{"operation":"document","citation":"16-0095","title":"Jamestown Container Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-12-22","effective_on":null,"summary":"16-0095 response to Jamestown Container Corporation concerning 171.7, 178.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0095.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0095.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0095","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/160095.pdf","body":"<<<PAGE 1>>>\n\nJamestown Container Corporation\n14 Deming Drive\nP.O. Box 49\nFalconer, NY 14733\nReference No. 16-0095\nDear Mr. Storms:\nThis letter is in response to your June 1, 2016, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the standards for United\nNations (UN) 4G fiberboard boxes. Specifically, you describe a scenario in which a customer\nhas challenged your stance on the construction of the corrugated components in a UN\nperformance-oriented tested package. We have paraphrased and answered your questions as\nfollows:\nQ1.\nYou ask for confirmation of your understanding that according to UN 4G packaging\nrequirements, both the outer and inner corrugated components must be manufactured\nwith liners and mediums that vary by not more than plus or minus 5% from the basis\nweights reported in the valid hazmat test report issued by a competent test lab or agency.\nA1.\nYour understanding is correct. As provided in § 178.516(b)(7), you have \"[a]uthorization\nto manufacture, mark, and sell UN 4G combination packagings with outer fiberboard\nboxes and inner fiberboard components that have individual containerboard or paper wall\nbasis weights that vary by not more than plus or minus 5% from the nominal basis weight.\nreported in the initial design qualification test report. \"ab\n* The HM-233C final rule, published March 18, 2014, amended § 178.516 by adding paragraph (b)(7). This action\nby PHMSA converted numerous competent authority approvals in to the HMR, which reduced paperwork burdens\nand facilitates commerce while maintaining an acceptable level of safety. (See 79 FR 15033; 15034)\nCA2005120010 - Authorization to manufacture, mark, and sell UN4G combination packagings with outer\nfiberboard boxes and with inner fiberboard components that have basis weights that vary by not more than plus or\nminus 5% from the measured basis weight in the initial design qualification test report.\nCA2006060006 - Authorization to manufacture, mark, and sell UNG combination packagings with outer\nfiberboard components that have individual containerboard basis weights that vary by plus or minus 5% from the\nnominal basis weight reported in the initial design.\n\n<<<PAGE 2>>>\n\nStrong, solid or double-faced corrugated fiberboard (single or multi-wall) must be\nused, appropriate to the capacity and intended use of the box. The water\nresistance of the outer surface must be such that the increase in mass, as\ndetermined in a test carried out over a period of 30 minutes by the Cobb method\nof determining water absorption, is not greater than 155 grams per square meter\n(0.0316 pounds per square foot)—see ISO 535 (IBR, see § 171.7 of the HMR).\nAs such, the outer surface of all fiberboard used in the construction of UN 4G fiberboard\nboxes must meet the water resistance requirements as determined by the Cobb method of\ndetermining water absorption. The Cobb test must be performed at a frequency sufficient\nto ensure that all fiberboard used in the boxes meets the water resistance standard.\nThe water resistance test is a manufacturing requirement, not a mechanical performance\ntest requirement. The UN 4G fiberboard boxes must also meet the mechanical\nperformance test requirements located in Subpart M of Part 178.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nstentoster\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\nCA2006010012 - Authorization to manufacture, mark, and sell UN4G combination packagings with outer\nfiberboard boxes and with inner fiberboard components that have individual containerboard basis weight that vary\nby plus or minus 5% from the nominal basis weight reported in the initial design qualification test report.\n\n<<<PAGE 3>>>\n\nPlease submit this for a letter of interpretation. Mr. Storms spoke with Eamonn in the Info Center.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Storms, Brian [mailto:Brian. Storms@JamestownContainer.com]\nSent: Wednesday, June 01, 2016 3:09 PM\nTo: INFOCTRPHMSA)\nSubject: Request for letter of interpretation regarding CFR 49, §178.516 Standards for fiberboard boxes\nTo whom it may concern,\nWe are a corrugated box manufacturer. Our question is in regards to the inner and outer corrugated components used\nfor the shipment of hazardous materials as stated in CFR 49, §178.516 Standards for fiberboard boxes. A customer has\nchallenged our stance on the construction of the corrugated components in a UN performance-oriented tested\npackage.\nOur stance is that both the outer and inner corrugated components must be manufactured with liners and mediums\nthat vary by not more than plus or minus 5% from the basis weights reported in the valid (not expired) HazMat test\nreport issued by a competent test lab or agency. We would also like confirmation that only the outer liner, of the outer\ncarton, needs to be able to pass the cobb water absorption test.\nWe would appreciate an official letter of interpretation clarifying these two points.\nThank you,\nBrian Storms\nCorporate Packaging Engineer\nJamestown Container Corporation\nwww.jamestowncontainer.com\n716.665.4623 x118\nCOMPANIES\n\n<<<PAGE 4>>>","truncated":false,"body_characters":5235}