Signode Packaging Systems — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Administration special Programs FEB 1 0 1998 Mr. Mark T. Hughes Senior Packaging Research Engineer Signode Packaging Systems 3640 West Lake Avenue Glenview, Illinois 60025 Dear Mr. Hughes: This is in response to your letter, and telephone conversation with Diane LaValle of my staff, requesting clarification on the definition of non-bulk composite packagings regarding the use of flexible plastic woven bags under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically, you describe a flexible woven plastic bag which has corrugated fiberboard sewn between the layers of woven material to provide rigidity and a 3 mil. plastic liner and ask if it may be described as a UN 6HH1 composite packaging (i.e., a plastic receptacle within a protective plastic drum). The answer is no. A packaging certified as a UN 6HH1 must be constructed as provided in § 178.509 (Standards for plastic drums and jerricans). However, as provided in § 178.601(h), a packaging having specifications different from those in §§ 178.504-178.523 may be used if approved by the Associate Administrator for Hazardous Materials Safety. Such packagings must be shown to be equally effective and the testing methods used must be equivalent. I hope this information is helpful. Sincerely, She Hillip of. Delmer F. Billings Chief, Regulations Development Office of Hazardous Materials Standards 171.8#

Page 2of Transportation U.S.Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration FEB 10 1998 Mr. Mark T. Hughes Senior Packaging Research Engineer Signode Packaging Systems 3640 West Lake Avenue Glenview, Illinois 60025 Dear Mr. Hughes: This is in response to your letter, and telephone conversation with Diane LaValle of my staff, requesting clarification on the definition of non-bulk composite packagings regarding the use of flexible plastic woven bags under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically, you describe a flexible woven plastic bag which has corrugated fiberboard sewn between the layers of woven material to provide rigidity and a 3 mil. plastic liner and ask if it may be described as a UN 6HH1 composite packaging (i.e., a plastic receptacle within a protective plastic drum). The answer is no. A packaging certified as a UN 6HH1 must be constructed as provided in § 178.509 (Standards for plastic drums and jerricans). However, as provided in § 178.601(h), a packaging having specifications different from those in §§ 178.504-178.523 may be used if approved by the Associate Administrator for Hazardous Materials Safety. Such packagings must be shown to be equally effective and the testing methods used must be equivalent. I hope this information is helpful. Sincerely, She Hillip of. Delmer F. Billings Chief, Regulations Development Office of Hazardous Materials Standards 980373#

Page 3• SIGNODE PACKAGING SYSTEMS * Fi # 3640 West Lake Avenue Glenview, Illinois 60025 Lavalle Telephone 1-800-722-5523 Telephone (847) 724-6100 Fax (847) 657-5365 File: 171.8 Bag, Drum http://www.ezone.com/signode SC: 510,300 MISIGNODE® June 10, 1997 Ms. Diane LaValle, DHM-11 U.S. Department of Transportation Office of Hazardous Materials Safety Regulations Development, DHM-11 400 Seventh Street, S.W. Washington, D.C. 20590 Dear Ms. LaValle: Thank you for following up our conversation on the definition of non bulk composite packagings in relation to the utilization of a flexible plastic woven bags. My customer has submitted that a flexible plastic woven bag could fall under the classification of a Composite Package - 6HH1 (Plastic Drum with a Plastic Receptacle Inner Packaging). He has submitted the Flexible Woven Plastic Bag with a 3 mil. Plastic Bag Insert (Capacity 4 cu. ft. bag - 250lb., 8 cu. ft. bag - 800 lb.). The plastic bag insert is secured closed with a plastic tie or a steel tie. The flexible bag has corrugated sewn between the layers of woven material to provide rigidity for loading. The flexible bag has woven material tie offs sewn around the closure to secure the bag closed. I have gone through the regulations and can not find a defining regulation that would not allow him to classify this assembly as a Composite Package (6HH1). Although the spirit of the regulations would define this product as a flexible bag, I request your assistance in a final ruling on the matter. Thank you for your time and assistance. Very Truly Yours: Signode Packaging Research Laboratory Senior Packaging Research Engineer 847-657-4382 An ITW Company • MW1055 6/9#

Page 4FILE No. 424 07/23 '97 09:49 ID:B.A.G. CORP 214 340 4598 PAGE 1 .i..i • Facsimile Cover Sheet To: Bob Richards Company: Phone: U.S. D.O.T. 202/366-0656 Fax: 202/366-5713 3753 From: Mark Eubank • Company: B.A.G. Corp. Phone: 214-340-7060 Fax: 214-340-4598 Date: July 21,1 997 Pages including this one: 3 COMMENTS: Bob, following are two pieces of literature for our containers that we trying to categorize as 4H2 solid plastic box. We can find nothing that excludes our package from being called this. The corrugated Stiffeners which are sewn into the plies allow the container to stand by itself. All performance requirements have been met and we are waiting a writen opinion from the DOT for final third party testing. I will follow-up with a phone call Thurs. July 24, 109:84! EHEl#

Page 5FILE No. 424 07/23 '97 09:49 ID:B.A.G. CORP 214 340 4598 PAGE 2 Bob DI íd Hochman ECONOMICAL LAND FILL CONTAINERS = 27 cubic foor volume BAC • 2,200 pound weight capacity .GORD • UN certifled for Group Il and ill e includes a 3 mil HDPE linor • Full open top, web ce closure • Flat bottom, no discharge a Four, ten inch lifting loops • Lightweight design The Super Sack® Container Call B.A.G. Corp. for all of your bulk packaging needs. B.A.G. Corp. is the only source for the original Super Sack® container. Call us today to learn how our products can save you time, space and money. B.A.G. Corp. Local Distributor: 11510 Data Drive Dallas. TX 75218 800/331-9200 214/340-7060 214/340-4598 (Fax) 11 11. I vip bullhel ren Winsu lirit#

Page 6FILE No. 424 07/23 '97 09:50 ID:B.A.G. CORP 214 340 4598 PAGE 3 FlexDrum FLEXIBLE CONTAINERS Anything a drum can do, the FlexDrum' Flexible Container can do better! Designed to take the place of metal drums, fiber drums or boxes. Facts: • Vohume of 8.5 cubic feer (equals a 5s gallon drum) • Weighs less chan 10 pounds • Weight capacity of 800 pounds • IN. certified for Class I1 & H1 hazardous waste • PE liner, 3.0 mil included, other options available • Sell supporting construction • Ships and stores collapsed • Acceprable for incineration Call us doday for quality solutions and expert technical support The MexDrum'n consiner is fres-standing because of its unique, patented construction. BAC 11510 Dola Drive, Dallas, Texas 75218 800/331-9200 • 214/340-7060 Fax: 214/340-4598 TE Continer Assion wil Strop tro ..... Printo 8-30-96 In U.S.A#

Page 7FILE No. 424 07/23 '97 09:52 ID:B.A.G. CORP 214 340 4598 PAGE 4 WASTE AWAY™™ CONTAINERS Includes Stiffeners For Stability Secondary Closure Designs Available Superior Protection When Closed THREE BASIC MODELS AVAILABLE CLASSIC Our basic design PLUS SUPER • 27 cu/ft capacicy. Identical features to the Classic * Salf supporting with veneer stiffeners. with the following added benefits: identical features to the Plus with # Full open cop, with web tre closure. • Includes triple wall corrugated the following added benefits: • Four, ten inch lifung loops - UN stiffeners. • Uses a four panel protective top certified for Group ll and 1Il. • Can be double stacked in addition to the standard open top. = Raced for loads up to 2.500 Ibs. • Includes a single flap protective = UN cerufied for Group 1. Il, and Ill. # Folds flat for shipment and storage, cover in addicion to the open top. a Includes 6 mil black, LLDPE/HDPE • Includes four cabs for securing blend liner, pre-inserted. container to a paller. Corrugated stiffeners allow for double stacking with the Plus & Super versions. FLEXDRUM ' CONTAINERS LASSIC Designed to replace fiber & steel drums. 8 cu/ft capacity. PLUS Rated for loads of up to 800 ibs. Identical to the Classic UN certified for Group Il and Ill. FlexDrum ™ container with Folds flat for shipment and storage. additional added benefits: Full open top, web te closure. Includes 3 mil black, HDLL liner: * Triple wall corrugated stiffeners pre-inserted. provide a more rigid concainer. Veneer stiffeners for support. 5 Cubic Foot Model Available All products in stock - ready to ship. We accept Visa & MasterCard. Call 1-800-331-9200 for more information on our complete line of containers.#

Page 8use plastic liner-gooseneck- insert into one ind can't come out Sop of sock 2 links of webking gathered into goose neck ....#

Page 9182uNE 1997 BAG ® CORE DrAiNE, BAG HEREIS THE OLGINA, ENGR NGE 100 SURE LOOKS LIKE A DRUM! BAG INTEL, SINCE 1059 Hah compeditor sampl bay sampl approval $178-601(4) 17880111) need an out for - A wholly owned Subsidiary of S.S.B.I. 11510 Data Drive Dallas, Texas 75218 (214) 340-7060 Phone 1 800 331-9200 (214) 340-4598 Fax#

Page 10FlexDrum ™M FLEXIBLE CONTAINERS Anything a drum can do, the Flex Drum™ Flexible Container can do better! Designed to take the place of metal drums, fiber drums or boxes. Facts: • Volume of 8.5 cubic feet (equals a 55 gallon drum) • Weighs less than 10 pounds • Weight capacity of 800 pounds • U.N. certified for Class II & III hazardous waste • PE liner, 3.0 mil included, other options available • Self supporting construction • Ships and stores collapsed • Acceptable for incineration Call us today for quality solutions and expert technical support. The FlexDrum™ container is free-standing because of its unique, patented construction. R.A.C: 11510 Dola Dive, Dallas, Texas 75218 CORP 800/331-9200 • 214/340-7060 Fax: 214/340-4598 SINCE 1969 Printed 8-30-96 in U.S.A.#