Smurfit-Stone Container Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W Washington, D.C. 20590 Research and Special Programs AUG 2 2002 Administration Mr. Richard M. Thomas Packaging Performance Specialist Ref. No. 02-0035 10 Pasquinelli Driv murfit-Stone Container Corporatic Westmont, Illinois 60559-5526 Dear Mr. Thomas: This responds to your January 29, 2002 letter requesting clarification on package testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if your box plant can be required to sign a blanket statement guaranteeing that fiberboard used in the outer packaging will always "pass" the 30-minute Cobb Water Absorbency Test. You also ask what must pass the Cobb Test, the "combined" (corrugated fiberboard material) or the "base material" (outer liner component only), and, what results to use, an individual result or average of test results as indicated in the ISO International Standard 535 provisions? According to your letter, 3r party and/or self-certified labs are requesting that your box plants sign blanket statements guaranteeing the fiberboard that is used in their outer packaging always "pass" the 30-minute Cobb Test. You believe that this type of practice is unacceptable since each run of corrugated board may provide different results. The HMR do not require blanket statements guaranteeing that the fiberboard will always pass the Cobb Test. Decisions regarding such business practices should be negotiated between your company and your customers. In your package testing scenario, the Cobb Test is conducted on the "combined"(corrugated fiberboard material) and it fails to pass the Cobb Test. If the Cobb Test was then conducted on the actual "base materials"(outer liner component only) that was actually used in the box and the base material passes, you ask which set of results should you use. Section 178.516(b)(1) requires the SO International Standard 535 specifies using the average. therefore, the average test resul uter surface of the combined board to be tested, not the "base materials" or outer liner componen determine whether the fiberboard passes or fails the Cobb Test. I hope this answers your inquiry. Chief, Standards Development Office of Hazardous Materials Standards 178.5166688 020035#

Page 201/28/02 15:37 FAX 5012548167 STONE GLOBAL @ 01 : Boothe Smurfit-Stone Marketing and Technical Center 3118.516 January 29,2002 Testing Mr. Delmer Billings US-DOT search and Special Programs Administratio 02-0035 0 7th St., SV fice of Hazardous Materials Standards, DHM-1 ashington, DC 2059 Dear Mr. Billings: 2000, we have realized that one of our questions were not answered: After thoroughly reviewing the responses (Ref. No. 00-0342 and 00-0342a) from our last Letter of Interpretation dated December 6, Can a 3rd-Party and/or Self-Certified Lab require any of our Box Plants to sign Blanket Statements guaranteeing the Request 4: Standards for Fiberboard Boxes (49 CFR 178.516) his type of practice is unacceptable since each run of corrugated board may provide different results. iberboard that is used in their outer packaging to always "Pass" the 30-min. Cobb Water Absorbency Test? We believ, New Questions During several recent conversations with Mr. Don Burger from your office on the topic of the 30-min. Cobb Water "combined" (corrugated) fiberboard or the "base material (outer liner component only)? Situation in question is this; the Absorbency Test, we are requesting a clearer explanation on "What must actually pass the 30-minute Cobb Test? The Cobb Test is conducted on the "combined" (corrugated Fiberboard material) and it fails to pass the Cobb Test. If the Cobb Test material passes, which set of results should we use? was then conducted on the actual "base material" (outer liner component only) that was actually used in said box and the bast Example: Combined Board Results 153 Base Material Only Results 150 149 100 107 155 186 107 106 158.2 104 105 Which result do you use to determine if the Cobb Test passes or fails? If any individual result fails or when the average recent version of ISO 535, ISO uses the average of the sample group to determine if the test passes or fails. fails? 49 CFR 178.516 does not specifically provide answers to these questions it only refers ISO 535. After reviewing the most eopardizing safe transportation of hazardous materials in commero n expedited response to these questions would be greally appreciated since it is costing our customers money and may b ply would be appreciated. Thank yo you have any further questions, please feel free to contact me by phone at (630)-794-0331 or by fax at (630)-794-0131. A speer Sincerely, Rickal M. Flower Richard M. Thomas ackaging Performance Specialist cc. Jim Mackowski - Smurfit-Stone Container Corporation Westmone Technical Center 910 Pasquinelli Drive Westmont, Ilinois 60559-5526 phone 630-920-9600 fax 630-920-9601 Smurfit-Stone Container Corporation#