{"operation":"document","citation":"06-0019","title":"3M Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-03-21","effective_on":null,"summary":"06-0019 response to 3M Company concerning 173.28.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0019.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0019.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0019","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060019.pdf","body":"<<<PAGE 1>>>\n\n•3. Depanmer\nf Transportatio\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nAdministration\nMAR Z 1 2006\nMr. Richard L. Sheehan\nReference No.: 06-0019\n3M Company\nSr. Package Engineering Specialist\nIndustrial Adhesives and Tapes Division\n3M Center 230-1S-10\nSt. Paul, MN 55144\nDear Mr. Sheehan:\nThis responds to your letter concerning the reuse of fiberboard boxes under the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask what performance\nstandards apply to a reused packaging, and if an outer package may be reclosed by taping over\nold tape with new tape.\nTaping over old tape with new tape would be acceptable if there is no damage to the\npackaging, it is reclosed in accordance with the closure instruction provided by the packaging\nmanufacturer, and the surface treatment created by the old tape does not adversely affect the\nclosure.\nThere are no separate performance standards for a reused packaging. Section 173.28(a)\nrequires packagings and receptacles used more than once to be in such condition, including\nclosure devices and cushioning materials, that they conform in all respects to the prescribed\nrequirements in the HMR. Before reuse, each packaging must be inspected and may not be\nreused unless it is free from incompatible residue, rupture, or other damage that reduces its\nstructural integrity.\nI trust this satisfies your request.\nSincerely,\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n173-28 (a)\n060019\n\n<<<PAGE 2>>>\n\n3M COMPANY\n6651 7338897\n01/24/06 14:55 0: 01/02 NO:913\nCorbin\n§173.28(a)\nReuse\n06-0019\nJohn A Gale\nJanuary 25, 2006\nChief, Standards Development\nOffice of Hazardous Materials Standards\nUS Department of Transportation\nFAX 202.366.3012\nDear Mr Gale\nWe have been contacted by a customer who is asking about a pressure\nsensitive box sealing tape that can be used to reclose used UN 4G boxes for\nshipment.\n49 C.FR 173.28 seems to have been changed to allow the reuse of\npackagings made of fiberboard. We are also aware of your letter of June 4,\n2004 to Mr Widman of Alliant Techsystems regarding re-taping used boxes.\nThe question of re-use of boxes raises many questions.\nBy visual inspection, it is impossible to determine if a used corrugated box\nhas retained adequate strength for reuse. The flutes may be crushed, the rear\nresistance may be reduced, the surface may be abraded, the ECT may be\nreduced, the burst strength may be reduced, the board may be chemically\nweakened, etc. There is not an established visual nor analytical\nmethodology to determine the residual strength of a used box.\nWith performance-oriented-packaging, what are the performance\nrequirements for a reused box? Experience dictates that the stacking\nstrength of a box is reduced and the drop/impact strength is reduced by\nnormal shipment. Yes, performance is always reduced for a reused box, but\nby how much?\nQuestions abound about the potential liability and the implied performance\nguarantee for reused packagings.\n\n<<<PAGE 3>>>\n\n3M COMPANY\n• 651 733 8897\n01/24/06 14:55 0:02/02 NO:913\nThe specific question we were asked concerned the use of pressure sensitive\nbox sealing tape. All tape manufacturers coat a polyester or a polypropylene\nfilm backing with an adhesive on one side and a release treatment on the\nother side. The easy-release treatment allows the tape to be wound up on a\nroll and subsequently unwound from the roll for use. When tape is applied\nover old tape, the new tape is trying to adhere to the release treatment on the\nold tape backing. The bond of the lape to tape is much less than the bord of\ntape to kraft corrugated board.\nIf someone were to apply tape on a used box, we would suggest that they\ncorsider applying 72 mm wide tape over the usual 48 mm wide tape which\nhad been slit open. The extra width of tape would adhere to the corrugated\nboard on each side of the old tape to help improve bonding. New tape\nshould be applied over all of the old tape, even the portions which are not\nslit open. Very limited T.2 m drop testing with this configuration has been\nsuccessful in our laboratory. We would not, however, guarantee\nperformance for all shippers. More thorough analysis would be needed.\nOther box closures (adhesives, staples, gummed tapes, strapping, etc) all\nhave similar problems with re-use.\nWe would not recommend the reuse of UN 4G corrugated boxes.\nSincerely\nRichard L Sheehan\nSt Package Engineering Specialist\n3M Company\nIndustrial Adhesives and Tapes Division\n3M Center 230-1S-10\nSt Paul MN 55144","truncated":false,"body_characters":4597}