Operational Policy 4 - Other Bulk Packagings Certification

The Other Bulk Packagings certification and maintenance of certification requirements in CVSA Operational Policy 4 should be revised to combine initial and maintenance of certification requirements with Cargo Tank inspection as applicable. OBP pre-requisites would be maintained; however, initial certification requirements for conducting 16 OBP inspections and maintenance of certification requirements for conducting 8 OBP inspections would be removed. Basically, OBP certification requirements would be combined with Cargo Tank certification as applicable. In essence, OBP would become a logical extension of Cargo Tank inspections, not a separate certification. In addition, this would be consistent with the discussions about how the certification requirements for the new Advanced Level I course will be handled.

This change should be made immediately and is of high importance. The addition of OBP certification was ultimately born from the fact the amount of material instructed in CT Inspection class became too extensive and it was necessary to divide the course material to cover information relating to CTs and, what came to be known as, OBP's. The primary issue with this philosophy is with cylinders that actually meet the definition of a non-bulk package. As permitted by Op. Policy 4, TX has maintained more stringent certification requirements since the inception of the OBP certification. As previously discussed in committee, our inspectors should conduct required inspections for certification maintenance in the appropriate category. Cargo Tank and OBP inspections are and have always been closely aligned with very minor inspection process differences. This proposed revision would ultimately not change current practices since CT inspections are now permitted to maintain OBP certification.

Change Operational Policy 4 as noted in the proposed revision submitted.