{"operation":"document","citation":"00-0191","title":"International Paper — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-01-09","effective_on":null,"summary":"00-0191 response to International Paper concerning 178.521.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0191.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0191.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0191","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000191.pdf","body":"<<<PAGE 1>>>\n\nU.5. Department\n400 Seventh St., S.W.\nResearch and\nof Transportation\nWashington, D.C. 20590\nspecial Program:\nAdministratior\nJAN - 2 2001\nMr. Richard Ruebush\nRef. No. 00-0191\nInternational Paper\nP.O. Box 4687\nSpartanburg, SC 29304-5687\nDear Mr. Ruebush:\nThis is in response to your letter dated July 10, 2000, regarding construction of \"UNSM2\" paper bags\nof three plies and four plies authorized in § 178.521(b)(2) of the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). You state the multi-wall bags are sometimes constructed either with\nplastic film plies or plastic film plies laminated to paper plies with adhesives, either with all over adhesive\ncoverage or stripes of adhesive.\nYour questions are paraphrased and answered as follows:\nQ1. Does the statement in § 178.521(b)(2) in reference to the number of plies only mean paper\nplies, or does it also include plastic film plies which may be used in combination with paper\nplies?\nAl.\nThe \" UNSM2\" multi-wall bag must be made of suitable kraft paper or an equivalent paper with\nat least three plies. To prevent the entry of moisture, a plastic film ply may be used as a\nwaterproof ply or water-resistant barrier in combination with paper plies as prescribed\n§ 178.521(b)(2).\n02.\nIs the plastic film ply considered a separate ply if it is laminated or bonded in some way to a\npaper ply, or is it only considered a separate ply if it is free and not bonded to a paper ply.\nA2.\nA plastic film ply bonded or laminated to the inner surface of a three ply bag as a waterproof\nply or barrier would be considered a separate ply.\n178.52)\n000191\n\n<<<PAGE 2>>>\n\nQ3.\nIs a bag constructed of a plastic film inner ply laminated to a ply of kraft paper having an outer\nply of water-resistant kraft paper considered a three ply \"UNSM2\" bag.\nA3.\nYes, provided the bag complies with all other requirements of § 178.521 and meets the testing\nrequirements of Subpart M of Part 178.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nShe Ailfis\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nINTERNATIONAL PAPER\nEngrum\n$178.521\nCUSTOMER RESOURCE CENTER\nP.O. BOX 5687\nPHONE: 864-596-7140\nSPARTANBURG, SC 29304-5687\n980-0191\nFAX: 864-596-7175\nJuly 10, 2000\nU.S. Department of Transportation\n400 Seventh Street, S.W.\nRescarch and Special Programs Administration\nWashington, D.C. 20590-0001\nOffice of Hazardous Materials Standards DHM-10:\nI have some questions about SM2 paper bags as mentioned in 49 CFR 178.521(b)(2). My questions are in\nreference to the statements about bags of three plies and bags of four plies or more.\nMultiwall bags are sometimes constructed either with plastic film plies between paper plies or plastic film\nplies laminated to paper plies with adhesives, either with all over adhesive coverage or stripes of adhesive.\nDoes the statement about the number of plies only mean paper plies or does it also include plastic film\nplies which may be in combination with the paper plies?\n2. Is the plastic film ply considered a separate ply if it is laminated or bonded in some way to a paper ply\nor is it only considered a separate ply if it is free and not bonded to a paper ply?\nI would be grateful if you can provide some clarification on these issues for me. Please contact me if you\nneed more information at 864-596-7159 or at the address on the letterhead.\nRegards,\nRichard Ruebush\nRichard Ruebush\nDOT Packaging Coordinator","truncated":false,"body_characters":3507}