has been using a new system to classify letters of interpretation as listed in the new online Code of Federal Regulations (oCFR). Letters of interpretation provide guidance to help stakeholders understand the regulations and are written in response to inquires. Each letter of interpretation is assigned to one of three categories: historic, use caution or current. PHMSA guidance lists “current” as indicating that the interpretation was published within the last 15 years. Letters may also be designated as “use caution” if a final rule has been issued since the letter was written. The user should check the referenced final rule before using the interpretation. The “historic designation” means the letter has either been superseded or is invalid for other reasons. Ed Mazullo, Technical Advisor, published an article in the Journal of HAZMAT Transportation regarding the legal status of PHMSA letters of interpretation and can be consulted for additional guidance when using interpretations.

In late November, Labor Secretary Alexander Acosta testified for the first time during an oversight hearing before the House Education and Workforce Committee. His comments included an update on the Overtime Rule. Since the request for information was published, they have received 200,000 comments. He indicated those comments will be used to formulate a new proposal. Secretary Acosta also stated that OSHA will request more funding for their Voluntary Protection Program (VPP) for compliance assistance. He stated that they understand that most employers are trying to comply with the regulations. He also noted that the Department may need to look at willful or repeated violators and possibly refer them to the Department of Justice for criminal prosecution.


After the recent Equifax hack, the Trump administration announced they were exploring alternatives to the use of social security numbers as the main method of verifying someone’s identities. The administration asked federal departments and agencies to investigate the vulnerabilities of social security numbers as well as investigate alternatives to replace the current system (which is tied to retirement benefits). According to Bob Joyce, special assistant to the President, “I feel strongly that the social security number has outlived its usefulness and every time we use the social security number, we put you at risk.” The massive number of hacks has jeopardized its security value.

People, Places & Things

Uber plans to deploy flying taxis within two years over the skies of Los Angeles. According to Uber, aviation manufacturers will supply and pilot the aircraft. Uber will operate the software that passengers use to book a trip and take a commission, similar to how Uber operates on the ground. “L.A. is a model city for this in that it’s highly congested from a traffic perspective, and there’s not a great mass transit relief on the horizon,” said Jeff Holden, Uber’s chief product officer. Dallas is the second city where Uber plans to deploy this new technology. However, certification of the aircraft from the FAA may take longer than the projected two year timeline.