{"operation":"document","citation":"02-0035","title":"Smurfit-Stone Container Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-08-02","effective_on":null,"summary":"02-0035 response to Smurfit-Stone Container Corporation concerning 178.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0035.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0035.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0035","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020035.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAUG 2 2002\nAdministration\nMr. Richard M. Thomas\nPackaging Performance Specialist\nRef. No. 02-0035\n10 Pasquinelli Driv\nmurfit-Stone Container Corporatic\nWestmont, Illinois 60559-5526\nDear Mr. Thomas:\nThis responds to your January 29, 2002 letter requesting clarification on package testing under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if your box\nplant can be required to sign a blanket statement guaranteeing that fiberboard used in the outer\npackaging will always \"pass\" the 30-minute Cobb Water Absorbency Test. You also ask what must\npass the Cobb Test, the \"combined\" (corrugated fiberboard material) or the \"base material\" (outer liner\ncomponent only), and, what results to use, an individual result or average of test results as indicated in\nthe ISO International Standard 535 provisions?\nAccording to your letter, 3r party and/or self-certified labs are requesting that your box plants sign\nblanket statements guaranteeing the fiberboard that is used in their outer packaging always \"pass\" the\n30-minute Cobb Test. You believe that this type of practice is unacceptable since each run of\ncorrugated board may provide different results. The HMR do not require blanket statements\nguaranteeing that the fiberboard will always pass the Cobb Test. Decisions regarding such business\npractices should be negotiated between your company and your customers.\nIn your package testing scenario, the Cobb Test is conducted on the \"combined\"(corrugated\nfiberboard material) and it fails to pass the Cobb Test. If the Cobb Test was then conducted on the\nactual \"base materials\"(outer liner component only) that was actually used in the box and the base\nmaterial passes, you ask which set of results should you use. Section 178.516(b)(1) requires the\nSO International Standard 535 specifies using the average. therefore, the average test resul\nuter surface of the combined board to be tested, not the \"base materials\" or outer liner componen\ndetermine whether the fiberboard passes or fails the Cobb Test.\nI hope this answers your inquiry.\nChief, Standards Development\nOffice of Hazardous Materials Standards\n178.5166688\n020035\n\n<<<PAGE 2>>>\n\n01/28/02 15:37 FAX 5012548167\nSTONE GLOBAL\n@ 01\n:\nBoothe\nSmurfit-Stone\nMarketing and Technical Center\n3118.516\nJanuary 29,2002\nTesting\nMr. Delmer Billings\nUS-DOT\nsearch and Special Programs Administratio\n02-0035\n0 7th St., SV\nfice of Hazardous Materials Standards, DHM-1\nashington, DC 2059\nDear Mr. Billings:\n2000, we have realized that one of our questions were not answered:\nAfter thoroughly reviewing the responses (Ref. No. 00-0342 and 00-0342a) from our last Letter of Interpretation dated December 6,\nCan a 3rd-Party and/or Self-Certified Lab require any of our Box Plants to sign Blanket Statements guaranteeing the\nRequest 4: Standards for Fiberboard Boxes (49 CFR 178.516)\nhis type of practice is unacceptable since each run of corrugated board may provide different results.\niberboard that is used in their outer packaging to always \"Pass\" the 30-min. Cobb Water Absorbency Test? We believ,\nNew Questions\nDuring several recent conversations with Mr. Don Burger from your office on the topic of the 30-min. Cobb Water\n\"combined\" (corrugated) fiberboard or the \"base material (outer liner component only)? Situation in question is this; the\nAbsorbency Test, we are requesting a clearer explanation on \"What must actually pass the 30-minute Cobb Test? The\nCobb Test is conducted on the \"combined\" (corrugated Fiberboard material) and it fails to pass the Cobb Test. If the Cobb Test\nmaterial passes, which set of results should we use?\nwas then conducted on the actual \"base material\" (outer liner component only) that was actually used in said box and the bast\nExample:\nCombined Board Results\n153\nBase Material Only Results\n150\n149\n100\n107\n155\n186\n107\n106\n158.2\n104\n105\nWhich result do you use to determine if the Cobb Test passes or fails? If any individual result fails or when the average\nrecent version of ISO 535, ISO uses the average of the sample group to determine if the test passes or fails.\nfails? 49 CFR 178.516 does not specifically provide answers to these questions it only refers ISO 535. After reviewing the most\neopardizing safe transportation of hazardous materials in commero\nn expedited response to these questions would be greally appreciated since it is costing our customers money and may b\nply would be appreciated. Thank yo\nyou 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\nSincerely,\nRickal M. Flower\nRichard M. Thomas\nackaging Performance Specialist\ncc. Jim Mackowski - Smurfit-Stone Container Corporation Westmone Technical Center\n910 Pasquinelli Drive Westmont, Ilinois 60559-5526 phone 630-920-9600 fax 630-920-9601\nSmurfit-Stone Container Corporation","truncated":false,"body_characters":4971}