{"operation":"document","citation":"98-0043","title":"Container-Quinn Testing Laboratories, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-11-06","effective_on":null,"summary":"98-0043 response to Container-Quinn Testing Laboratories, Inc. concerning 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0043.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0043.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0043","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980043.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh Street, S.W\nResearch and\nWashington, D.C.\n20590\nSpecial Programs\nAdministration\nNOV 1 6 1993\nMr. Stephen C. Powell\nLaboratory Manager\nRef. No. 98-0043\nContainer-Quinn Testing Laboratories, Inc.\n170 Shepard Avenue\nWheeling, IL 60090\nDear Mr. Powell:\nThis is in response to your letter dated April 30, 1998, requesting clarification on certifying packages\nusing corrugated materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\n• Specifically, you are requesting clarification on whether to use the Edge Crush Test (ECT) or Mullen\nBurst Test to certify various grades of corrugated packaging materials used in industry, and whether\nchanging liners makes a \"different packaging\" for testing purposes.\nUnder the HMR a \"different packaging\" is broadly defined. As specified in § 178.601(c)(4), a\npackaging which differs in construction such as bursting strength, fluting, basis weight, etc. is considered\na different packaging under § 178.601(c)(4), and must be certified by undergoing design qualification\ntesting. Packagings with different liner/medium combinations are differences in construction or design\ntype and will require testing as a different packaging design. A packaging which differs only in surface\ntreatment, e.g., color, is not considered to be a different design type under provisions of\n§ 178.601(c)(4). The HMR does not require the use of the ECT in lieu of the Mullen Burst test for\ndesıgn qualification testing. Additional supporting information and statistical data on these tests must be\nprovided to this office if you believe that one test in lieu of the other should be recommended for use in\ndetermining a \"different packaging\" or as a design qualification test. As provided in § 106.31, you may\nsubmit a petition for rulemaking on this matter.\nI hope this answers your inquiry. If you need additional assistance, do not hesitate to contact me.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nBoothe\nE.CONTAINER-QUINN\n178.601\nTESTING LABORATORIES, INC.\n170 SHEPARD AVENUE WHEELING, IL 60090\nE-MAIL: QUINNLABS@aol.com\nTELE: 847-537-9470\nFAX: 847-537-9098\n30 April 1998\nU.S. Department of Transportation\nOffice of Hazardous Materials Standards\n400 Seventh Street, S.W.\nUS DOT / RSPA / OHMS DHM-10\nWashington, D.C. 20590\nAttn.: Ed Mazzullo, Director\nRe: ECT vs Mullen Burst\nKraft vs Bleached or Clay White\nDear Mr. Mazzullo;\nRe: ECT vs Mullen Burst\nAccording to current practices, when conducting a certification on a package, all corrugated materials are subjected to a Basis\nWeight Analysis to determine the make-up of the board. This make-up of the board is then suppose to be maintained through-out the life\nof that given certification. Thusly, if I do a Basis Weight on an ECT box and it comes out at (40-26-40), that box is suppose to be\nmade-up of that combination through the life of the certification. With Mullen Burst Board, this is a straight forward procedure as your\nvarious board grades are always suppose to have the same values (ie: 200# test single-wall (42-26-42), 275# test single wall (69-26-69),\n200# test DW (33-26-26-26-33), etc.). With ECT board this is a totally different senario. A 32# ECT board may have a dozen different\ncombinations of liners and/or mediums. These values are determined by a Stifi Value and not Basis Weight. Thus it is more difficult for\nthe mills and sheet plants to run the same board run-to-run. One of the ways of assisting in this matter would be to run an ECT test in\nconjuction with a Basis Weight Analysis. This way ECT board could be used more addequately with hazmat boxes with-out the need to\nmatch the liner/medium combinations. With the ever changing industry, more and more combinations of board for ECT are surfacing.\nThe Basis Weight Analysis could be utilized as a base value for the ECT shipper but various liner/medium combinations would be\nallowed as long as that ECT test value is maintained.\nWith the above in mind, wouldn't it be easier to clarify the shippers by test rather than by board make-up. Bursting strength board\n(200, 275, etc.) would still be governed by the board grade (basis weight) while ECT board would be governed by the ECT test with the\nboard grade utilized and documented as a reference.\nPACKAGING TESTING • DESIGN • DEVELOPMENT • ENGINEERING • SYSTEMS • CONSULTING SERVICES\nSINCE 1923\n\n<<<PAGE 3>>>\n\nCONTAINER-QUINN TESTING LABORATORIES, INC.\nRe: Kraft vs Bleached or Clay White\nIf we are to go on the assumtion that 42 Ib. liners are equivalent, then there are no differences between the various liner board that\nis made. Although the industry utilizes kraft, bleached, clay white board, etc., if we consider that a 200# test box has to have a board\ncombination of (42-26-42) whether that liner is kraft or bleached shouldn't matter as long as the minimum requirements for Cobb\nWater Absorption are maintained in the board. This is the question that is coming up more often. Is there a difference. The regulations\nstate nothing about these variables but they are in existance. If a manufacturer is running a bleached outer liner can he certify his\nshipper using a kraft outer liner or does he have to have bleached samples for the testing. Is the Basis Weight and Cobb Water\nAbsortion the governing factors in this.\nof further assistance, please call.\nYour assistance in clarifying and verifying these matters, as always, is greatly appreciated. If you have any questions, or if I can be\nSincerely;\nStephen C. Powell\nContainer-Quinn Testing Laboratory\nLaboratory Manager\nSA-9009004; ID Code +AX\nPage 2\n\n<<<PAGE 4>>>\n\nMemorandum for the Record\nMeeting on Interp Letter 98-0043, per Recommendation By Don Burger for Policy Decision on\nResponse to Letter from Mr. Powell at Container-Quinn Testing Laboratories, Inc.\nOctober 1, 1998\nSubject: RSPA response to use of Edge Crush Test (ECT) vs. Mullen Burst testing on corrugated\npackagings and Definition of a \"Different Packaging\"\nAttendees:\nEd. Mazzullo, Del Billings, Deborah Boothe, Charlie Hochman, Don Burger\nMeeting Results/Recommendations:\n- He can use either ECT or Mullen Burst (RSPA doesn't tell them which one to use).\n- Any change, incl. ECT and Burst strength, is a different package and must be retested.\n- Any change, e.g., single wall or double wall, is a different package and must be retested.\n- Provide Mr. Powell with a general response to his letter which should include:\n- What a \"different packaging\" is under the HMR.\n- RSPA has a broad definition of a design type under the HMR, and if he wants this criteria\nmodified or changed, he must get an approval from RSPA.\n- He needs to provide RSPA with additional information and statistical data on testing for\nreview if he wants one test in lieu of the other to be recommended for use.\n- ECT is performed on raw material, not finished package.\n- Stifi is a short span of the ECT.\nDeborah Boothe\nDHM-11\n10-1-98","truncated":false,"body_characters":6993}